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Archive for May, 2009
Be Consistent, Be Immediate, Be Successful at SEO
The online business model is changing the way we do business in the 20th century. The search engines played a big part in bringing about this change, enabling millions of users to have access to real time information on news, products, services, businesses, entertainment and people. This presented smart entrepreneurs with an opportunity to sell products and services, information and entertainment, in a way that would never have been possible with traditional business models.
SEO too has seen many changes over the decade, and much to my surprise is still veiled in secrecy and confusion as to the standards and values that are applicable for the success of your online business and brand. In my previous posts – What I have learnt about SEO so far, and Seperating SEO Myths and Reality, I had covered some very important misconceptions about SEO and Lessons learnt. It will help you get bigger picture before I delve deeper into the not-so -known "value" attributes that search engines are paying more and more attention too.
What differentiates one SEO professional from another? if both could help you achieve search rankings in the same time, at the same rate? The answer lies in the "value" that's being created for the users.
Your online business is a reflection of your values and business ethics. And in delivering consistent "value" your online business is on a path of success.
1. Be consistent in creating unique, compelling and resourceful content in the form of articles/ blog posts – 3 to 4 a WEEK.
2. Be consistent in syndication of the same to 10 – 15 relevant and popular article submissions sites a WEEK (Build Author Reputation, Traffic, Natural Links).
3. Be consistent in promotion of the same content links across 10 – 15 relevant and popular social bookmarking sites a WEEK (enhance Social Reputation, Traffic, Natural Links).
4. Be consistent in attracting 3 to 5 user thumbs up/ reviews for same content each WEEK(enhance Social Reputation, Traffic, Natural Links).
5. Be consistent in participating in 3 to 4 relevant blogs, by blog commenting and forum postings each WEEK.
6. Be consistent in ALL OF THE ABOVE each WEEK
BENEFITS: Enhance Social, Web (Page Rank) and Link (Natural and Diverse links) Reputation by participating in relevant social, user and web communities. Increase Traffic. Higher Ranking for your Keywords.
1. Be immediate in syndication of your 3 – 4 articles to the selected and relevant article submision sites.
2. Be immediate in promoting the same articles to select and relevant social bookmarking sites.
3. Be immediate in posting the link to Twitter, and Stumble Upon
BENEFITS: Faster delivery of your content/brand/message across relevant channels. There is no news lie fresh news.
Separating SEO Myths from Reality
SEO has been around for a decade, and is still somehow lost behind veils of myths and secrecy. I am here to remove the sugar coating that surrounds SEO.
The Faith Myth
If I build it (a website), they will come? The answer to that is NO. If you create unique content, actively syndicate and promote that content to selected sites, and participate in social, web and user communities – Then they will come.
Do I need a SEO guru? The answer to that is NO. Anyone who claims to be a Guru is a normal person with SEO knowledge, but he likes to flaunt it to people who don't know anything about SEO.
Do I need a Technological Wizard? The answer to that is another NO. SEO is based on online branding, marketing and selling strategies, and is not a programming code. Yes, a good website needs a tech wizard for other things, but that will not help with search rankings.
Do I need an in-house SEO expert? The answer is YES, if you have the budget to hire the "Best". But if you don't have the budget you can outsource to a SEO expert at half the cost (minus the employee benefits).
Do I need a top SEO company? Working with a company has its advantages and disadvantages. The main advance is that a team of SEO's will be working on your project. The main disadvantage is that the team of SEO's working on your project will probably have just 1 to 2 years of experience. SEO is more about creating constant value for your users, following your intuitions, and keeping a look out for opportunities. Will this company be attentive to these?
Do I need a Link Builder? The answer to that is NO. Amazed! The era of paid link building, reciprocal linking, and link building requests is OVER. Natural link building is based on the merit on your content, and syndicating and promoting your content on relevant and popular web, user and social communities.
What you need is a SEO expert who is a willing partner with your online success, can assist build a long term SEO / SEM strategy, and take responsibility for the success and failures. It's a journey to your online success, so partner with someone who is willing to go the distance.
The Rate Myth
Are all SEO services the same? NO they are not. While the foundations principles remain, each SEO expert follows their own process to higher rankings based on their own unique experiences and knowledge. It's a case of many roads all leading to one. Ask the SEO expert to explain his strategy. If it does not sound like common sense to you, it's probably nonsense.
Hiring a SEO expert is expensive? YES they are expensive, but not as much as the "Losses" you are making right now because your competitors are stealing your business.
Cheap SEO services are cheap? NO it's not necessary. It's not about the price, it's about value. A SEO expert who is constantly dedicated to creating value for the users, and actively promoting your products/ services across diverse web, user and social communities is bound to succeed.
What you need is to "outsource" to a SEO expert who can "be part" of your core online team. Get the best of both worlds. Find a SEO expert who is ready to work on a fixed monthly remuneration (plus some nice bonus), and if he/she is good, then don't let go.
The Time Myth
Is 6 months enough for SEO? The answer is NO. Do you plan to be in business for 6 months only? I though not. Then SEO and Internet Marketing needs to be a part of your core marketing activities till the time you plan to be in business.
Is 3 to 4 months enough to see results? The answer is NO. The reason is search engines are now valuing consistency and quality over a period of time. In 3 to 4 months you will become a serious contender in the search rankings but emerging a winner (convert your traffic into leads and orders) can take 6 months to a year depending on the keywords and the competition.
The faster I build links the better? Speed is not the key here, its consistency that's the new mantra. Are 500 web directory submissions in 15 days better than say 30 to 40 high quality web directory submissions every month? The answer to that is NO.
What you need is to implement a long term SEO strategy, implemented "Weekly". Create resourceful, unique and informative content EACH WEEK, syndicate to selected 10 to 15 popular article sites EACH WEEK, promote across 10 – 15 relevant social media and bookmarking sites EACH WEEK, and participate in relevant social, web and user communities EACH WEEK.
The Link Myth
I have to pay, beg or trick for links? The answer to that is NO. The days of paid links (unless they are part of a PPC or advertising campaign), reciprocal links and requesting for links are OVER. Natural link building is actively syndicating and promoting your content so that these communities that you participate in link back to your content. These links are based on merit, and are highly valued. In the near future I predict that these may the only links that matter.
Is quantity of links the King? NO, it's quality and diversity of links that's King. Quality means that credible and relevant websites are linking to your content as they see value in it for their users. Diversity means that it's better to build a healthy matrix of links from diverse websites (web directories, article submissions, social bookmarking, social media and networking etc) all pointing back to your content, than build thousands of links from say only article sites, or only web directories.
What you need is a link strategy that actively encourages the creation of unique content, and then actively promoting and syndication of that content across relevant user, web and social communities. This is a weekly exercise. Other than this create a healthy mix of links from web directories, article sites, social bookmarking sites, education (.edu, .org) sites, PR releases, relevant sites/ blogs, industry sites, blog reviews etc.
The Traffic Myth
Is Traffic = Conversions? The answer is NO. There are various ways to get targeted traffic to your website, but to convert a visitor to a customer requires innovative design, content, services, products, rates, service and business sense. Did I just forget to put in SEO in the list?
All traffic is good? The answer is NO. Surprised! To target traffic means to target a keyword. To target a keyword means "time" and "effort" to focus on targeting that keyword. If you create highly targeted keywords then you get targeted traffic. So traffic from keywords that don't synergize with your product, information or service is useless, so are keywords that don't lead to a sale.
What you need is to identify keywords that will translate into customers. Each keyword had separate competition and traffic potential, and you have to build links to each of these keyword pages. Identify keywords will lesser competition yet higher traffic potential. Start with local keywords (local traffic), then country specific keywords before you try for global keywords. As you attain success with each keyword (on page #1 of search rankings) you will create a funnel of traffic to your website.
The Ranking Myth
I want # 1 ranking for my keywords? Good for you, but it's not possible for anyone to guarantee #1 rankings unless they own the search engine. Set goals for Page #1 rankings for your keywords. It is wise to start with city centric keywords and after success, move to country specific keywords, and then capture the global keywords.
My new site will rank because I am ready to pay? The answer to this is NO. Search engines value sites that have been in business for long, and those that intend to be in business for long. A new site will take 6 months to start ranking well in search listings, but that does not mean you cannot start getting business for your new website via PPC, Adwords, and banner ads etc till then.
My SEO efforts and should translate into steady rise of my keywords in Search rankings? I agree it seems reasonable to expect that after 2 months of SEO effort you would see a steady rise in the search listings, but it does not work that way. Search engines update their listings every 2 – 3 months. What you will notice however is a quantum leap after you have been showing consistency in building user value, and building quality links.
What you need is to FOCUS on being consistent with creation of quality content, and syndication and promotion of that content, including other link building opportunities that may arise. Don't worry about rankings, if you build a strong SEO strategy that's implemented week to week, then your keywords will find way to page #1, and stay there …
How much time is SEO time?
This is one question from the clients that almost makes liars of most of us SEO experts. Why? Because we know that SEO takes time, patience and perseverance, and a client with a wallet full of Greens a business full of Dreams (pardon the poetry here) expects to see his money work for him immediately.
The pitch "In the next 6 months to a year we will build a strong foundation for your online business using on-page and natural link building strategies, create content and syndicate content that your users will love, cultivate a buzz about your brand, product and services, target keywords that will translate into conversions, and bring in new customers" is loved by most clients except the 6 months part.
The problem I feel lies in the misconception that SEO is an easy and fast, money making devise. If that were the case, all us SEO experts would be rich – now wouldn't we? SEO is not about making money online. That is just the after-effect of executing a well planned and researched SEO/SEM strategy over a period of time. Consistency it seems is soon becoming the most valuable ace card up search engines sleeves.
Many clients come to us when they fail to create a successful online business, or are starting a new website, or want to grow their online business further and don't know how to do it. SEO and SEM then becomes a beacon of hope for the future of their business. While that is good, it also becomes a cause for higher expectations from the clients in terms of time to deliver.
Here is how one conversation with an eager client went:
Client: It all sounds great, except the time you mentioned. I need results in 2 to 3 months. Can you not put in more efforts and reduce the time, or hire another 2 people to help you. I could even pay you more.
SEO expert: I understand your need for speed. But a successful SEO strategy shows results only after a few months of consistent effort, creating value for your users, and participation in relevant web, user and social communities. It's the search engines way to deter websites that feel that they can walk right in, and become top dogs by using some secret SEO techniques, or spending a whole lot of money.
Client: I see what you are saying, but still let's get the time down to 4 months. Six months is too long a time, and who has seen what happens in six months. I could be out of business by then
SEO expert: That's the same reason why search engines are valuing consistent effort, quality content, and websites that are going to be around for a long time. We need to build your online reputation, link reputation and social reputation, and not just speed through to the higher rankings bit.
Client: Ok, I get it. You tell me what all is possible in 4 months, and after that we can evaluate and take things further. I am sure there will some results to show for in 4 months.
SEO expert: Definitely there will be many measurable results. Let do it for 4 months, and then we can plan ahead…
Incidentally, this client is still one of my best customers over the years.
So did I lie about the 6 months in the first place, or did I just give-in to the clients demands for doing it in lesser time? It was neither.
What I did was start a relationship with the client, teach him about SEO along the way, assist him in creating value for his potential customers, and helped him build a successful ongoing weekly SEO strategy that constantly adds value for his users, increases brand awareness and recall, promotes his products and services, drives in new customers every day, and increases his business profits every quarter.
What I have learnt about SEO so far!
Hi friends, I run a successful SEO/SEM consultancy with clients across the globe, mentor and share my experiences with Internet marketing strategies in my Zen of SEO Blog, and assist individuals and companies run successful online businesses.
I have highlighted my rankings below, not as an example of what a top notch cool SEO guy I am, but rather, as a benchmark of a journey that took a year to accomplish, and the core lessons I learnt.
My website (www.seo-optimization-experts.com) ranks in Google:
# 1 for the keyword seo expert mumbai (No #1 spot for past 6 months)
#4 for the keyword seo experts in india (4 lac competing links)
# 7 for the keyword seo expert india (4.5 lac competing links from SEO's and SEO companies in India)
My Blog (www.seo-optimization-experts.com/seoblog.html) ranks in Google:
# 2 for the keyword seo expert mumbai
It's been an exciting journey since I started my SEO Expert Consultancy Company about a year ago. There were many lessons learnt and strategies that worked that I have been sharing with all my readers in my blog posts over the past year, and I thought I would compile all my posts into one not-too-long neat post which shares – What I have Learnt about SEO So Far.
Naturally I can't cover everything in one blog post, but I have covered the most important aspects of my understanding of SEO.
Naming your business
Its best to include your primary keyword in your domain name, but if you have a built brand, or a well known business, you should use the domain for your brand or company.
Don't have too many hyphens in your domain (it's a mistake I had made by keeping a long domain www.seo-optimization-experts.com, and I guess I will have to live with it), it's better to keep www.seooptimizationexperts.com, in case a smaller domain name was unavailable.
