Treating Cardiovascular Disease Via Gene Therapy And The...

Topic: Discuss the technologies available for treating cardiovascular disease via gene therapy and the future direction of this as a therapeutic option. Introduction The definition of cardiovascular disease as stated by the British Heart Foundation is as follows, â€Å"cardiovascular disease includes all diseases of the heart and circulation, including coronary heart disease (i.e. angina, heart attack), heart failure, congenital heart disease, and stroke. It is also known as heart and circulatory disease.† Although there are numerous subtypes of cardiovascular disease they are all interrelated by a common setback. Atherosclerosis, which is the build-up of a fatty streak inside of the arterial walls, is the mutual element that links all forms of cardiovascular disease together. The build-up of fatty plaque inside of the artery walls can have a number of negative effects on the human body. For example, angina occurs when the narrowing of the arteries due to the build-up of plaque inhibits a sufficient amount of oxygen-rich blood to pass through to the heart. Similarly, a heart attack occurs when part of the fatty plaque breaks away or ruptur es and clots the coronary arteries, drastically reducing blood-supply to the heart. Both of these conditions lead to various side effects that can significantly lower ones quality of life or even result in death. The main risk factors that increase a persons chance of obtaining cardiovascular disease include smoking, obesity, highShow MoreRelatedMerck Case18783 Words   |  76 PagesPatrick Co-principal Project Investigators Center for International and Area Studies Yale University New Haven, CT 06520 203-432-9395 (Fax: 5963) e-mail: william.rapp@yale.edu Revised December 1998 Table of Contents 1. Introduction: Objective of this Study 2. The Pharmaceutical Industry in a Global Context 3. Product RD and Clinical Trials 4. Manufacturing and Process RD 5. Technological Factors Structure-Based Drug (Rational Drug) Design Structure-Based Drug (Rational Drug) Design 6. MerckRead MoreMergers Acquisitions in Pharma Industry21425 Words   |  86 Pages ABSTRACT One plus one makes three. This is the special alchemy of Merger and Acquisitions. When two firms, often about the same size, agree to go forward as a new single company rather than remain separately owned and operated, a merger happens. Mergers facilitate synergies between the merged companies, generate efficiency, competitiveness, and increase the economies of scale, spreading costs, acquiring new technology over a large customer base. By this Research paper I have attempted implicationsRead MoreDeveloping Management Skills404131 Words   |  1617 Pages10/12 Weidemann-Book Credits and acknowledgments borrowed from other sources and reproduced, with permission, in this textbook appear on appropriate page within text. Copyright  © 2011, 2007, 2005, 2002, 1998 Pearson Education, Inc., publishing as Prentice Hall, One Lake Street, Upper Saddle River, New Jersey 07458. All rights reserved. Manufactured in the United States of America. This publication is protected by Copyright, and permission should be obtained from the publisher prior to any prohibitedRead More_x000C_Introduction to Statistics and Data Analysis355457 Words   |  1422 PagesIntroduction to Statistics and Data Analysis This page intentionally left blank Introduction to Statistics and Data Analysis Third Edition Roxy Peck California Polytechnic State University, San Luis Obispo Chris Olsen George Washington High School, Cedar Rapids, IA Jay Devore California Polytechnic State University, San Luis Obispo Australia †¢ Brazil †¢ Canada †¢ Mexico †¢ Singapore †¢ Spain †¢ United Kingdom †¢ United States Introduction to Statistics and Data Analysis, Third

The War On Drugs in the USA Essay - 465 Words

The War On Drugs in the USA One of the most explosive issues in the current American political climate is illegal drug use. Drug abuse is intimately connected to problems like crime, economic discrimination, and race relations, and is a topic of great controversy for many Americans. The campaign to stamp out illegal drug use is called the â€Å"war on drugs† because it pinpoints the need to crack down on drug dealers, arrest users, and generally pursue an enormously expensive law enforcement agenda. The war on†¦show more content†¦Africa-Americans comprise 12.2% of the population and 13% of drug users, but 38% of those arrested for drug offenses, and 59% if those convicted are Africa-Americans. The war on drugs is taking a toll on low-income, minority families, adding to the obstacles between them and economic success. A lot of poor youths turn to illegal drug use and the illegal drug trade because they are looking for a better life. If we use the money spent on fighting the illegal drug trade to educate these poor youths we would give them a way to gain economic and social success. They would not have to enter the illegal drug trade looking for a way out of the slums. Drugs are an issue of government and political debate. Lower income families will deal drugs trying to make a better life for themselves, but instead end up being addicted and committing crimes to feed their habit. In the United States 9% of whites live in poverty, compared with the 31% of blacks living in poverty. Because of this percent of blacks living in poverty there are more involved in illegal drug use and sales. This makes the police more skeptical when they see a black person in a place they think he shouldn’t be. The racial disproportionate nature of the war on drugs is not just horrible on the black Americans. It contradicts faith in the principles of justice and equal protection. TheShow MoreRelatedThe War On Drugs And Drugs1199 Words   |  5 PagesThere was so much information on this topic of the War on Drugs that I am still wrapping my mind around it. It went into such detail about the war on drugs that are never talked about. We always hear â€Å"just say no.† I know that drugs are a very big problem in our society and even the whole world but I never knew to what extent it really was. I found it very interesting how Johann Hari interviewed these people who were in the middle of the drug war and their stories. It really opened my eyes to whatRead MoreThe Mexican President Felipe Calder989 Words   |  4 PagesName: Kevin Whitten Topic: Mexico s War on Drugs Purpose: Inform Organizational Plan: Topical Introduction Attention Getter: A bloody war has been raging on in North America for the last four years which has resulted in over 34,500 deaths as of December 2010, which was by far one of the most violent years so far with over 15,000 people killed. Speaker Purpose: Having been stationed in Fort Hood Texas for three years I often visited Mexico and being an addict in recovery, in some smallRead MoreThe Rights Of The Child1186 Words   |  5 Pagesto children alone. Among these rights are topics such as survival and development, drug use, free expression, the child’s best interest, and violence. This essay discusses two books, which examine these rights and the ways they are influenced. Survival and Development is a right given in the Convention of the Rights of the Child. To Ishmael in A Long Way Gone, this played a large role in his struggle during the war. When he and his friends are running from village to village, the boys find themselvesRead MoreTraffic : The Post Modern Civil War1639 Words   |  7 PagesCivil War Traffic is a film written by Simon Moore and Stephen Gaghan, directed by Steven Soderbergh, and released in 2000 by USA Films. The movie tells three different stories. The first story is of two Mexican police officers, which become entangled in the Mexican cartel war, during a drug bust of one of the cartels. The second story in the movie is about a conservative federal judge in Ohio who has been appointed by the President to the position of director of the Office of National Drug PolicyRead MoreThe War On Drugs And Its Impact On The United States1396 Words   |  6 PagesThe current policy in use by the United States concerning illegal drugs is both outdated and unfair. This so-called war on drugs is a deeply rooted campaign of prohibition and unfair sentencing that is very controversial and has been