text:
Home Policy Priorities ICI Comment Letters
- Fund Regulation
- Retirement Security
- Trading & Markets
- Fund Governance
- Taxes
- ICI Comment Letters
June 19, 2000
Mr. Jonathan G. Katz
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0609
Re: File No. S7-11-00
Dear Mr. Katz:
The Investment Company Institute1 is writing in response to the Commission's recent release on the use of electronic media by securities issuers and market intermediaries.2 Our members are actively engaged in using electronic means to communicate and conduct business with investors. Consequently, we strongly support the Commission's goals of reducing uncertainty about the application of the federal securities laws to the use of electronic media, and removing barriers to the use of electronic media, while preserving important investor protections.3
In the case of mutual funds, however, the Commission's new "guidance" falls far short of these goals. In fact, it takes several steps backwards by increasing uncertainty about and barriers to the use of electronic media by mutual funds. In large part, this is the result of the Release's focus on typical corporate issuers and its lack of attention to unique considerations for mutual funds. While the Release nominally covers mutual funds, in several instances references to mutual funds appear to be thrown in as afterthoughts. Moreover, in contrast to the Commission's previous releases on the use of electronic media,4 both of which provided helpful examples to illustrate the application of the Commission's interpretive positions to mutual funds, the Release does not include any mutual fund-specific examples. The problems the Release creates for mutual funds are exacerbated by the odd procedural approach the Commission chose, under which new interpretive positions became effective while the Commission simultaneously requested comments on them.
This letter discusses issues that the Release raises regarding mutual funds' use of hyperlinks to third-party information. It then comments on issues that arise in connection with the Commission's attempt to clarify the "envelope theory." Finally, the letter addresses issues related to consent, electronic-only offerings, access to historical information, and Internet discussion forums.
I. Mutual Fund Use of Hyperlinks to Third-Party Information
The Release purports to provide guidance on issuer responsibility for hyperlinked information under the anti-fraud provisions of the federal securities laws. With respect to mutual funds, however, the Release creates confusion and uncertainty in this area. The unfortunate result is to put a chilling effect on the use of an effective and convenient means of allowing investors to gain easy access to information that may assist them in making an investment decision or simply be of interest to them. The problems created by the guidance are discussed below.
First, mutual fund web sites generally are treated as a form of advertising and, as such, must be filed with the NASD under the NASD Conduct Rules. For the last several years, mutual funds whose web sites include hyperlinks to third-party information have relied upon guidance issued by the NASD regarding their responsibility for that information.5 While this guidance relates specifically to the responsibility of NASD members for third-party material under NASD rules, it establishes conditions that address relevant investor protection concerns. Nevertheless, without even so much as a footnote acknowledging the NASD's existing guidance, or any opportunity to comment ahead of time on a proposed different approach, the Release institutes new and conflicting standards for analyzing responsibility for hyperlinked information.
Second, the Commission's framework for analyzing issuer responsibility for third-party information simply does not work for mutual funds. In particular, in discussing issuer responsibility for hyperlinked information, the Release distinguishes between hyperlinks embedded in "documents" required to be filed or delivered under the federal securities laws, and other hyperlinks. In the case of "documents" falling into the first category, the Release indicates that an issuer would always be responsible for third-party information to which it establishes a hyperlink.6 For other hyperlinks, the Release discusses certain factors that may be relevant to an analysis of whether the issuer has "adopted" the hyperlinked information for anti-fraud purposes.
This framework ignores the fact that mutual fund advertisements and sales literature are "document[s] required to be filed . . . under the federal securities laws."7 In fact, because mutual fund web sites themselves generally are considered a form of advertising, read literally, the Release effectively indicates that a mutual fund is always responsible for third-party information to which it establishes a hyperlink from its web site. Presumably, this result is not what the Commission intended.
Third, the Release separately discusses considerations that apply to web site communications (including hyperlinks to third-party information) when an issuer is "in registration." By treating this as a discrete issue, the Release again makes apparent its focus on typical corporate issuers, while further complicating the application of its guidance to mutual funds, which are continuously "in registration."8 The Commission should clarify that any special restrictions on issuers "in registration" would cease to apply to a mutual fund once it has an effective registration statement.
In short, the discussion of hyperlinks in the Release evidences little understanding of how mutual funds use web sites or even of how they are regulated – a bizarre occurrence given the Commission's oversight and regulatory responsibilities for this seven trillion dollar industry.
Our specific comments on the Commission's approach to analyzing issuer responsibility for hyperlinked third-party information are set forth below.