Keep away from using underscore ( _ ) in your domain name or page namesEg. www.xyz.com/seo_services_company.html
If you can't have your keywords in your domain name, another technique is to include your keyword by creating sub domains. Eg. mumbai.seo-optimization-experts.com to target by location, or ppc.seo-optimization-experts.com to target a new pay-per-click service. Use sub domains for 3 – 4 important keywords you want to target, and don't overdo it by creating sub domains for every keyword in your list.
In the beginning there was a word – it was called a Keyword.
Keywords are the foundation of your online business. It all begins with selecting the right keywords for your business. The on-page optimization, the content creation and all future link building campaigns will stem from the keywords you select.
There are various statistical and analytic tools available on the net for keyword suggestions, and many of them are free, so use them. Keywords discovery is based on hard facts, trends, and history of performance of the keyword; it's not an estimated guess!
Don't underestimate the competition. Analyzing your competition for keywords they use or don't use is a step you don't want to miss. If your competition is on page # 1, they must be doing something right.
Don't fight the big boys. No matter how hard you are willing to work, or pay a SEO expert to do that work for you, it will take time, patience and money to go after the big keywords. Set optimistic goals and start with keywords that have lesser competition, and yet good traffic potential. These types of keywords can be researched into, also called long tail keywords; they can be identified once you understand how your potential customers search for information on a product or service like yours. Eg. Create keyword centric topics – articles, blog posts, how-to guides, FAQ's etc.
Start with city centric keywords. It makes sense to start with keyword combinations that include your city of business Eg. Seo expert mumbai. Once your keywords are ranking well in your city, it's time to expand your business with country specific keywords Eg. seo expert india. And finally you can go after the BIG global keywords!
Start with keywords that are local. General keywords (eg. seo expert) get a lot of traffic, but they are difficult to rank for, so start with your city (eg. seo expert mumbai), and work your way to country (eg. seo expert india). With time, consistency and patience, the bigger traffic pullers can get targeted.
Start with targeting easier keywords with good traffic potential. You will see faster results on your site and it becomes motivation to go after the more difficult keywords. Even an extra character like 'a' in your keyword will have different competition and rankings in search listings.
Test-drive your keywords. Run a PPC (Pay-Per-Click) campaign for 15 days to a month and see which keywords are being searched for, their performance history, and titles and descriptions that work with your customers. This helps identify the winning keywords you should be targeting on your website, plus getting the extra traffic and business can be quite a high.
Each keyword or keyword phrase is a traffic funnel to your website, and keywords on page # 1 of search engine results have a higher chance of getting clicked. There are always "more keywords" you can target, you have just not looked deeply enough.
Meta-Tagging. When is it enough to say enough!
No matter what one says, it's important to focus your pages i.e. page name, title, desc, other relevant Meta tags, and the body content around a specific keyword. What this means is that you create ONE PAGE of content themed AROUND one KEYWORD you want to target, and include the keyword in your page name, title, description, and other relevant Meta tags on that page.
Well that makes sense, considering that each keyword will need to be targeted separately, each keyword will have different competition, and links will have to build to target each keyword page.
In the body content of the page, write for the reader only and not for the search engines. If you are writing about a particular topic in focus, the keyword will be included naturally into your sentences in any case, if you can write well. The emphasis is on 'natural' writing, and NOT seo writing (if such a word exists). Don't stuff your keyword in Meta tags and body content. It should all make sense to your potential customer when reading your title, description and body content.
Other than title, description, keyword, headings (hi, h2, h3) and link text, there are NO other Meta tags of relevance. Remove all irrelevant Meta tags. Keep title tag around 60 characters, and the description tag around 100 characters. Short and simple copy works best.
Creating Content that Attracts
There is content that's created for your website – listing your services, products, infrastructure, contact details, post jobs etc. This is important to brand your company, sell your services/products, introduce the team, and give information to potential clients on how to get in touch with your company.
And then there is content for the purposes of educating and informing your users about developments in the industry/business you operate in, product tips, FAQ's, How To guides etc . You can post the content in the form of articles, or blog posts, or new content pages on your site. This kind of content is informative, useful and is liked by users and search engines alike.
The content created should be focused around keyword phrases you want to target. Eg. How to hire a seo expert.
Use content for creating internal links and external links. Internal links should be used from within the content to point to (anchor text) another page of related information, and external links point out of your domain to other useful sites and resources. Internal linking also works well when you link from pages with good page rank to pages that don't have page rank.
On average create 3 – 4 articles, or blog posts a week. This content should then be syndicated to selected article submission sites, and promoted across selected social bookmarking and networking sites to build quality natural links.
If you can create innovative and useful Video content and submit to sites like YouTube, you will have an edge over your competitors. Don't make dull, poor quality, badly edited or lengthy videos! If your videos are not generating traffic, then rethink your content and presentation. Try one video at a time and learn from your mistakes.
The Link Building Matrix (Reloaded)
The search engines are becoming smarter by the hour. Link building was always an important parameter for search engines to understand the value of your content, and will always be. But, due to good reasons, search engines now give more value to those links that come from relevant, credible and popular sites, and links that are gained on the merit of your content.
No link exchanges, no reciprocal links (unless it's between two mature and relevant sites), no paid links (unless they are part of pay-per-click campaign, or part of your advertising on other sites).
Get links from diverse and relevant web, user and social communities that you are participating actively in. A healthy matrix of quality and diverse links includes web directory submissions, article submissions, social bookmarking and networking, video submissions, PR submissions, blogs reviews and commenting, participating in forums, Yahoo answers, submitting how to guides etc.
Directory Submissions – To Pay or Not to Pay
When I first start link building for a new client, I always start with getting a few good quality links from selected web directories with high page rank (PR 3 above).
With many free high page rank directories on the web, you can create your business listing and submit to these directories for no cost. Expect little or no traffic from these sites, but the links they give you back are good for your rankings.
There are few good paid directories. If you have a budget of 400 $ (Yahoo directory included), then go for paid directories, otherwise focus on other link building techniques. You may get some traffic from paid directory sites especially Yahoo, but the link back is permanent.
Post to around 100 good web directories every two months. Build a portfolio of good quality web directory links over time. All submissions are to be made manually to web directories managed by human editors. A good web directory takes 10 to 15 days to verify a submission, though its not the only factor to concider.
Don't try and complete your directory submissions quota in one sitting (i.e. 600 directories at one time). It's not about reaching a number or completing a target, but building quality links consistently over time.
Article Submissions – The power of Syndication
Articles submission sites are my favorite for increased traffic, reputation and for building quality links to a website I am working on. Generally once you write content for the web, you cannot use that content any place else on the web, else it will be caught by the duplicate content filter of search engines. But submitting your content to article sites is not treated as duplicate content.
Write once and syndicate to 10 to 15 popular and relevant article sites with high page rank. This number works best as you can build your personal reputation as an expert author, increase traffic to your website (I get good traffic and referrals from Ezines), and build links from these sites.
First submit the article (3 – 4 a week works best) or blog post to your own website. Then consistently submit your articles to top and relevant article submission sites over a period of time, and building your credibility as an author on the topics or industry you are writing about.
Blogging – Start Talking
If you can't write, don't have anything interesting and unique to talk about, and don't want to learn what your readers like, then hire someone who can!
Start a blog only if you plan to continue writing and building content. Working hard to write great content and promoting your blog is going to be hard work. If you plan to stop creating informative, unique and entertaining content after 6 months, don't bother starting (especially with SEO in mind).
Blogs and blog posts (your content) get ranked much faster by search engines. It's a proven fact. But unless your content is good enough to excite webmasters (who actively search blogs, RSS feeds, article sites and social sites for the latest buzz) to link back to your content, the ranking won't be maintained.
Make each blog post count. Once you post on your blog, syndicate that content to article sites and promote across social bookmarking and networking sites for maximum leverage of your content.
Innovative corporate blogs are doing better at generating traffic than their websites. But don't expect your blog to generate business for you in the short term. It takes time and patience to develop a voice that can sell your ideas to your readers.
Social Media – Start Listening & Bookmarking
People are talking right now about your brand, your services and your products online, whether you are listening or not does not matter. Either you can participate in this conversation, or hope that ignorance is really bliss.
"I need information now" is the new mantra of people, and the popularity of sites like Twitter, Yahoo Answers, Facebook is backed by the fact that these social platforms allow users to communicate, share and receive information faster.
You create content (articles or blog posts) and post it on your website. Then you syndicate that content to selected article sites. The next step is to promote your content across social bookmarking and networking sites.
Select 10 – 15 social bookmarking sites and consistently submit your content each week to these selected sites. Participation is the key here. It's not good enough to post your content or link and hope for the best, you have get reviews or "thumbs up" for your content. Get atleast 3 – 4 thumbs up or reviews for all your postings for maximum leverage.
If you feel I have missed out on anything important then do send in your comments.
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Al Satwa is a Locality in Dubai, United Arab Emirates. It is located southwest of Bur Dubai and nearby on Sheikh Zayed Road. Al Satwa is known for its big South Asian community. (Sheikh Zayed Road forms the southern boundary of Al Satwa. Al Satwa is the total area of 2 km2 (0.8 sq mi). Al Satwa is the residential community and Notable features include the Iranian Hospital and the Al Satwa bus terminal. It's a favorite within the south Asian community of workers.
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"I am 6.1 weeks pregnant last monday at 4 am i whent to the restroom and when i wiped my self thers was blood on the tissue i went to the hosp. And they sent me back home i have been spotting brownish for 5 days my ob doctor checked me o..."
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In this month's edition of What's New, we highlight the newest features and enhancements to the Lead Commerce order management platform.
FLEX Order Notification (FN)
The FLEX Notification or FN feature allows users of Lead Commerce to post order, product and customer information to any 3rd party URL for any integration needs. Examples of how the FN can be used would be Google Ecommerce Analytics, any sort of dashboarding or reporting software, 3rd party financial systems and more. Using the Order Confirmation Output Tags, data such as order number, customer name, business, line items, order total, shipping information and more can be passed to any application using the FN. For more information on the FLEX Notification (FN) feature of Lead Commerce, please see our online documentation.
Package Weight and Packing Material Weight Settings
Lead Commerce now allows you to set default package weight and packing material weights to your Packages that you have defined in Lead Commerce. These default values then get applied when you use the Pack and Ship option on any active Fulfillment. These weights allow you to calculate the incidental weights that make up the entire shipping weight for a particular Fulfillment (i.e. Shipment). For more information on Package Base Weight and Packaging Materials Weight, please see our online documentation.
Override Shipping Weight
This feature has been highly requested for some time. On the individual Fulfillment, you can now specify an Override Weight for the entire shipment. This value can be entered as whole pounds as well as fractional pound values. This field is located on the Fulfillment record by clicking on the individual Fulfillment and opening the Edit window.
Lot Value
Some of our customers have a need to tie certain Lot Values to the Batch level of our inventory feature. This new option allows you to pass in a Lot Value when receiving on a Purchase Order OR when editing the Batch record in the SKU drill down area. These values can then be reported on as well as viewed on the Order drill down within the Fulfillment records.
Attribute Ordering
This release marks the ability to order your Custom Attributes from left to right on the drill down details of each subcomponent. Users can now specify which Custom Attributes show up from top to bottom by entering in a sequential value like 1, 2, 3, etc. This allows for complete control of the interface and also makes it easier and quicker to find the field when drilling down into a specific record.
ALT Order ID
The Alternative Order ID is now available within the Column Sorter of the Orders Table More menu. This allows you to see the Order ID from other 3rd party systems that are mapped to the unique Lead Commerce Order ID. This value is also searchable, so you can search for an order by either the Lead Commerce ID or the 3rd party systems ID number. This can also be arranged in any order from left to right using the drag and drop functionality of the Column Sorter located in the More Menu (blue button) on the Orders table.
Content Delivery Network (CDN) via Fastly
Lead Commerce now provides all users with a CDN to handle high traffic loads as well as sporadic traffic increases to the storefront. Users using the B2C/B2B Ecommerce option of Lead Commerce now gain from this powerful CDN delivered by Fastly. The Fastly CDN is also providing faster load times for the Back Office area of Lead Commerce as well. This service is provided as part of your monthly subscription of Lead Commerce and there is nothing to configure. For more information on the CDN of Lead Commerce and a technical breakdown, please see our online documentation.