debated for many years. The war on drugs is designed so that it will never end. This current drug was has very little impact on the overall supply of prohibited drugs and its imp act on demand seems non-existent. United States’ taxpayers are spending billions of dollarsRead MoreEssay Why All Drugs Should Be Legalized 1468 Words   |  6 Pagesforgetting the modern day prohibition: The War on Drugs. The History of The war on drugs Why didn’t we listen to Lincoln? People have been using drugs for thousands of years. The first anti-drug laws in the USA were solely based on the public’s views on the laws; mostly racist propaganda. The very first anti-drug law was outlawing Opium in 1870 which was aimed at Chinese immigrants. Then in the 1920’s Cocaine became illegal; which was aimed at Black men. The first drug laws were just about the governmentRead MoreChildren At 25 Or 45 Essay1399 Words   |  6 Pagestheir strong sides, and in my view, both of them are suitable for building a family. Private exploration of space – expository In the twentieth century there were two main explorers of the outer space – USA and USSR. In the modern technology world along with governments’ spaceflights, private exploration of space has become popular. Private space investigation is the term used to describe a space exploration, paid by entrepreneurs and large private companiesRead MoreEssay Bushs War On Terror and the Erosion of Civil Liberties643 Words   |  3 PagesBushs War On Terror and the Erosion of Civil Liberties Nearly all the amendments in the Bill of Rights have been reduced since the beginning of the war. The fourth through eighth amendments have been especially hit hard by this â€Å"war.† Search seizure, due process, a speedy and public trial with a jury, and cruel unusual punishment have all been disregarded as part of the current administration’s policy. The â€Å"War On Terror† has effectively eroded the civil liberties that Americans foughtRead MoreAmerica Needs A Second Reconstruction Era1425 Words   |  6 Pagesera. For one to understand that the United States of America needs a third reconstruction era, one must first understand what a reconstruction era is and what occurred in the first two. The first reconstruction took place after the American Civil War. Even though slavery had been abolished, newly freed slaves still found themselves second class citizens but as time passed, the 14th Amendment was changed to include freed slaves as citizens of the United States and thus were entitled to equal protectionRead MoreWhistleblowing629 Words   |  3 PagesRanbaxy is an Indian Multinational pharmaceutical company that was producing generics drug for USA market. In this case, Ranbaxy was denouncing by Thakur, an American chemical engineer. When  he was working for the organization, he stated that the company was making a generic medicine like â€Å"Lipitor† without any data supporting the research. In 2005, the whistleblower brought the case to America and reported to Food Drugs administration in Maryland. On June 2012 he testified that when he reported the

Child Abuse and Sex Trafficking Essay - 1637 Words

As for myself, I have seen inappropriate situations and first one is that I had seen a man caressing and going to make love with a woman under the bridge at the park while two children at probably under six years old uneasily watched and tried not to watch at same time. Other time was a small child walking to the bus stop with no people and a few blocks on a busy street and finally a man came up to her. That bothers me wondering he is a bad or good person which still haunts me. My problem is I have no cell phone to call or to take picture which is worth a thousand words that led me to wonder how common is child abuse, sex trafficking and what are we dealing with. It is a ongoing worldwide†¦show more content†¦Early marriage between a girl and an adult man is common and still are common in the third world such as India, Central Africa and other countries. Child trafficking is a huge business that makes billions of dollars every year by using children for many different purpo ses. They use children for sexual purposes, labor, to be adopted and even to become a soldier for their group. The cultures influenced the habits to be passed down from generation to next generation and the culture and religious patterns allows the parents to kill their children or abandon them (Trafficking of Children). The child marriage report on National Geographic caught my eye as a wedding of those 5, 10, 13 years old girls at India and it is common practice as often poor parents are offered to sell their daughter to pay off their debts or obligations. There are some arranged marriages by families choice, not the bride or groom and for those daughters who waits are coming from the well to do families that there is no reason for selling off their daughters. The child physical abuse is world wide spread and the principles differ due to the culture and society (Child Brides). Davenport 3 The USA TODAY newspaper reported by Laura Ramirez on the children trafficking and theShow MoreRelatedThe Statistics Of Prevalence For Child Sex Abuse Essay1483 Words   |  6 PagesThe statistics of prevalence for child sex abuse varies because of all the unique cases of child sex abuse that is reported. Although, statistic show that one in three girls will be sexually abused at one point in the United States and boys are one in seven to be sexually abused (Anderson, 2014). Children are not susceptible to crime as shown in the statistics because predators like pedophiles have fetishes towards little boy or girls. One study found that 10% of children experienced or came closeRead MoreChild Pornography And Child Trafficking Essay1197 Words   |  5 Pages000 SEX TRAFFICKING BOOK. More than 80% of these victims are women and girls, and 70 % of them are forced into sexual servitude SEX TRAFFICKING BOOK. When a person obtains children for the purpose of sexual exploitation or child pornography and plan to victimize these children for illegal activities, this is defined as commercial sexual exploitation Commercial Sexual Exploitation Fact Sheet. UNICEF Commercial Sexual Exploitation, which includes child trafficking, child pornography, and child sex tourismRead MoreChild Sex Trafficking877 Words   |  4 PagesWhen some people hear the expression â€Å"child sex trafficking† inevitably unspeakable thoughts come to mind, others are unaware this is even happening. Sex trafficking is a serious criminal issue taking place within the borders of the United States, but on the outside of these boarders this crime stands as a reliable source of income for those who participate. Although child sex trafficking is a local crime it is obvious that multiple nations have different viewpoints on the topic. The problem at handRe ad MoreThe Worlds Oldest Profession1574 Words   |  7 Pageslifestyle. In today’s society, sex sells. There are many factors that are making sex a commodity that can be bought or sold. There is a quote that states â€Å"Prostitution is the world s oldest profession†. Some find this statement true but there are many advocates groups who are fighting to end this profession. In this paper we will explore the history, the business side, the players who are involve in the world of prostitution and how it is related to sex trafficking. Also the different factors thatRead MoreNo More Sex Trafficking?1689 Words   |  7 PagesMore Sex Trafficking Human sex trafficking is an illegal trade that is steadily increasing in the United States. In particular, human trafficking starts with young children. Around the world today, 5.5 million children are victims of trafficking (Bales, Free the Slave). Young children become victims to sex trafficking for many different reasons. How they enter into the system is one issue, but who is there to help them get out is a bigger issue? Children are forced into the sex trafficking systemRead MoreDomestic Minor Sex Trafficking : Prostitution Or Exploitation?1518 Words   |  7 PagesDomestic Minor Sex Trafficking: Prostitution or Exploitation? Although the history of child sex trafficking in developing nations has been widely documented, recently research has revealed that minor sex trafficking (also known as child