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The idea of having a tattoo can be exciting and an opportunity to express a part of your personality through body art. Those people who have chosen to have a tattoo without visualising what it will look like when it is in place on the body have often lived to regret either the choice of design or the placement. As you would want your tattoo to be a friend for life and not a permanent reminder of a mistake, it helps to plan in advance and be sure you are prepared for the final plunge.
The design of your tattoo is one of the most important decisions you will make. Ideally it should be something that is relevant to you now and that will have longevity. The idea of having "I love Dave" tattooed across your forearm might seem a good idea now, but what about when you have an important interview, or on the day you marry someone not called Dave? It is advisable to spend some time considering an appropriate design that you will be proud of your whole life. After all, a tattoo is a lifelong commitment.
Many people visit their tattooist with only the vaguest idea of what they would like and where they would like it to be placed. Placement is particularly important if you think that there might be days when you don't want your tattoo to be visible. With that in mind, it is wise to try on different types of clothes and imagine neck lines and sleeve lengths, for example. Be sure about where you want your tattoo placed and give your tattooist precise instructions.
Visualise at home
You can give yourself an idea of how your tattoo will look with only a small amount of effort and equipment at home, and you don't have to be a great artist to do it. Get some tracing paper, your tattoo design and a soft pencil. Trace the outline and some of the detail of the tattoo onto the tracing paper and be sure to go over it several times, so that the pencil lines are thick. Now, place the tracing paper tattoo onto the part of the body you intend to have the tattoo and press down firmly and consistently to avoid smudging. Depending upon where you want the tattoo to be placed on the body, you might need the help of another person. You should have a basic pencil line tattoo outline on the body part where you wish to have it and can actually see how it will look with clothes, or without!
Professional visualisation
Various online companies are now offering a service where you can send them a photograph of yourself and an image of the tattoo design and they will combine the two. This makes the resulting photograph appear as if you already had the tattoo and you can use this image to consider your options and ask the opinions of friends and family.
Most recent
- Stockbyte/Stockbyte/Getty Images


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Crosscreek partners for ministry with other Baptists and Christians in our community, our state, and the world. Through the following partnerships, Crosscreek helps express the love of God:
Crosscreek Family Services — a center for pastoral counseling housed at Crosscreek;
Alabama Cooperative Baptist Fellowship — a statewide fellowship of Baptist churches;
Cooperative Baptist Fellowship — a global fellowship of Baptist churches and missionaries;
Shelby Baptist Association — a local sharing of ministry among Baptists;
Together for Hope, Arkansas – a ministry of the Cooperative Baptist Fellowship's rural poverty initiative that seeks, through Christian ministry and community development, to encourage and empower the people of Helena, Arkansas.
Global Women— an ecumenical ministry that seeks a world where every woman is empowered by the love of God, valued by her community, and equipped to fulfill her unique purpose. The ministry of Global Women (GW) is conducted worldwide in partnership with indigenous Christian women leaders and women called to serve outside their native country.
AA — six recovery groups meet throughout the week at Crosscreek.


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Is there such a thing as asking for it?
In every situation that involves a wrong being committed, there are at least two elements. There is the individual who commits the crime, and there is the situation leading to the committal. It's tempting to shoulder the full yoke of responsibility on the criminal. Some might brand it victim-blaming and go crazy over the assertion that the victim of a wrong might in some way be culpable.
I speak in general terms, and I do believe that in every situation, it's important to examine one's own actions as opposed to simply brushing of the assailant as the one with the problem. And while it is important to recognize that in many situations there isn't anything one could or even should do differently, this act or self-reflection is important. Not only does it help the victim of a wrong to put things into perspective, but it also teaches sensitivity. This is something Jesus understood — that it's just as wrong to induce someone to sin as it is to commit a sin.
Suppose you know someone with a drinking problem, who confided in you that he's trying to recover from alcoholism. You go out to lunch together, and perhaps you order yourself a drink. On the one hand, you're not the one with a drinking problem and so you shouldn't have to restrict yourself because of someone else's problem. On the other hand, you know this person is only beginning to recover, and so the slightest temptation might push them over. To restrain one's personal desires is an act of love, here. You don't want this person to be tempted by watching you drink, so you make this sacrifice for them.
Where does the balance lie? And how much of your own personal comfort should we sacrifice for the sake of others?
In the wake of the Harvey Weinstein media frenzy, the conversation has once again opened up the can of worms around relations between the sexes. It needs to be said that sexual harassment is wrong. Catcalling is wrong. Belittling and objectifying someone for any reason, including your own sexual appetites is wrong. These things need to be said because they're important. But if we're honest, there are some women who welcome this kind of behavior. Here's the proof: that people like Harvey Weinstein are allowed to continue. It's not at all different from Pavlov's dogs. A man commits a certain behavior and is either positively reinforced or negatively reinforced. A man does not continue with this behavior for decades if he doesn't get some kind of reward out of it. So you hear all manner of questions about what she's wearing or how she acts and the like, and these questions get brushed off as excuses.
But I have to ask, how much of her own personal comfort should a woman be asked to sacrifice in order to not tempt those men who have this problem? On the one hand, she's not the one with the harassment problem and so she should have to restrict herself because of some random dude's problem. And let us be fair: a healthy number of men don't have this problem, but a lot of them do.
It's a disgusting balance. Do we want to go back to the old Victorian days where the woman have to dress frumpy and cover themselves from head to toe because some men can't control themselves? Or was that even effective back then? Some women dress provocatively, that's a fact. Do they deserve to be harassed by every guy they meet? Of course not. But she's going to get attention. Some guys are assholes, that's a fact. No, it's not fair to blame a woman just because some guy can't keep his mouth or hands to himself no matter what she's wearing. No, she's not 'asking for it.' No, it isn't fair. But I do have to ask myself if there's some element of "you may be weak but that's your problem, not mine" at play. And is that love? Just how much of ourselves should we sacrifice out of love for others?
I don't know, but Jesus died for us.
Michael Patrick Lewis is a teacher, and bestselling author of Edge Of God, and Preferred Rewards. You can also find him on Twitter @fakeMikeLewis.


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The Washington International Horse Show (WIHS) is pleased to welcome back the Washington Area Chevrolet Dealers (WACD) as the title sponsor of the WIHS Winner's Circle, where top awards presentations will take place during show week. WIHS, the country's leading indoor championship horse show will take place Oct. 21-26, 2014, at Verizon Center in Washington, D.C. The top horses and riders in the country and throughout the world including Olympic champions will compete during six days of exciting competition in the heart of our nation's capital.
WACD also returns for a second year as sponsor of the crowd favorite celebrity barrel racing exhibition. This year it will take place Friday evening as part of WIHS Military Night with an Army vs. Navy theme. Professional barrel racers affiliated with National Barrel Horse Association, Women's Professional Rodeo Association or American Professional Rodeo Association will team up with a celebrity rider to run the barrels.
International show jumper Aaron Vale running the barrels during Celebrity Barrel Racing sponsored by Washington Area Chevy Dealers | Shawn McMillen Photography
In addition, WACD is generously offering a limited number of free ticket vouchers to dealership visitors during the month of October. WIHS fans can pick up these general admission ticket vouchers at any local Washington Area Chevy dealership. While at the dealership, Chevy encourages fans to enjoy their complete lineup of trucks. As the 2014 North American Truck of the Year, the Silverado 1500 offers better fuel economy than the leading competitor. Heavy duty jobs deserve heavy duty strength, and the Silverado HD offers the proven power with its heavy duty engines, including the Duramax Diesel and Allison transmissions, and now the all new Chevy Colorado is here to reinvent the midsized truck.
"There's no power like horsepower! Chevrolet is proud to partner with WIHS, an event that represents the very best in equestrian competition in the heart of our city just like Chevrolet represents the highest caliber of automotive lineup in the industry and top service in the area. We are pleased to be a part of this fantastic event for the third year in a row." said Karen Radley, owner of Radley Chevrolet."We are thrilled to continue our partnership with Washington Area Chevy Dealers," said WIHS Executive Director, Bridget Love Meehan. "They offer great support to our outreach in the D.C. community and bring an important local distinction to our event."