prostitution) is a growing problem within U.S. borders as well. â€Å"Child prostitution is the sexual exploitation of a minor for profit, which can include money, drugs, or other items of value† (Center for Arizona Policy, 2014). The sexual exploitation of minorsRead MoreThe Problem Of Human Trafficking1168 Words   |  5 PagesImagine a small child, who cowers in the corner of a dark room. The child sits there in silence trembling with fear, and all you can hear is your heart beating faster and faster. Above the helpless child stands a creepy looking old man. He is not there to comfort the child, or help them in their time of need, but rather to have sex with the adolescent; or auction them off to other older, creepy looking men. This is a form of what we know today as human trafficking. The traff icking in persons is aRead More Child Trafficking Essays1660 Words   |  7 PagesChild Trafficking â€Å"The global market of child trafficking is at over $12 billion a year with over 2 million child victims† (â€Å"Stop Child Trafficking Now† 1). This statement from the article â€Å"Stop Child Trafficking Now† describes how serious this crisis is nationwide. Child labor, illegal adoptions and child prostitution are the three forms child trafficking typically exists as (â€Å"Riverkids Project† 1). There has been a rising number of Cambodian children being trafficked for sexual exploitationRead MoreVictims of Trafficking Protection Act Essay1716 Words   |  7 Pagessingle piece of legislation that deals with trafficking. Countries should be held accountable if they do not comply. The only way that sex trafficking can be officially over is if every single country complies with all the legislation. The United States looks at six different factors when deciding if they have met the criteria for eliminating trafficking. The United States looks at wheth er the country has investigated and prosecuted severe forms of trafficking, if they protected the victims, educatedRead MoreCambodia: A Place of Countless Struggles1545 Words   |  6 Pageslack of education, abuse, and sexual trafficking consume most of Cambodia, and the government continues to let these issues flourish. One of the most prominent problems Cambodia battles with is the sex industry, with prostitution and trafficking rates skyrocketing. According to recent human trafficking statistics, an immense amount of victims are sexually trafficked and exploited in Cambodia each year, but 80% of victims are young women and girls (Bertone). While sex trafficking affects nearly every

Essay on Drive a Car Not a Cell - 945 Words

Drive a Car Not a Cell While operating a vehicle, all cell phone usage should be illegal. Not only is it dangerous for the driver but it also dangerous for the other drivers on the road. Drivers on the road today have many disturbances that impact their driving skills. Necessary action needs to be taken to limit more major harm due to cell phone usage while driving today. (Word Count: 64) First and foremost, cell phone use while driving can be distracting to the driver. Some may say in today’s society, most people need to be in touch with others on cell phones. However, this need to be continuously informed on the social world is not a necessary quality to have while driving. ANSWERING THE OPPOSITION. Instead, drivers need to put down†¦show more content†¦However, cell phone use while driving has not only increased, but so has accidents caused by cell phones. In the January of 2010, Michael Edward Wolsynuk was texting and driving in the Victoria-area in Canada when he lost control of his car. He hurdled into the median and then crashed head-on into an incoming truck. Wolsynuk was killed in the accident (Mulgrew). Driving a vehicle takes the drivers full attention in order to stay in control of the car. A Nationwide Insurance examination approximates 73 percent of total operators use their phone. Also discovered was 87 percent of mature drivers consider that a driver’s capability to driver is damaged while using a cell phone (Hazewski). Drivers know that cell phone usage is wrong while driving and yet they do it anyway. The University of Utah’s Applied Cognition Laboratory found that the reaction of an operator of a vehicle while on the phone is comparable to someone that is legally intoxicated (Hanes). Thus, this shocking outcome should make drivers think twice before using their cell phone. Drivers can easily lose control of their vehicle. (Word Count: 262) Finally, driving while using a cell phone is not only risky to the driver but also to passengers and others driving on the roads. 19 year old, Chelsey Murphy, is an example of this. On March 9 of 2010 in Naples Florida, Murphy was four months pregnant and crossing the street with her friend when teen driver, AbrahamShow MoreRelated Drive a Car, Not a Cell Phone Essay1898 Words   |  8 Pagesâ€Å"When a driver ‘talks and drives’ they are not only putting themselves at risk, they are also putting everyone around them in a dangerous situation† (ComparisonMarket.com). A study conducted last year by the Virginia Tech Transportation Institute, had cameras placed inside one hundred cars and trucks to track drivers activities before a dangerous event occurred. Research shows users of cell phones while driving caused far more crashes and near misses than non-users. These statistics do not changeRead MoreEssay about The Solution to Texting and Driving1145 Words   |   5 Pagesdriving accidents. These days, many strive to be connected with the world and their friends by using mobile devices. The problem is that numerous people tend to do so at bad times. For example, while one is driving, it is common to look down at the cell phone to send a short text message that could put their lives in harm. Across the nation, numerous advertising and support groups are spreading the word to encourage society to put phones down and focus on driving instead of texting. However, it reallyRead MoreIs Inattentional Blindness So Different Between The Two Tasks?1040 Words   |  5 Pagesefforts I still do use my phone and drive. Most people seem to fall into the same trap, but can we text and drive safely? According to David L. Strayer and Frank A. Drews research, no. It’s estimated that 100 million drives use a phone and drive. Yet people are not distracted as much by the radio, or audio books, why? The researchers wanted to see why inattentional blindness i s so different between the two tasks. To test this participants were placed in a car that had been modified for the lab, toRead MoreThe Effects Of Technology On The World1130 Words   |  5 PagesThere are many dangers in the world. 33,561 fatal car accidents occurred in 2012; 3,328 of these deaths were due to texting and driving.421,000 people were injured in automobile accidents due to distracted driving. Many people believe that it is safer to drive a car than fly in an air plane, ironically statistics show that cars are much more dangerous. Prior to modern day technology drivers were distracted by passengers, drinking, music, make up, talk shows, lighting cigarettes, or eating. RecentlyRead MoreCar Accidents Caused By Drivers882 Words   |  4 PagesCar accident can happen to drivers and passengers anytime, and anywhere. Even though we are more pay attention to the safety of the cars, car accidents is still happening. At the same time, car accidents is an important issue aroun d the world. It has become a significant factors leading to death. Car accidents can be caused by three factors, including the bad driving conditions, personal driving habits and car conditions. Firstly, the bad driving conditions can cause car accidents. Drivers can’tRead MoreTexting While Driving, Deadly Or Not?1416 Words   |  6 Pagesdrivers on a statewide basis. A federal survey showed that there are ninety four percent of Americans that think texting and driving should be illegal. Clearly, car accidents have increased because of the use of cellphones while driving and something more must be done about this problem. The first topic is about how texting while driving causes car accidents. The number of teens dying or being injured has skyrocketed because of this. Texting while driving has become a greater risk and hazard than drinkingRead MoreAdvertising On Not Be Drinking And Driving960 Words   |  4 Pagesthat says â€Å"Drive sober or get pulled over†, meanwhile a cop is putting a man behind bars for driving while intoxicated. As you’re driving down the highway on your way to work, you see a bulletin board with the same phrase, â€Å"Drive sober or get pulled over.