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Greenhouse & The Roosevelt Rubicon, Redux
Linda Greenhouse has a compelling Opinionator column today at the New York Times that concludes that Chief Justice Roberts, not Justice Kennedy, may be the key vote in the individual mandate cases that will ultimately come before the Court. Thus continues the Great 2010 F1@1F-Greenhouse Mind-Meld.
Reminding readers that Roberts's mentor and predecessor, Chief Justice Rehnquist, aborted his own "federalism revolution" in 2003's Nevada Department of Human Resources v. Hibbs, Greenhouse goes on to examine Roberts's own role as the fifth vote to last year's broad, Breyer-written federalism case, United States v. Comstock. She concludes:
In his decision this week, Judge Hudson also mentioned the Comstock case, endeavoring to show why it didn't save the statute. In my view, his effort to wish the case away was unpersuasive, but my view is not the one that matters. The view that ultimately may count the most is that of Chief Justice Roberts. As everyone knows, he was once William Rehnquist's law clerk. So my question, as the health care debate continues on its path to the Supreme Court, is this: When John Roberts thinks about his former boss and mentor, which Rehnquist does he see? The one who started the federalism revolution, or the one who ended it?
Without my gunning for her attention (a/k/a "the Greenhouse Effect) and surely without her looking to F1@1F, Greenhouse and I have been on the same wavelength, absent reference to Rehnquist's ghost, for nearly a year now.
For any challenge to the health care legislation, at least one of the current Court's conservatives–my guess is Roberts himself–will recognize that the political moment, at least in terms of an individual mandate for all Americans to have health insurance, is not ripe for restoring the reign of the Constitution in Exile.
John Roberts is an acutely image-conscious chief justice, as watchful and protective of the Supreme Court's image as he is of his own. I find it almost impossible to believe that this careful student of history would place his court in the same position as the court that has been rewarded with history's negative judgment for thwarting the early New Deal.
F1@1F in May, post-Comstock:
Of course, Roberts may have simply agreed from the start with Breyer and the liberals. But even if such a thought was ideologically plausible prior to the announcement of Comstock, it just doesn't make strategic sense for the Chief to entrust the opinion to Breyer. However, if the Chief was in the majority and did assign the opinion to Breyer, it could have been to send a message to those hoping the Court will strike down Obamacare: abandon all hope ye who enter here, for the Roberts Court will not cross the Roosevelt Rubicon.
After Schwarzenegger v. EMA, I'm no longer as confident in Comstock as dispositive of the Chief's vote on the individual mandate. Before oral argument in EMA, no one could see any daylight between Roberts's robust First Amendment opinion for the Court in Stevens and the similar violence-as-obscenity facts in EMA, but Roberts made clear from the bench that he believed that Stevens, however sweeping in its language striking down Congress's ban on depictions of animal cruelty, did not touch the constitutionality of California's ban on the sale of violent video games to minors. Accordingly, in the health care cases, Roberts already has a blueprint in Judge Hudson's decision for distinguishing Comstock away, however apposite Comstock might seem.
Still, history and politics will be sitting like massive gorillas in the room–indeed, every room: chambers, conference, court–when this case finally reaches the Court. Not only would a decision against the mandate mark the Court's deepest incursion into pre-1937 territory since, well, 1936, but it would also come during a Presidential Election year. A conservative majority ruling against the liberal incumbent's signature first-term legislation will be an inter-branch collision not seen since, you guessed it, 1936. The decision itself will fast become campaign fodder for Obama to cast the Court as unprincipled political actors hell-bent in their conservative activism to collide with the elected branches and stand athwart the forward march of history screaming "NO!"
How unseemly it all could be.
And let's not forget that unlike Citizens United, which sat alone on last term's docket among a bunch of less-than-massive cases, the health care cases may very well reside on the same docket as the Prop 8 case, the University of Texas affirmative action case, the Arizona immigration case, and maybe a Nebraska abortion case. The Court will have to pick its hot button to push in a deeply political moment, and I can't see the Chief selecting the one that reduces to rubble a cornerstone of modern American jurisprudence.
Graham, Comstock, and the Chief Justice
F1@1F has from its inception been animated by my hypothesis that the Roberts Court's docket and decisions have been shaped the Chief Justice's sensitivity to the Court's surrounding political climate. As such, Citizens United represented less an act of war against the Democratic-controlled White House and Congress, and more a picked battle strategically placed to cause minimal institutional harm to a conservative Court with diminished political capital. Now that oral arguments are over and the politically salient cases are finally being decided, F1@1F will focus more fully on whether this term's opinions support or disprove the hypothesis.
Last week's opinions in Graham v. Florida and United States v. Comstock found Chief Justice Roberts unexpectedly siding with the Court's liberal wing on ideologically divisive questions of law and politics.
In Graham, six members of the Court voted to vacate a juvenile's sentence of life without parole for a non-homicide crime. Justice Kennedy's five-member majority opinion, joined by the Court's liberal bloc, declared that all such sentences categorically violate the Eighth Amendment.
Concurring in the judgment, Chief Justice Roberts hedged with an as-applied analysis rather than categorically endorse Kennedy's expansive Eighth Amendment jurisprudence. Yet Roberts also refused to sign onto Thomas's categorical denial of relief, despite his joining the dissent in Kennedy v. Louisiana, which outlawed the death penalty for child rape.
In a way, the Chief's vote seems to recognize the public ambivalence towards life without parole (LWOP) for juveniles convicted of non-homicide crimes. As he saw it, people are either confortable enough in theory with the laws as written that allow LWOP, but are loath in practice to trust trial judges to fairly wield such awesome power; or they are uncomfortable in theory with LWOP for juveniles, but wish the death penalty still applied when confronted with particularly heinous crimes committed by almost-adults. It was for the latter type who, like the majority, reject even the theory of LWOP for juveniles, that Roberts juxtaposed Graham, who received LWOP for armed robbery with assault or battery, with a 17-year-old who "beat and raped an 8-year-old girl before leaving her to die under 197 pounds of rock in a recycling bin in a remote landfill" and two juveniles "who together with their friends gang-raped a woman and forced her to perform oral sex on her 12-year-old son."
Judging by his Graham concurrence and his joining the Kennedy dissent, Roberts's own Eighth Amendment jurisprudence is more pragmatic and politically responsive than that of his eight colleagues. In undertaking a proportionality analysis, Roberts's views are apparently guided by the shock of the crime rather than the severity of the punishment. Particular punishments are never categorically beyond the pale; only certain crimes are.
In Comstock, Roberts joined Justice Breyer's opinion without any hedging whatsoever, thereby restoring a seemingly more expansive view of Congress's Article I power than the Rehnquist Court would have allowed, at least before Raich. He could have joined Kennedy's or Alito's narrower concurrences in the judgment and thwarted a majority. Instead, he gave a fifth vote to a mode of reasoning that may dim the hopes of those challenging the Affordable Care Act.
The Chief Justice may have felt compelled to join Breyer's opinion, which also included the rest of the liberal bloc, so to secure for the parties and future litigants a clear holding. I have difficulty believing that if the votes at conference were the same as they were at decision–7-2 to uphold as within Congress's power a federal statute allowing for the civil commitment of sex offenders after their federal prison sentences have ended–the Chief would have delegated the majority opinion to Justice Breyer. This case had serious federalism implications, after all, and Breyer's penchant for multi-factor balancing tests and general hostility to narrower readings of Congress's Article I powers promised an opinion that would not sit well with the Court's conservatives.
Two scenarios, then, come to mind. Roberts may have originally been with Thomas and Scalia in dissent, believing that Congress's legislative powers go no further than those specifically enumerated in Article I of the Constitution. Justice Stevens, as the senior justice in the majority, could have assigned the opinion to Breyer as a reward for Breyer's fever-pitch dissent in Lopez protesting the start of the Rehnquist Court's ultimately incomplete federalism revolution. When Breyer's opinion failed to attract five votes, Roberts may have switched his own, finding the opinion's mushy language eminently manipulable to more conservative results in more important future cases.
The same pattern holds for a second scenario in which Roberts, unable to countenance freed sex offenders for the sake of federalism principles, may have voted at conference with Kennedy or, more likely, Alito. If the conference counted the votes based on reasoning rather than results, then Stevens still would have been the assigning justice.
Of course, Roberts may have simply agreed from the start with Breyer and the liberals. But even if such a thought was ideologically plausible prior to the announcement of Comstock, it just doesn't make strategic sense for the Chief to entrust the opinion to Breyer. However, if the Chief was in the majority and did assign the opinion to Breyer, it could have been to send a message to those hoping the Court will strike down Obamacare: abandon all hope ye who enter here, for the Roberts Court will not cross the Roosevelt Rubicon.
Together, Graham and Comstock reveal a Chief Justice acutely aware of the country's political climate and unwilling to sacrifice the Court's institutional legitimacy for across-the-board conservative gain. There remain a handful of major cases yet to be decided, however, that could reveal a Chief Justice ready to gamble what remains of his Court's post-Citizens United political capital on a few more battles.
Regular Posting to Resume Next Week
I've just emerged from finals and am now enjoying my recovery period. I've got some thoughts on this past week's Graham and Comstock decisions, and how they relate to the Roberts Court and our political climate. Those, as well as analysis on the Court's forthcoming opinions on Monday, will be up next week.
Thank you for your patience!
Welcome Volokh Conspiracy readers! While you're here, give the below "weekend reading" a look – I know many of you will surely have strong opinions about my observations.
Thanks to Professor Randy Barnett for the VC shout. I just finished reading the first part of his book-to-be, Fundamental Rights in the Constitution and very much enjoyed his exploration of the Ninth Amendment's original public meaning.
Also, over the weekend, Professor Orin Kerr, another prominent Conspirator, suggested that I supply some information on how early one must arrive in line at the Court to get a decent chance of getting inside to hear an argument. Here are my preliminary thoughts:
- Be Before 50th: The Court reserves at least fifty seats for the general admission line.
- The "Dogs": From my experience, if you get in line between 7 and 8 for the "dogs"–the technical cases without any newspaper coverage–you'll get in. By "experience," I mean the first oral argument I ever attended, Danforth v. Minnnesota, for which my father and I got in line around 8am, received numbers around 50, and were among the final ones seated inside the Court. Of course, despite no major awareness of Danforth in the news or general public, the case, like all SCOTUS cases, was still massively important for its area of law. Indeed, Prof. Kerr noted Danforth's major legal importance for criminal law and procedure over at VC in November 2007. This week's cases, as far as I can tell, haven't touched any public nerve, so I am taking this week off from the line. I leave it up to the Klingensmiths to tell me otherwise. Still, keep your eyes trained on F1@1F at the 10am hour should Wednesday see the release of Citizens United.
- The "Mid-Majors": Get in line by 6am. Last week's cases exemplify the "mid-major" cases: issues that attract the public's attention without creating a frenzy. Briscoe mattered not as much for its subject matter, but rather for Sotomayor's centrality in the fate of a year-old precedent. Comstock dealt with sex offenders (and, of course, the scope of the Necessary & Proper Clause of the Constitution), who are always interesting subject matter. American Needle fought against the NFL, which sounds cool regardless of the more mind-numbing aspects of antitrust law that really animated the case.
- The "Blockbusters": Get in line before 4am…and that probably won't be good enough. I got in line for the rehearing of Citizens United, also Justice Sotomayor's first oral argument, at 11pm, thinking that there would already be a line at least a dozen people long. There wasn't. I was first. The next batch of people didn't show up until 3:45am. That said, for the super-blockbusters, prepare to eat your previous night's dinner on the First Street sidewalk: friends of mine got in line at 4:30pm on Heller's Eve…they were around 40th. This term's blockbusters–McDonald, Kiyemba, Christian Legal Society, Doe v. Reed—will likely draw its earliest linegoers at varying hours of which I am not yet qualified to predict.
Once again, thank you for coming by F1@1F. Although I will not be reporting from line this week, I will endeavor to keep the content flowing!
Vox Populi – 1/12/10
"I think it says something positive about American democracy that people are out here to see the Court and how it works," said Ryan Lirette. Mr. Lirette is a recent graduate of Boston University School of Law. He is taking his law firm's deferral year to work as a research associate at the American Enterprise Institute here in DC. Sixth in line, Lirette arrived before 6am to see Comstock.
Last week Mr. Lirette wrote an op/ed, crossposted at the National Review Online's "Bench Memos" blog and AEI's own blog, urging the Court to strike down the federal statute authorizing indefinite civil commitment of convicted sex offenders after their prison sentences have run. "The Court", he wrote, "should take this opportunity to rebuke Congress's gluttony by preventing it from meddling in areas that lawfully belong to the states." Yet when I asked Mr. Lirette for his thoughts this morning, he left his partisan bona fides on the web in favor of a civic pride that all of us standing in the dark could agree upon.
Brandon Bartels, a political science professor at George Washington University, has made his career out of studying how the Court works. A judicial politics scholar, Professor Bartels just moved to DC in June and this was his "maiden voyage" to a Supreme Court oral argument. He came out for Comstock primarily because he wanted to "see a case where the United States was a party," and believed that the Court would uphold the civil commitment law, in contrast to Mr. Lirette's argument to the contrary.
Although Prof. Bartels, a young political scientist, calls the Court a "political institution," he does not mean it in the rawest, most cynical sense promoted by other scholars of judicial politics. Instead, he frames the Court as an institution, rather than nine policy-driven judges, that is "forced to make decisions on political issues" by virtue of the political nature of some legal controversies. For example, "when a court strikes down a law as unconstitutional, [the decision] has clear policy implications," whether or not judges sought to implement their own policy preferences.
Still, he maintained that on the day-to-day basis, the Court simply doesn't "give a crap" about politics–at least since Justice O'Connor retired. For Prof. Bartels, this distance preserves the Court's independence and grants it the institutional legitimacy to be the "final arbiter of what the law means," even as the Court does follow "long waves," or general trends, in public opinion over time.
Further down the line stood four forensic psychologists who belong to the American Psychology-Law Society. As opposed to Mr. Lirette and Prof. Bartels, who had more academic and theoretical interests in Comstock, these women came up from Richmond because the outcome of the case would impact their field. Civil commitments, they said, have become "huge" in their area and Comstock's "trickle-down effects," however the case will be decided, will "make a difference" in their work.
Blair and Erin Miles, two years married and soon to move to Southern California, stood in front of the forensic psychologists. The Miles's have assembled a DC "bucket list" before they abandon their winter parkas for summer sandals out West. Mr. Miles had been "DC born and raised," but had "never been to a case" despite having lived in DC his whole life. Ms. Miles, who met her husband while they were in law school at University of the District of Columbia, had "tried once before [to get into an oral argument], but didn't make it in." This time, however, they arrived early enough to catch one more bitterly cold morning and their first oral argument. To make matters sweeter, Ms. Miles works at the National Center for Missing and Exploited Children, where she "does a lot of work with the Adam Walsh Act," which contains the civil commitment law at issue in Comstock.
Of course, no morning line would be complete without the law students. Several, including Timothy Ziese, a Georgetown 2L who arrived with his out-of-town twin brother Jonathan to claim the third and fourth spots in line, had a zeal for constitutional law in general. Others, such as Allison Segal of Widener Law School in Delaware, came to see the oral argument after spending months on a law review article that contributed to her near-expert understanding of the issues at play in Comstock. Indeed, Ms. Segal went so far as to lay out her justice-by-justice predictions to conclude that Chief Justice Roberts would be the swing vote to affirm the 4th Circuit's ruling the civil commitment statute unconstitutional.
In Comstock, a Congressional statute lay at the mercy of the Court. But those of us who witnessed night turn to day on First Street this morning saw the same sun rise over the Court and the Capitol. And so did it rise over us, whether right or wrong in our predictions, or right or left in our politics, as we stood united, waiting to watch American democracy in action.
Conservative principles of law-and-order and limited government clashed this morning in United States v. Comstock. At issue was the constitutionality of 18 U.S.C. § 4248, which provides for the federal government's civil commitment of sex offenders after they have served out their full sentences in federal prisons.
On the one hand, section 4248 keeps off the streets convicted sex offenders deemed by federal authorities to be a continuing threat when they otherwise would be released back into the state where they committed their offense. This much seems wise: if a state is unwilling to exercise its police and public welfare powers by rehabilitating its violent sexual offenders upon their release from federal prisons, the federal government surely shouldn't just let those deemed a continuing danger to society roam free among, well, society. This is the United States' position in Comstock.
On the other hand, section 4248 relies on provisions of the constitution that may not authorize such federal action, however wise or well-intentioned. Specifically, Comstock argues that the Commerce Clause and the Necessary and Proper Clause of Article I, both relied upon by Congress in creating section 4248, do not cover civil commitment of criminals when the federal government's power, through the prison sentence has been exhausted.
Solicitor General Elena Kagan rested her argument for the United States largely on the Necessary and Proper Clause, with barely a nod to the Commerce Clause. That much in itself was a victory for the late Chief Justice Rehnquist's "federalism revolution," which, to varying degrees of success, sought to limit the expansive reach of the Commerce Clause to issues more closely connected to interstate commerce than the permissive post-1937 Courts often allowed.
But only Justice Scalia truly seemed to believe that 4248 also strained the bounds of the Necessary and Proper Clause to maintain law and order. Justice Scalia looked to the text of the Necessary and Proper Clause, finding nowhere that it authorizes the federal government to act according to what is "necessary and proper for the good of society." Rather, he maintained that the clause enabled the federal government's actions that were necessary and proper to execute another power given to the federal government by the constitution itself. As such, he agreed with what would be the defendant's argument that the states and states alone are responsible federal prisoners whose sentences have run.
Kagan countered that indefinite civil commitment of sexual offenders under 4248 was necessary and proper to the "responsible exercise of operating the criminal justice system." On this point–that the federal government needed its own civil commitment regime as a "backstop" for when the state governments refused responsibility for released federal prisoners–Justices Alito and Breyer seemed sympathetic. They peppered G. Alan DuBois, a veteran federal public defender and counsel for Comstock, with hypotheticals about the constitutionality of the federal government's ability to deal with prisoners who grows more violent while in prison or, in the opposite instance, is injured in jail in an attack by another prisoner as his sentence ends. Per these and several other hypotheticals, Alito and Breyer both seemed to believe that the federal government does have the power to retain custody over prisoners that it deems dangerous to public health and safety, or to themselves, upon their scheduled release from federal custody.
As Justice Breyer persisted in exploring the federal government's power to set up, for example, national mental hospitals, Justice Scalia clutched his head in frustration: "No, No, No! The Issue is not setting up hospitals, it's detaining and committing people!" Scalia simply could not believe that any governor or state attorney general, upon receiving a note or a call from the federal government, would deny his or her obligation to civilly commit a sexual offender and rather face the electoral consequences of letting such a criminal roam the state without rehabilitation. Justice Stevens then took the opportunity to look at the statute from the opposite end of Scalia's looking glass, suggesting that the Court look to the wisdom of the statute and "assume there are cases out there that there is no solution" like Scalia's belief that all states would naturally accept responsibility for rehabilitating federal prisoners released within their borders.
But DuBois stood firm against Stevens', as well as Justice Ginsburg's, apparent approval of the federal "backstop" when states refuse to cooperate. Chief Justice Roberts tested DuBois's position, asking that "if a state says no" to receiving a released, but still dangerous, federal prisoner, "then the federal government says, 'you have to'?" DuBois dug in: "Yes, the Constitution requires it."
Scalia remained astonished that the other justices even entertained the federal government's claims of responsibility. Noting that states have involuntary commitment procedures, he wondered why the federal government could not simply fund an office that brings state proceedings for involuntary commitment. "They should do that!" Dubois actually shouted in reply. When Stevens tried to get the Court back to assessing whether 4248 itself was constitutional, Scalia shot back that the statute "isn't even necessary!"
Towards the end of the argument, Justice Sotomayor interjected with a compromise, asking DuBois if it would be constitutional for a judge to mandate civil commitment for a sexual offender during his trial's sentencing phase. If such a mandate contained protections to avoid turning indefinite commitment into interminable detention, then it would be constitutional, replied DuBois.
Sotomayor's trial-judge pragmatism may persuade all but Scalia (and possibly the ever-silent Justice Thomas) to side with public safety over rock-ribbed federalism and uphold 4248 as constitutional. If this happens, then Scalia, confronted with Sotomayor's aggressive questioning this term and her possible coup over his Melendez-Diaz decision in yesterday's Briscoe v. Virginia, may finally be meeting his match.
UPDATE: Read the official transcript here and use the comments section to call me out on my own transcription errors.
Back home now to defrost my toes and shed my hobo skin. A few thoughts before heading back to One First:
The quality of interviews from line this morning more than made up for my missing out at first in line by a single swipe at my snooze bar.
The line started building up around 5:30am. Economists, actors, political science professors, forensic psychologists, out-of-town tourists, and yes, more law students.
United States v. Comstock, which will be heard at 10am, was the biggest draw, although my usurper–one Shannon Salembier from Vermont Law School–snagged the official F1@1F title in order to see 11am's Abbott v. Abbott. In contrast to yesterday, however, far fewer people in line today came "just because." For details, come back tonight for my Vox Populi report.
Time to suit up. Rock!


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As a business owner, how you are perceived by your customers, prospective customers, business contacts and colleagues can be important to your success. But let's face it; it's not easy to understand how other people perceive us or indeed simple to change the minds of people who have already effectively judged us.
Sometimes we may be completely unaware of the attributes, qualities and behaviours traits that we are projecting. For example, I am known for not suffering fools gladly, but does this come across as the strength I see it as or are people potentially thinking that I am intolerant? Continue reading


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Mustelid Control
Ferret, Stoat and Weasel control is arguably the most difficult task trappers undertake in NZ. During the last fifteen years I have played an active role in developing National Best Practice and have used these methods for species protection at dozens of sites throughout NZ. By engaging CPS to undertake your mustelid control you are guaranteed that the most proven methods available will be used.
CPS Mustelid Control Services:
• Mustelid Monitoring programmes to the National DOC Standard
• Design and implementation of annual control programmes
• Live trapping for research
• Kill trapping
• Supply of quality Mustelid baits and Lures


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Tiny hand necklace - silver£64.00 £80.00
A miniature silver hand hanging on a dainty chain. It's sort of protective, making a comforting little gesture. Gentle and delicate.
The hand is approximately half an inch long, and cast in sterling silver. Chain is slightly blackened sterling silver and is 18 inches long in total.
Cast from my original hand carved wax, this piece will be produced to order and finished by hand in my studio. Currently items ship within 2 to 3 weeks, though often much sooner. Please read our policies for shipping info.