† It is a constant reminder that you’re given and the consequences are severe. High schools around the nation created something called â€Å"Shattered dreams†. It involves a play with voluntary students from the school who drink and drive only to getRead MoreDifferent Types Of Vehicles On The Road Today1273 Words   |  6 Pageswhich incorporate some type of internal combustion engine whether it be gasoline or diesel. In modern times however, consumers have been given the option to purchase vehicles that are either fully battery powered or contain a mixture of battery fuel cells as well as an internal combustion engine. The reason for this change has to do with the pollution created by internal combustion engines. The fuel used to power internal combustion engines produce many harmful gases to the atmosphere such as carbonRead MoreCell Phones While Driving Essay642 Words   |  3 PagesCell Phones and Driving In today’s society we’ve all become attached to our cell phones. Cell phones make our lives easier in many ways we can check our email, receive phone calls, send text messages, listen to music, and take pictures, all at our finger tips. With all this convenience, however there is a dangerous side to cell phones, and that’s when we use them while driving. Most of us are guilty of using cell phones while driving, but have we ever thought about its danger? Five states plusRead MoreTexting And Driving Is Wrong921 Words   |  4 Pagesbecause of the deviant behavior and mindset towards texting and driving. When you text and drive you are knowingly taking a risk of an accident because of how texting distracts a person from driving properly. Texting and driving is when you use your phone while operating a motor vehicle. When making this choice to do this, drivers often: drift off to the sides of roads, run stop signals, run into another car, etc. Using your phone any kind of way is distracting because you are taking your eyes off

Judicial Precedent in the English Legal System Free Essays

string(42) " of the decisions of the superior courts\." The doctrine of judicial precedent is based on the principle of stare decisis which means ‘to stand by what has been decided’. It is a common law principle whereby judges are bound to follow previous decisions in cases where the material facts are sufficiently similar and the earlier decision was made in a court above the current one in the court hierarchy. This doctrine of precedent is extremely strong in English law as it ensures fairness and consistency and it highlights the importance of case law in our legal system. We will write a custom essay sample on Judicial Precedent in the English Legal System or any similar topic only for you Order Now Black’s Law Dictionary defines â€Å"precedent† as a â€Å"rule of law established for the first time by a court for a particular type of case and thereafter referred to in deciding similar cases. † For this system to operate successfully, in both criminal and civil courts, three things are required – a settled court structure, a ratio decidendi and accurate records of the decisions made by superior courts. A settled court structure is required as judges need to know which decisions they are bound to follow. The English Court hierarchy was largely established by the Judicature Acts 1873-75. The House of Lords was made the final appeal court in 1876 under the Appellate Jurisdiction Act, in 2009 the Supreme Court became the final appeal court. There are two court systems, criminal and civil, and they both contain various appeal routes in a vertical court structure. As the UK is a member of the EU, the European Court of Justice and the European Court of Human Rights bind all English Courts in respect to matters within their jurisdiction. For criminal cases the Supreme Court, formally the House of Lords, is the most superior court in the hierarchy. It binds all courts lower than itself and generally follows its own past decisions. The next court below in the hierarchy is the Court of Appeal (Criminal Division), they are bound by the past decisions of the Supreme Court/House of Lords and its own past decisions. Both Supreme Court and Court of Appeal have a way of avoiding following their own binding precedent which I will discuss later. Below the Court of Appeal is the Queen’s Bench Divisional Court, they are bound by both Supreme Court and Court of Appeal. They are bound by their own past decisions however they can take a flexible approach in order to protect the liberty of the individual in question. The last two courts in the hierarchy are the Crown Court and Magistrates Court. These courts are bound by the Supreme Court, Court of Appeal and Queen’s Bench Divisional Court however they are not bound by their own decisions and they do not bind any other court. The civil court hierarchy is different; the Supreme Court is still the superior court, followed by the Court of Appeal (Civil Division). The next court down the hierarchy is the Divisional Courts of The High Court, which are bound by the Supreme Court and Court of Appeal, also bound by their own decisions. The next court is the High Court, they are bound by the decisions of all three superior courts and the decisions of the High Court bind the two inferior courts which are the County Court and Magistrates Court. The inferior courts are bound by all superior courts but they are not bound by their own past decisions. The ratio decidendi, ‘the reason for deciding’ is the legal principle which the decision of the court is based upon. It is the ratio decidendi which forms the binding precedent which must be followed in future cases of similar fact, the same court and all courts below it. An example of a ratio decidendi is in the case of R v Howe (1987) where the House of Lords held that the plea of duress was no defence against the charge of murder; this judgement became binding precedent which must be followed by the Supreme Court and all courts below it. It is also important to mention the obiter dictum which forms the remainder of the judgement. An obiter dictum means ‘other things said’ and these statements do not bind however they can form highly persuasive precedent. An example of an obiter dicta statement is also found in the case of R v Howe (1987) where the judge stated that if the charge had been attempted murder rather than murder, then duress would still not have been available as a defence. This statement was obiter dicta because it did not directly relate to the facts of this particular case. This persuasive precedent was followed in the case of R v Gotts (1992) where a defendant charged with attempted murder tried to use the defence of duress in the Court of Appeal. The ratio decidendi of R v Gotts (1992) then formed its own binding precedent. Other persuasive precedents include decisions of the Scottish courts and those made in the courts of other Commonwealth countries such as Australia and Canada. This may be because a case with these particular facts has not been heard in the English Courts before but may have been heard in another country. This was the case in R v R (1991) where the Court of Appeal and House of Lords followed previous decisions made by the Scottish courts that a man could be found guilty of raping his wife. Another persuasive precedent are dissenting judgements which come from the appeal courts. In the Supreme Court and Court of Appeal the cases are heard by more than one judge and sometimes a decision is reached by only a majority of these judges. The judges in the minority will also give a judgement for why they came to their decisions and this is called a dissenting judgement. A dissenting judgement was followed by Lord Denning in the case of Candler v Crane Christmas (1951). The final requirement to ensure effective operation of judicial precedent is that there needs to be accurate records of the decisions of the superior courts. You read "Judicial Precedent in the English Legal System" in category "Papers" These can be found in Law Reports. It is crucial that accurate records are available so that it is possible for the binding and persuasive precedents to be found. One example of a law report is the All England Law Report, law reports are also found in the media, The Times publishes law reports weekly. The reports contain all relevant information relating to the case – names of litigants, cases used, solicitors, barristers, a summary of the facts and the judgement itself. There are a number of advantages and disadvantages to judicial precedent and how it operates in the courts in England and Wales, most advantages have corresponding disadvantages. One advantage is the certainty it provides, as the courts follow past decisions. Due to this certainty people are more aware of what the law is and have a better idea of how it may be applied in their case. In the House of Lords Practice Statement 1966 it points out how important certainty within the law is. Another advantage is consistency and fairness in the law so it can be seen that similar cases are decided in a similar way. In order for law to be credible it must be consistent. For example, the ratio of R v Howe that duress is no defence to the charge of murder must be followed in cases of similar material fact. There is a wealth of detail contained in the reported cases. The principles set out in the cases are a response to real life situations and things that may have occurred and this can guide future litigants. Over time the law will become more precise as it will gradually be built up by all the variations of facts that come before the courts. Judicial precedent is also flexible and there is room for the law to change as the Supreme Court can use the Practice Statement to overrule cases. An example of flexibility is in R v R, after the judgement was made, Parliament amended the Sexual Offences Act 1956, stating that marital rape is a crime. The doctrine of precedent also allows for new or ‘original’ precedents to be created. This will occur when there are no previous decisions on the case before the court or there is no legislative provision. Therefore an original precedent makes legal provisions for a matter for which there was previously no law. An example of this, where the matter had no come before the court before and Parliament had no guidance to offer, is found in Gillick v West Norfolk and Wisbech Area Health Authority (1985). In this case the House of Lords had to decide whether girls under the age of 16 could be prescribed contraceptives without parental consent. The Lords decided that girls could be prescribed contraceptives in this circumstance, provided they could understand the issues involved. Judicial precedent can also been seen as a useful timesaver. Where a principle has already been established, cases with similar material facts are unlikely to have to go through a lengthy litigation process. A major disadvantage of judicial precedent is how rigid it is. An unjust precedent can lead to further injustices, as once the Supreme Court sets an unjust precedent it won’t be overruled until a case with similar facts goes on to the Supreme Court on appeal. The chances are that this may not happen for many years. Also, the law may become outdated and require modernisation. An example of this is where judges since the 1960’s had felt that the law stating a builder did not owe a duty of care to persons they had sold a house to was unfair. Lord Denning made obiter comments regarding this to the effect that a duty should be owed. However the law was not changed until 1978 in Batty v Metropolitan Property Realisations Ltd where it was held that a duty of care was owed. Sometimes the law will only be changed if an individual had the courage, the persistence and the money to appeal their case. It can be very difficult for anyone to conduct thorough research into the law; hundreds of judgements are made every year so it can be hard to discover the precise law on a matter. In order to find this out a person may have to search through many volumes of law reports, the complete official law reports are estimated to run to almost half a million pages. The judgements are often complex and therefore it can be difficult to determine what the ratio decidendi of a case actually is. In the Court of Appeal and Supreme Court there is more than one judgement to consider and a common ratio must be decided by the judges in future cases. A judge may also give more than one ratio, for example in Rickards v Lothian (1913) where Lord Moulton gave two ratios for not holding the defendant liable. Judgements themselves are often long with no clear distinction between comments made and the reasons for the decision. In Dodd’s Case (1973) the judges in the Court of Appeal were unable to find the ratio in a decision of the House of Lords. Also, the use of distinguishing to avoid past decisions have lead to some areas of law becoming very complex. It can also be argued that judges are overstepping their constitutional role by actually making the law rather than just applying it. Judicial precedent maybe seen as undemocratic as it is the role of Parliament to create law, the judiciary are there to enforce it. In the same way it can also be seen as undemocratic as judges are not elected and therefore should not be making law. Another disadvantage is that there is no opportunity for the judge to research or consult experts on the likely outcomes or effects of their decisions. Therefore judges are confined to making their decisions based on the arguments presented in the course of the case. Despite the doctrine of judicial precedent being a major factor in the English legal system, there are a number of ways by which a judge may avoid following a precedent. Distinguishing is a method which can be used by a judge to avoid following a precedent. If a judge finds that the material facts of a current case are sufficiently different from those of a previous precedent and can draw a distinction between them, then he is not bound by the previous decision. Two cases that demonstrate this process are Balfour v Balfour 1919) and Merritt v Merritt (1971). In both cases a wife was making a claim against her husband for breach of contract. The judgement in Balfour was that the claim could not succeed as it had been a domestic arrangement rather than a legal one and therefore was not legally binding. In Merritt the court held that there was a legal contract between husband and wife and the agreement had been made in writing and took place after they had separated. This distinguished the case from Balfour, the agreement in Merritt was not just a domestic arrangement, and it was a legally enforceable contract. This provided sufficient differences between the cases that the judge in Merritt did not have to follow the judgement made in Balfour. Another mechanism which can be used by judges to avoid following precedent is overruling where a court in a later case states that the legal ruling decided in an earlier case is wrong. Overruling is where a higher court does not follow a precedent set in a previous case, either by a lower court or by itself. This may occur when a higher court overrules a decisions made in an earlier case by a lower court. An example of a superior court overruling a previous precedent set by a lower court is Hedley Byrnes v Heller and Partners (1964) which was a claim for damages arising from negligent and misleading advice. The House of Lords overruled the decisions of the majority in the Court of Appeal in Candler v Crane Christmas (1951) and held that there can be liability for making a negligent mis-statement. However, too frequently overruling casts doubts on the certainty of the law and leads to inconsistencies. For lawyers to be able to give good advice the law must remain relatively â€Å"safe to predict† and this not the case if senior judges use every available opportunity to reverse the decisions of their predecessors. Some alarm was caused in the 1986 case of R v Shivpuri (1986) which was the first use of the Practice Statement in a criminal case. The House of Lords overruled their own previous decision made in Anderton v Ryan which had only been made twelve months earlier as they believed that the law (Criminal Attempts Act 1981) has be