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We very rarely put up posts about Puppy sales,but from time to time we get these very interesting situations and we are obliged to publish so as to better the Dog World in Nigeria.
As a breed,Doberman Pinschers in Nigeria are very poorly represented.So many that we see lack the Physical traits of top Doberman breeds.
A Prime male Doberman is about 27-28 inches at the withers,taller than any Alsatian,yet wiry though lean,strong,same weight as an Alsatian but sharp,speedy,agile.Great for vast Estates,Great guard dogs.Unique breeds indeed.
To get Prime,quality specimens a tough order.For this reason and because owner of the Sire,Dam and puppies is a very esteemed and trusted gentleman,not a breeder but more a fancier who will not compromise standards for costs,we decided to put up this post.
For pictures of puppies and every other detail readers should please call : Nigeria, 08064473279
As is our practice,we advise that would be buyers get to see physically Sire and Dam to appreciate what they are buying and to guard against any doubts as to quality of what they are getting.
In the picture above,the Sire is the impressive specimen in the middle of the picture,while the Dam is towards the gate.The smaller Doberman juveniles are from the first litter,about 5 Months old in this picture.
Those currently up for sale are a second set of puppies currently 8 weeks old.


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Watching tape of Seattle Seahawks' quarterback Russell Wilson in preparation for the Super Bowl, New England Patriots' head coach Bill Belichick was reminded of Dallas Cowboys legend Roger Staubach--particularly in the way he is able to scramble out of trouble.
Belichick remembers Staubach well from his father Steve's years as an assistant at the Naval Academy, where the man they called "Roger the Dodger" played his college ball. Staubach went on to win two Super Bowls with the Cowboys in the 1970s. Wilson will be going for his second Super Bowl Championship on February 1.
"He kind of reminds me of watching [Roger] Staubach," Belichick said Tuesday, per ESPN. "I remember a lot of Staubach's spectacular running plays where it looked like he was about to get tackled by three or four guys, and he would Houdini it out of there somehow. You see Wilson doing some of the same things."
Stay on top of the latest Dallas Cowboys news with NBCDFW.com. Follow NBC DFW on Facebook or have breaking Cowboys news sent directly to your phone with Blue Star SMS alerts. Text "bluestar" to 622339 (NBCDFW) to subscribe, text HELP for more info, and text STOP to end the subscription. Message and data rates may apply.Read more about it here.


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OK, I'm not going to overdo it with a flurry of Hoops & YoYo posts and I won't rave about how much I love Hoops & YoYo. But they are so FUNNY in a really annoying and mischievous kind of way. Hee. My kids always send me Hoops & YoYo e-cards (they are characters invented by Hallmark), or watch the little videos when they are feeling low. Nothing like 20 minutes of belly-laughing to cheer a person up!
Here's one of their best. It's All About Manners. Gather the kids 'round and set them in front of this! LOL! Click on the links on the page to learn a new lesson. 😀
My personal favorite? Asking to go out and play. I need more practice!


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Save big with Yamibuy deals and coupon codes, Shop online and get wide range of discounts & offers available for Yamibuy - one of the popular online website that offers variety of consumer goods.
How to use coupons for Yamibuy?
We update deals and coupons on daily basis to our wide listing so that we can offer you the best & latest discounts for Yamibuy. With DealsPricer, it is very easy to share Yamibuycoupons and deals with your friends and family anywhere on social platforms just by clicking the share button
We take care of your shopping experience for which you can vote and comment in the coupon section. We love to hear from our customers and your feedback is always welcome in our feedback section.
Our endeavor at DealsPricer is to list down the Latest Yamibuy Coupons , Deals and offers.Check out all the latest Yamibuy deals, discounts ,coupons and offers at DealsPricer.com and start saving big on online shopping for Yamibuy.
You can reach this page by searching Yamibuy Deals, Yamibuy discounts , Yamibuy Promo Code, Yamibuy coupons and Yamibuy Offers.
The official site of Yamibuy is http://www.yamibuy.com/en/.


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MathDali Song
Views 473 157
Knowledge Channel
MATHDALI Every Saturday, 8:00 AM on ABS CBN and Everyday every 10:20 AM, 3:00 PM and 5:00 PM on Knowledge Channel
Knowledge Channel developed a new series that focuses on overcoming this fear of the subject to pave the way for better Math learning: MathDali. The foundation's latest contribution to K to 12's aim of providing mastery of concepts and skills in Mathematics.
This episode of MathDali teaches how to round-off numbers to the nearest thousands and ten thousands.
Subscribe to Knowledge Channel YOUTUBE Channel
For Donors:
For Teachers and Learners:
Knowledge Channel Foundation Inc.
5th Floor Benpres Bldg. Exchange Road corner Meralco Ave. Ortigas Center, Pasig City Philippines 1600 +632 910.3181 • +632 910.3183 to 84
Email: [email protected]


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Technical support is one of key elements of IT administrators' daily routine. Because of that, an increasing number of companies and institutions decide to invest into software designed to provide a remote support.
IT administrators are responsible for a variety of tasks – apart from hardware issues, they are also obliged to install software necessary for other workers, protect from viruses and DdoS attacks as well as implementing new programs.
Many companies nowadays also have their structures distributed – so, their localizations usually possess own networks which are controlled by one or two workers. While taking into consideration daily worktime standard and rising demands of supervisors, it is necessary to solve problems in almost real time – and this is why remote support is not a luxury anymore. It is a key tool for every IT administrator to perform their tasks coherently.
Integration with helpdesk
Your remote support system should be integrated with IT resource management system – and especially with the helpdesk. This kind of solution both serves as a way to help the end-user instantly and creates a database about IT incidents. With such a solution, you can analyze every problem basing on the history of issues.
We will analyze remote computer access basing on an example of statlook system. It possesses our in-house developed solution – Direct PC. It is an integral part of statlook system and Helpdesk suite.
Remote connection to a user
If an IT incident appears, the user can report it through the application installed on his computer or any other device. The report is instantly aggregated as a ticket within a system. The administrator may describe the status of the issue and the level of priority, and later on assign it to a person who will resolve the problem. Next, if such a need appears, he can connect remotely to the computer via one of three ways – by sending a permission to connect, informing about the time of creating a connection or connecting to the computer in silent mode (without the knowledge of end-user)
After maintaining a connection, the administrator might manage both register and processes from remote, as well as operate on files and catalogues. While doing it, the incident can be analyzed and solved directly through remote desktop. Direct PC enables you to connect with a user both with the authorization of a user of the administrator's one.
It is especially important because the end-users often find it difficult to describe the moment of the problem appearance or which sequence causes the issue. With this solution, it is easy to recreate the end-user's logic during issue appearance. Direct PC also serves as a tool to monitor certain groups of computers. Company Online function enables you to remotely preview many workstations in different localizations.
Full control over IT infrastructure
Statlook means more than remote access and helpdesk. It is a full-fledged software to manage IT infrastructure. It takes only to install agents on workstations – also from remote, if you prefer – to gather valuable information about devices, software and users' activity. An intuitive interface enables you to filter and group data according to your need, as well as create certain reports concerning different elements of IT infrastructure. Our system also allows you to maintain a current monitoring of changes within both software and hardware.
If you would like to see how our system works – including remote access and helpdesk – we would like to invite you to see our free webinar.


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Appoquinimink Ruritan Club Auction
|April 28, 2017
Location: MOT Senior Center; 300 S. Scott St., Middletown
View and bid on hundreds of items donated by generous local area businesses for goods, services, entertainment, fitness and more! Preview and silent auction begin at 6 pm, live auction and continuation of silent auction at 7 pm. Funds received directly assist the MOT community through scholarships, donations and services. The Appoquinimink Ruritan Club has served the Middletown/Odessa/Townsend (DE) community since 1991 and is a member of Ruritan National. We are community people meeting community needs through five areas of service: business & professions, citizenship & patriotism, environment, public service and social development. Typical community programs and projects include: Little league sponsorship; educational scholarships; roadside clean-up and anti-litter drives; supporting life-saving squads/fire departments, veterans groups, senior citizens groups, blood drives, children's cancer camps and many more community endeavors. Food and beverages will be available for purchase from the MOT Senior Center. Join us for a night of fun and great buys!
American Towns - Ruritan Auction


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At our dental practice in Fremont, California, we look forward to giving you another reason to smile. With a full range of services and advanced dental technology, Drs. Thi Hoang and Thanh Pham can provide the compassionate, convenient, and comfortable care you are looking for. We invite you to contact us today and schedule your appointment! We are excited to help you discover a smile that you love!
Monday 9:00 a.m. – 3:00 p.m.
Monday 9:00 a.m. – 3:00 p.m.
Tuesday 10:00 a.m. – 6:00 p.m.
Wednesday 9:00 a.m. – 5:00 p.m.
Thursday 8:30 a.m. – 4:30 p.m.
Friday 9:00 a.m. – 5:00 p.m.
Mowry Dental
2147 Mowry Ave. Suite A5
Fremont, CA 94538


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What do you get when your favorite Chinese dishes and American classic brunch items have a love child?
We're picturing Peking duck and waffles; fried rice with scrambled eggs and sausage; and an omelet stuffed with Szechuan beef.
Blackbrick's Richard Hales must be reading minds, because that's exactly what he's serving at his new weekend brunch, offered in addition to his dim sum menu.
Hales tells Short Order that the idea came from the success of his Sunday midmorning offerings. "The dim sum menu has been very popular, with the restaurant packed every Sunday. We decided it was a good idea to offer dim sum Saturday as well, and to offer some brunch items to complement it."
See also: Blackbrick Offers $10 Lunch Special Featuring Local Produce
So Hales went into the kitchen and pretty much let his imagination run wild. "We're playing around with ideas of doing classic American brunch staples with Chinese ingredients and preparations. It's fun stuff."
The Blackbrick team has taken items from the regular menu and turned them into more breakfast-friendly options. Chinese flatbreads are stuffed with bacon, egg, and cheese. Chinese duck sausage is served over biscuits and smothered in Southern gravy. Peking duck rests on cinnamon bun waffles.
Other brunch-worthy Chinese/American mashups include a basket of Parker House rolls with char siu pork shoulder and Chinese hot mustard; the General's chicken liver toast on Zak the Baker's Jewish rye; and mala shrimp 'n' grits with Miami Smokers' bacon bits and a poached egg. If you've had a long, booze-filled evening, the Chinese salt-and-pepper tater tots with jalapeño and scallion will sop up any residual alcohol in your system.
Speaking of alcohol, bloody marys with spicy mustard and an MSG rim (yes, they went there); spicy peach and chili bellinis; and other specialty cocktails will be served, in addition to local beers such as Wynwood's La Rubia and Funky Buddha's Hop Gun.
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Dim sum shouldn't be forgotten, and for $20 you can get a pot of Blackbrick's seven-year aged Tou Cha hot tea and a selection of buns, bites, and dumplings.
Prices aren't set yet, but everything costs between $5 and $29. Brunch (and dim sum) will be served every Saturday and Sunday from 11:30 a.m. to 4 p.m. beginning Saturday, April 19.
Follow Laine Doss on Twitter @LaineDoss and Facebook.
Follow Short Order on Facebook, Twitter @Short_Order, and Instagram @ShortOrder.