incorrectly applied. On the other hand, the House of Lords have often been reluctant to overrule even bad previous decisions. This was illustrated in Jones v Secretary of State, where the decision in R v Dowling was allowed to stand even though four of the seven Law Lords thought it was wrong. The need for certainty is still highlighted in the decision of the House of Lords since 1966. Both of these practises can be useful in allowing flexibility within the law but can also lead to uncertainties and inconsistencies which undermine the reliability of the system. However, where these two parallel ideas of certainty and flexibility is concerned, there will never be one definite solution to satisfy all. Disapproving can also be used by judges to avoid following precedent; this is where a judge states in his judgement that he believes the decision in an earlier case is wrong. This may occur where the present case is on a related point of law but the point of law is not sufficiently similar for the earlier decision to be overruled. It can also occur where the judge in a lower court in the hierarchy than the court which made the original decision. In this situation the lower court cannot overrule the superior court however they can disapprove of the decision by expressing their view that it was wrong. An example of this is found in the case of R v Hasan (2005), this case was about the availability of the defence of duress by threats, to a criminal offence. The main point of the case was whether a defendant could use the defence of duress if he should have realised that he was putting himself in a position where he might be pressurised into committing an offence. Reversing is similar to overruling however it occurs where a higher court does not follow precedent set by a lower court in the same case. Reversing is where the same case has gone to appeal and the appeal court reaches the opposite decisions to that of the lower court. An example of reversing is found in Fitzpatrick v Sterling House Association Ltd (2000). In this case the Court of Appeal refused to allow the homosexual partner of a deceased tenant to take over the tenancy due to regulations laid out in the Rent Act 1977. On appeal the House of Lords reversed the decision of the Court of Appeal. The Practice Statement 1966 was issued by the House of Lords, declaring their intention not to be bound by their own previous decisions. The Practice Statement allowed the House of Lords to change the law if they believe that the decision made in an earlier case is wrong. It gave them to the flexibility to refuse to follow an earlier judgement when ‘it appears right to do so’. This was shown in the case Herrington v British Railways Board (1972) which involved the law on duty of care owed to a child trespasser. In the case of Addie v Dumbreck (1929), the judgement was that an occupier of land would only hold a duty of care for injuries to child trespassers if they were caused deliberately. In Herrington the Lords held that social and physical conditions had changes since 1929 and therefore the law should also change. The judgement in Herrington was that land owners did owe a duty to prevent injury or death to child trespassers. The Court of Appeal can also refuse to follow its own previous decisions under three exceptions that were bought up in the case of Young v Bristol Aeroplane (1944) These exceptions are as follows; If a previous decision conflicts with a later House of Lords (Supreme Court) decision, it must follow the decision of the House of Lords; if there are two conflicting previous decisions then the Court of Appeal must choose between them. †¢If its previous decision was made per incuriam e. g. mistakenly or without care †¢If the House of Lords (Supreme Court) has ove rruled a previous decision of the Court of Appeal There is an additional reason for the Court of Appeal to depart from following its own past decisions and that is where it has been disapproved by the Privy Council. Privy Council opinion has only persuasive value, it is not binding. An example of this is where Morgan Smith killed a former flatmate during a fight. His defences were that he did not intend to kill or cause grievous bodily harm; that he was suffering from diminished responsibility; and that he was provoked. The focus of the appeal was on the objective part of the test for provocation and whether the reasonable person could be given certain characteristics of the accused, in this case the characteristic of having a severe depressive illness. The Court declined to follow the opinion in Luc Thiet Thuan v R (1996). It is also important to mention in the effect of the Human Rights Act 1998 on judicial precedent. If the precedent was set before the Human Rights Act came into force, the precedent may be contrary to it. As with judicial precedent itself, there are also a number of advantages and disadvantages to the avoidance of precedent by the courts. One advantage is that it allows potential for growth and means that case law is not completely rigid. The different mechanisms for avoiding precedent allow judges to develop and modernise the law when it is necessary. An example of this is the case of Hall v Simons (2000) where the House of Lords modernised the law and held that barristers could be held accountable for negligently presenting a case in court. In this case the court refused to follow the decision made in the case of Rondel v Worsley (1967) as it was deemed that the commercial world had changed significantly since 1967. Sometimes precedents can be developed to a point in which they are seen to be unfair, avoiding precedent allow these unfair laws to be replaced with more appropriate ones. In the case of R v R and G (2003) which involved two very young defendants convicted of arson, the House of Lords used the Practice Statement to avoid following the precedent set in the case of Caldwell (1981). The question facing the House of Lords was whether the defendants had foreseen the risk; they held it was unfair to judge the actions of an 11 and 12 year old by the standard of a reasonable person. The House of Lords brought about a change in the law meaning that if the question of recklessness should come up, a subjective test is used which requires the defendant to have foreseen the risk. A disadvantage of avoiding precedent is that the law changes as a result, creating laws retrospectively. This can be seen as being unjust, as the precedent that is set applies to events that have already happened. It may be that the defendant in a case committed an act that at the time of commission was actually within the law. This was the case in R v R (1991), at the time of the attack, the law stated that a man could not be found guilty of raping his wife. Due to the retrospectively law making, the defendant was found guilty and imprisoned. When there is a chance that a judge may avoid precedent it can remove the certainty within the law and make the outcome of some cases uncertain. This is unwelcome as justice requires that cases and defendants are treated in the same way. It also causes problems for legal professionals, who will not be able to advise with certainty on the likely outcome of a case. In criminal law certainty is particularly needed because the liberty of the defendant is at stake. In the case of Howe (1987), the House of Lords held that duress was no defence for murder, whether the defendant is the principle or an accessory. This case overruled the earlier House of Lords decisions in DPP v Lynch (1975), where it was held that duress was available as defence when charged with being an accessory to murder. Also, avoiding judicial precedent does not conform with the idea of separation of power. Only Parliament should create new law and it is the role of the judiciary to apply it. However when judges avoid following precedent they inevitably create new law. 1. Black’s Law Dictionary, p. 1059 (5th ed. 1979). How to cite Judicial Precedent in the English Legal System, Papers

The Energize Insurance in India Essay Example For Students

The Energize Insurance in India Essay For Immediate Release India Insurance Industry Essay Writing Competition Winner Announced Ms Megha Asnani, Business Analyst with Accenture Service Private Limited was declared winner of the 2nd India Insurance Industry Essay Writing Competition organised by Asia Insurance Review in conjunction with the India Rendezvous. Ms Asnanis essay on the topic: An Indian Solvency II? stood out for its originality and in-depth analysis of the subject. Ms. Asnani will receive a cash prize of S$5,OOO and she will also make a presentation of the winning essay at the 5th India Rendezvous in Mumbai on 20th January 2012. The Energise Insurance in India essay competition drew entries from some of the best insurance writers in India and was Judged by a distinguished panel of top industry professionals and chaired by Mr Yogesh Lohiya, Chairman and Managing Director of GIC Re. Others in the Judging panel included: Mr Jan Mumenthaler, Head- Insurance Services Group, Business Risk Department, IFC; Ms Joan Fitzpatrick, CEO, ANZIIF; Mr Michael J Morrissey, President CEO, IS; Mr Dezider Stefunko, Chief, Insurance Unit, UNCTAD; Mr Jawaharlal Upamaka, Editor, IRDA Journal; Mr A K Roy, General Manager, GIC Re; Mr K Raghunath, Vice President, Reinsurance, Bharti AXA General Insurance Co; and Mr G V Rao, Chairman CEO, GVR Risk Management Associates. More details at wrww. asiainsurancereview. com For enquiries, please contact: Asia Insurance Review Ms Ann Tay, DID +65 6224 5583 or email: [emailprotected] com OR Mr Jimmy John, DID +91 98302 46752 or email: [emailprotected] com An Indian Solvency II? Word count : 4552 Megha Asnani Business Analyst Accenture Service Pvt. Ltd. Pune megha. [emailprotected] om megha. [emailprotected] com Years in Insurance 4. Years Pagel of 18 Insurance is the business of selling commitments of transfer of risk to the policy hold ers. Thus financial health of an insurerl is of utmost importance if it were to honor its commit ments to policy holders in form of insurance policies or treaties. However, no catastrophe is in control of any insurer thus it becomes important for the risk carriers2 to keep their claim payin g capacity at much hig her levels than its liability, at any point of time. A solvency for an insurer corresponds to its claim paying ability. An insurer is insolvent if its assets are not adequate over indebtedness) or cannot be disposed off in time (illiquidity) to pay the claim. The solvency of an insurance company (financial strength) depends mainly on whether sufficient technical reserves have been set up for the obligations entered into and wh ether the company has adequate capital as security. It can be described by the following formu la: Solvency = Ability to pay the claims of policyholders = (Policyholders assets Policyholders liabilities) In 1970s the life insurers of Europe were required to maintain the size of their assets more than the size of their liabilities by a margin. This margin was known as Solvency Marg in. This margin takes care of unanticipated claims that have potential to make an insurer insolvent thereby creating an awkward situation for the insurance company, regulator as well as the government. The solvency margin is thus aimed at preventing such a crisis. Nowaday s solvency margins have become norm in Insurance Industry globally. Indian Solvency Norms In 1994, the Union Ministry of Finance constituted an expert group to formulate solvency margin requirements for Indian insurance companies. The regulations of many countries before framing the current regulations. As per the IRD A (Assets, Liabilities, and Solvency Margin of Insurers) Rules 2000, both life and general insurance Insurer here refers to Direct Insurers and Reinsurers operating in life and non- life domains Insurers or Reinsurers 2 Page 2 of 18 companies need to maintain solvency margins. Indias solvency regulation is a hybrid of the I-JK and Canadian norms. The regulation follows the UK model while the regulators admi nistrative fiat to maintain a 50% extra margin is taken from Canada. This 50% extra capital cush ion is to make sure that a breach is never reached by insurers or has a very low probability. It also nsures that a fraudulent insurer is caught much earlier. According to IRDA (Assets, L abilities and Solvency Margin of Insurers) Regulations, 2000, all insurance companies are required to maintain the solvency ratio of 150% at all times. It also mandates all insurers to file the Statement of Solvency Margin (General Insurers) as on March 31 every year. But post relaxation of controls on the tariffs for the general insurance industry, there was a need to moni tor the solvency position of all insurers at shorter intervals. The regulator mandated all insurance companies to file their solvency position as at the end of each quarter. It was expecte d that the stipulation would enable insurance companies to lay down their business plans and be in a position to meet their capital requirements in a timely manner. Challenges/ issues in the present solvency norms in India Solvency is a part of prudential norms and as risks increase across markets, the solve ncy margin also needs to go up tangentially. In order to satisfy the solvency margin requirements, companies have to systematically build up reserves by transferring a part of the surplus to a special reserve called Solvency Margin Reserve. However, transferring the surplus w ll result in a reduction in bonus rates declared and make insurance unattractive vis- a-vis other financial instruments. Therefore, only a part of the amount needed to meet solvency margin requirements can come from the surplus held back. The balance requirement has to be met by other sources for capital, which include: Share capital Free reserves in the shareholdersfund Difference between the market value and book value of assets Page 3 of 18 This coupled with the FDI restrictions in private insurers and mandatory majority gov ernment shareholding in public insurers constrains capital raising and poses significant challenges for nsurers to maintain 150% solvency margins in a fast growing industry scenario. What is Solvency II? Solvency II is an European Union (ELI) legislative programme to be implemented in all 27 Member States, including the I-JK. It introduces a new, harmonized EIJ-wide insurance regulatory regime. The legislation replaces 13 existing EIJ insurance directives. The o bJectives of implementing Solvency II are: Improved consumer protection: It will ensure a uniform and enhanced level of policyholder protection across the ELI. A more robust system will give policyholders greater confidence in the products of (Re)insurers. Multicultural Education: Piecing Together the Puzz EssayAs ins urers take steps to better manage their capital, theyll generate more operational data, which in turn will enable more informed and improved decisions. A study conducted by SunGards found that more progressive organizations, typically large companies with more than E25 billion in assets, see Solvency II as a real opportunity to create business advantage. They are likely to commit management resources to understanding the scope of the work involved and are gearing up their people and processes accordingly. Solvency II is an incentive for both insurers and reinsurers to adopt a risk- based management approach that is based on properly measuring and managing their risks. Solvency II would break the departmental silos as it would require Senior executives, risk, actuarial and IT de partments would require to work together to develop the reporting practices, management reports and other internal MIS necessary for building a risk aware corporate environment thereby providing Page 7 of 18 ctive on other business opportunities that the company should be exploring. As they optimize their governance structure and enhance their reporting standards with statuary reports and public disclosure, the business as a whole will benefit. By implement new risk management processes and systems, insurers will improve their ability to track and report their exposure to r isk. Asa result, they will be in a much stronger position as they plan for business developmen t, manage their liquidity and risk appetite to optimize their return on capital reserves. To summarize, Solvency II promises to bring greater transparency to insurance ompany operations along with more and better information for improved operations and competitive