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Michael Head
Company: Pyramid Technology Solutions, Inc.
Title: General Counsel | Director of Contracts
Michael Head currently serves as General Counsel and Director of Contracts at Pyramid Technology Solutions, Inc. (���PTS�). PTS is a leading provider of IT consulting, business technology, software development and professional staffing services for both domestic and international markets. PTS supports private and public sector clients of all sizes in a variety of industries providing high quality services, customized solutions and experienced personnel at budget-conscious prices. PTS is a one-stop solution for its clients�۪ IT needs.
Michael is responsible for managing the day-to-day legal affairs and overseeing contracts administration and management at this growing company. In addition to those responsibilities, Michael supports company management with corporate strategy and operations helping PTS stay on the forefront of technology while adapting to the changing needs of its clients and consultants.


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Join us on Oct. 10th, from 5-7, for "A Taste of Nature," a unique dining experience at The Nature Place! This progressive dinner will take your taste buds on a tour of The Nature Place and surrounding grounds, as you move from station to station, sampling seasonal food and beverages curated locally by Sweet Street Desserts, Oakbrook Brewing Company, Farmhouse Kitchen & Wild Sage Coffee & Kitchen!
Tickets can be purchased by clicking HERE!
Your ticket includes food, as well as beer and other beverages throughout the event. The evening's menu will be published by Sept. 21.
Event open to Berks Nature members, at $50/per ticket.
Non-members: A combination event ticket and one year individual membership can be purchased together for a reduced price of $80.
Childcare available on-site during the event for an additional $10. Simply add it to your cart along with your ticket.
This event is supported in part by Sweet Street Desserts & Oakbrook Brewing Company.
Those with questions are asked to contact Becca Gregg Sansom at email@example.com, or 610-372-4992 x109.


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PES project – Little Avon
Phase two of this project has been completed and the final stage which would include recommendations for next steps is due for completion in August. BART are excited at how well the combined team have performed and for the future on this lovely little river. BART are also busy building relationships in other areas of the Little Avon, and are particularly pleased to welcome John West as our local Beacon for the area.
The following link will take you to the PES project description on the DEFRA website
Partnership Working
Festival Of Nature
Mark and Ian model their new T-shirts!
The Festival was BART's first major public outing and it was great to see and hear the excitement of youngsters seeing the fish and bugs on display. Plenty of future volunteers! It was also good to get some of the main messages across about how damage to the health of the river can be caused.
The Festival itself was a fine example of volunteering and youth in action – I was met by a volunteer on arrival, checking I was entitled to be there, let into my tent by a pair of brilliantly effective co-ordinators, clearly destined for leadership roles, and assisted throughout the day by volunteers who seemed capable of almost anything. We hope to have made an impression on some as they have offered to become involved with BART during the Summer.
Challenge of the day? Explaining the word spawning to a young French chap!
Festival Of Nature
The Festival takes place on Saturday and Sunday, 15th and 16th June. BART will be helping in the WildWaters tent and we have just completed our display board – everything arriving by van and postman during the week as planned. While searching for some photos to include I found this little "volunteer" from 20 years ago. If she turns up over the weekend I will be in trouble!
Bristol Big Green Week
If you haven't already seen the array of interesting talks available in Bristol during this week – 15th to 23rd June take a peek. A highlight should be the Question Time: The State of Nature, the Next Step. BART will be attending to keep abreast of the great work being done locally by our Wildlife Trusts. We have recently had an excellent meeting with Wiltshire Wildlife Trust to discuss work BART is doing in the By Brook area to avoid duplication and to look for areas where we can compliment each other.


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Ryan Davon McKinney Sr. | Funeral Home
Funeral service for Ryan Davon McKinney Sr., age 43 years, of Sea Breeze Estates, will be held on Saturday May 19, 2018 at 10:00 a.m., at Church of God of Prophecy East Street Tabernacle, East Street. Officiating will be Bishop Jeffrey Knowles assisted by Minister Branson Gibson. Interment will follow in Woodlawn Gardens, Soldier Road.
Left to forever cherish his memories are his Parents: Charles and Patricia McKinney; Son: Ryan Jr.; Sisters: Greer and Shovonia McKinney; Grandfather: Charles McKinney Sr.; Nephew and Niece: Caleb and Shiloh Elizabeth; Aunts and Uncles: Victor and Vernitia McKinney, Bishop Samuel and Lula Thompson (Miami Fl.), Derek Thompson, Phillip and Polly Thompson, Andrew and Lilis Thompson, Basil and Theresa Thompson, Stephaine McKinney and Patrick and Emily McKinney; Grand Aunt: Elva Minnis, Godparents: Bishop George Thompson and Paulette Haven; Numerous cousins including: Dave, Sophie and Andre McKinney, Pastor Byron and Tiffany Hudges, Garvado and Ghandi Thompson, Darius Francis, Ambrose and Shanell Dean, Matthew, John, Philian, Lavar, Andice, Lasalle, LeAndo, Andrenique, Candace, Tarell, Teron Thompson, Patniksa and Jermaine McKinney, Enique Farrington, Endrenice Babb, Jarrisa, Mario and Eldira Beckford and Antione and Jipco Thompson; and a host of Relatives and Friends including: Bishop George and Damaris Thompson, Helen Taylor, Ruth and Albert Cleare, Gwen and Ervin Knowles, Sean and Christine Gibson, Lynden, Gregory and Frankus Gibson, Vincent and Bernardette Beneby, Pastor Phillip and Helena Ferguson, Kevin and Samita Ferguson, Clifford and Anastacia Forbes, Joey and Collene Alleyne (Los Angeles, CA.), Veron and Siobhan Addision, Derek and Rose Moss, Georgette and Mackeon Thompson, Garzelle Woodside, Bronson Knowles, Chino, Johnathan, Timothy and Krista Knowles, Dellerece Carroll, Barbara Johnson and Family, Darius Johnson, Florie Adderley and Family, Malvese Adderley, Minster Ezekiel and Oralee Adderley, Sharon Thompson and family, the families of the late Caroline Wallace and the Late Julia Adderley, the Late Barbara Adderley, Barclays Bank Pensioners, Fingertips Beauty Salon, Burns House, Bahamas Dept. of Corrections, Ministry of National Security, Pandora Thurston, Ian and Sheree Morley, Aldrin and Pamela Sears, Sharmine Smith, National Insurance Broad- Central Benefits Dept., Audrey and Shena Rolle and Family, Anna Dean and Family, Ena Stubbs and Family, George Hall and Family, Theresa, Allison, Marsha and Warren Doc Thompson, Elise Delancy, Kim and Christoff Iturriaga, Helen Williams, Clarice Williams and Family, Quinton and Patricia Rolle, the Bay Cedar Close family: Larisa Johnson, Paula Darville, Anthony and Cherry Weech and Family, Joyann Cartwright, Raphael and Wendy Munnings, Kim Thurston, the Kemp Road, Coopers Terrace and Five Pound Lot family, Delores Delancy, Carol Hanna, Lydia Rahming, Essie Ferguson, Frylease Knowles, Chery Gibson, Paulette Miller, Karon Clarke, Margaret Larrimore, Sybilene Taylor, Georgina Curtis, Marina Young, Millie Young, Judith Williams, Petrona Kemp, Marcus Wilkinson, Kelesy, Rudolph and Rosevelt Williams, Andrew and Harry McKinney, Walter Gibson, Kathlene Moxey, Henry Dean, Joan Miller, Betty Bullard, Carmie Taylor, Ronald and Preta Burnside, Charlotte Wells, Reginald Wells, Ellen Adderley, Shirley Cooper, Calvin Davis, Wemyss Bight, Eleuthera Family, Hillside Park family, Church of God of Prophecy Ernest Street, Men and Women Fellowships, Jan Mortimer and many others.
Special Thanks to: Commonwealth Brewery/Burns House and Butlers' Funeral Homes & Crematorium, Dr. Ramphal, Dr. Isaacs, Dr. Khan, Dr. Chernile Carey Bullard and Advance Family Medical.
Friends may pay their last respects at Butlers' Funeral Homes & Crematorium at Ernest and York Streets on Friday May 18, 2018 from 11:00 a.m. to 5:00 p.m. and on Saturday May 19, 2018 at Church of God of Prophecy East Street Tabernacle from 9:00 a.m. until service time.
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