advantage. By addressing the wider ERM issues raised by Solvency II, companies can minimize operational risk, potentially minimize the IT cost base, implement enhanced processes that create a more flexible organization and so potentially lower their capital requirements. Companies who imbibe the principles and purpose of solvency II would also get competitive advantage apart from maintaining good financial health of the organization. Challenges to implementing Solvency II norm Data Collection for timely risk assessments Collation of accounting, risk and actuarial information Systems process and data need to be streamlined Solvency II directives shall affect monocline insurers and benefit the large diversified groups as they would avail the benefits of diversification credits. This can discourage the specialist insurers such as Health insurers. Page 8 of 18 Challenges before IRDA and an Indian Solvency II Initiative The IRDA was founded, to protect the interests of the policyholders, to regulate, pro connected therewith or incidental thereto. Since opening up of Insurance Industry IRDA continues to refine t e Indian regulatory environment and address India- specific problems and purposes like 0 Increase insurance penetration Extend the insurance services to rural areas of country Improve financial literacy Create conducive environment to attract more new players in market. Regulations for curbing malpractices and set up systems and process to protect inter est of policy holders. Ensure overall growth of the sector by following Inclusion Philosophy. Today, there are 2 dozen general insurance companies and an equal number of life i nsurance companies operating in India, and the insurance sector is a ignificant piece of the Indian economy, growing at a rate of 15 to 20 percent annually. Most companies are Joint ventures with foreign partners thus close attention is being paid to how Solvency II will play ou t in this marketplace. The European Unions Solvency II regulations promise to be a huge catalyst for change within the insurance industry. Though it is not expected that IRDA would exactly replicate the model of Solvency II in India however it can learn many new and better ways to regulate the sector. Solvency II has had its own share of appreciation and criticism, and considering both, IRDA can formulate norms and guidelines or systematic and exponential growth of the industry adopting some of the guidelines relevant to Indian Insurance industry from Solvency II. IRDA has initiated some action on these lines. The recent guidelines issued by IRDA to Indian insurers broadly suggest alignment with the Solvency II regime that in Page 9 of 18 Beginning with the initial IRDA Regulation in 2000, IRDA has issued ongoing updates and guidelines both for company activities within India as well as for compliance with Inte rnational Financial Reporting Standards (IFRS). Some of the key areas touched upon by IRDA in an ndeavor to prepare Indian Insurance sector for an Indian Solvency II regime are: Capital Management The IRDA Regulation 2000 a set of regulations for valuation of assets, liabilities and solvency margin and the minimum capital requirement for setting up of insurance companies, ensure s that the capital with each insurer is large enough to withstand any eventuality. At present, the Indian insurance industry follows a simple formulaic approach and is related to the total amount of business that an insurer transacts. The minimum solvency capital that insurers are required to hold is 150% of Required Solvency Margin (RSM) calculated a per the guidelines. No ratios have been prescribed for assets, and the solvency margin is sim ilar to EIJ Solvency l. Recently, IRDA has asked the companies to calculate economic capita14 and submit their calculations along with the Appointed Actuaries Annual Report beginning with their actuarial valuation. IRDA has published a report on calculation of economic capital as a reference for Indian insurers. Insurers are required to conduct a calculation of economic capital an d submit a report every year starting from 31st March 2010. The EC calculation recognizes the capital requirement for specific risks a non- ife insurance company is exposed to, as opposed to a formula approach based on simple proportion of premium or claims. The EC is calculated as the sum of EC for: Underwriting Risk, Market Risk and Other Risk. 4 Typically, Economic Capital is calculated by determining the amount of capital that th e insurer needs to ensure that its realistic balance sheet stays solvent over a certain time period with a pre- specified probability. E. g. The EC may be determined as the minimum amount of capital required to make 99. 5% certai n that the insurer remains solvent over the next twelve months Page 10 of 18

Andy Warhol the Founder and a Major Figure Essay Example For Students

Andy Warhol the Founder and a Major Figure Essay Warhol was obsessed by ambition to become famous and wealthy, and he knew the only was to achieve this was faith hard work. In the asses, he moved to a place on East 75th Street, his mother moved with him. Warhol had successful career as a commercial artist, he won several commendations from the Art Directors Club and the American Institute of Graphic Arts. In 1952, the artist had his first individual show at the Hugo Gallery, exhibiting Fifteen Drawings based on the Writing of Truman Capote. His work was exhibited in several Other venues during the asses, including his first group how at The Museum of Modern Art in 1956. Soon He had all of New York copying his work The asses was when Warhol began to make his first prints. They started off mostly based on comic strips like, Dick Tracy, Superman, and Popeye. In 1962 Warhol made prints of dollar bills and Campbell soup cans. He also did many prints on famous people, including Marilyn Monroe, John Wayne and Nanny Oakley, He was well known for making prints with slight color change, Whorls favorite printmaking technique was silkscreen. In this same year, 1962, he mounded The Factory, it an art studio where he employed in a rather chaotic way art workers to mass produce mainly prints and posters, but also some other things like shoes designed by the artist. Other from art, the Factory also served as a filmmaker studio. He made a series of mom films about time, boredom and repetition which became underground classics such as the Empire, The Chelsea and Blow Job. In November of this year, Eleanor Ward showed his paintings at Stable Gallery, it became a sensation November, 1964, his first solo exhibition in the LLC. S was held at Leo Castillo Gallery. This is when he began his self Portrait Series. Summer Of 1966, six Of his self portraits was shown at Expo 67 in Montreal, Quebec, Canada. In August of this year he began to go to different colleges across the Los Angles area and give Lectures, they became so popular that some colleges hired Allen Midget to impersonate him for lectures. Warhol later moved and met Fred Hughes, Who later became president Of Enterprises and Interview Magazine. Then, on June 3rd, 1968, Valerie Solaris. Member of the entourage surrounding Warhol, and the sole member of SCUM Society for Cutting LIP Men) walked into Whorls Studio, The Factory, and shot Andy Warhol 3 times in the chest. He avgas rushed to the hospital and the doctors said he was dead, but they decided to open up his chest and massage his heart, just in case. It worked and Warhol survived the attempted murder after spending tuft months in the hospital Valerie turned herself in and was put in a Mental Insti tute and later given a 3 year prison sentence. Afterwards, Warhol dropped out Of the filmmaker business, but continued every now and then With his nutrition to art. During the sasss and Us, Warhol Status as a media icon skyrocketed. He began publishing issues for Interview Magazine. In 1971 He opened his play, Pork, at the London Roundhouse Theatre. He resumed with his paintings in 1972 The Factory was moved to Broadway. In 1976 he did he Skulls, and Hammer, and Sickle series. On February 22, 1987, a day of medical infamy, quoted by a biographer, Andy Warhol died Although the bullets didnt kill him, his own gall bladder did. He died after a routine gall bladder surgery, he was 58 years old.