A. Relevant Factors
As noted above, the Release discusses certain factors that may be relevant to an analysis of whether an issuer has "adopted" third-party information to which it has established a hyperlink. These factors are: (1) the context of the hyperlink; (2) the risk of confusion about the source of the hyperlinked information; and (3) the presentation of the hyperlinked information. In contrast to the NASD Hyperlink Letter, which sets forth objective criteria for determining responsibility for hyperlinked information,9 the Commission's guidance incorporates many subjective elements. While we understand that the Commission has an interest in maintaining flexibility, excessively vague standards are difficult to administer, provide no regulatory certainty, and could discourage mutual funds from using hyperlinks to third-party information, thereby depriving investors of a useful and desirable feature of electronic communications.
1. Context of the Hyperlink
In introducing the discussion of the three factors listed above, the Release states: "We do not mean to suggest that any single factor, standing alone, would or would not dictate the outcome of the analysis."10 Yet, just two paragraphs later, the Release seems to contradict this statement by indicating that when an issuer embeds a hyperlink to a web site within a document that is required to be filed or delivered under the federal securities laws, the issuer should always be deemed to be adopting the hyperlinked information. We recommend that the Commission, at the very least, clarify that its sweeping statements in the Release regarding an issuer's responsibility for third-party information to which it establishes a hyperlink from a document required to be filed under the federal securities laws were not intended to cover hyperlinks from mutual fund advertisements or sales literature.
We note that the remaining discussion of the significance of the context in which an issuer places a hyperlink is not particularly helpful. For example, why should the fact that hyperlinked information may support a particular assertion on an issuer's web site necessarily suggest that the hyperlinked information is attributable to the issuer?11 And what should an issuer make of the statement that "even when an issuer remains silent about the hyperlink, the context nevertheless may imply that the hyperlinked information is attributable to the issuer"?12
Further, the Release states that "when an issuer is in registration, if the issuer establishes a hyperlink . . . from its web site to information that meets the definition of an "offer to sell," "offer for sale" or "offer" under Section 2(a)(3) of the Securities Act, a strong inference arises that the issuer has adopted the information for purposes of Section 10(b) of the Exchange Act and Rule 10b-5."13 The Release does not provide a rationale for this "strong inference," nor does it indicate how the inference might be countered. As a result, given that mutual funds are always "in registration" and given the breadth of information that might possibly be deemed an "offer to sell," "offer for sale" or "offer," this statement merely creates additional regulatory uncertainty for mutual funds. This result is directly contrary to the stated goals of the Release.
2. Risk of Confusion
The Release states that in determining whether an issuer has adopted hyperlinked information, the Commission also would consider the presence or absence of precautions against investor confusion about the source of the information. As a general matter, this is a reasonable proposition. We note, however, that after describing certain practices that may lessen confusion and thus help establish that an issuer has not adopted hyperlinked information, the Release indicates that "the risk of investor confusion is higher when information on a third-party web site is framed or inlined."14
The Institute is concerned that this negative characterization of the use of various techniques for importing third-party information into a web site ("inverse hyperlinks") inappropriately fails to acknowledge that there are effective ways to lessen the risk of confusion when these techniques are used. Indeed, earlier this year, the Institute sent a letter to the NASD recommending that the NASD extend its position on "ongoing hyperlinks" to cover inverse hyperlinks if the third-party information is clearly identified as such and investors are put on notice that the member is not responsible for the content of the third-party information.15 As we indicated to the NASD, the important consideration for regulatory purposes should not be how the information is linked, but rather that appropriate safeguards are in place to ensure that the third-party information investors receive is unbiased and not misleading.
Likewise, the Commission should not cast an unwarranted pall over the use of innovative techniques for providing investors with convenient access to useful information, but rather should focus on how to promote responsible use of these techniques. Thus, for example, a mutual fund web site should be able to include framed third-party information such as industry or market data or financial news, subject to safeguards that address the potential risk of confusion (e.g., clear identification of the source of the third-party information), without the mutual fund becoming responsible for the third-party information.
3. Presentation of the Hyperlinked Information
The Release indicates that the presentation of hyperlinked information by an issuer is relevant in determining whether the issuer has adopted the information. To some extent, it appears, this factor seeks to address concerns that the NASD Hyperlink Letter addresses through conditions that limit an NASD member's ability to exercise selectivity in making a third-party hyperlink available. Unfortunately, the Release goes on to provide several examples of what the Commission might consider regarding the presentation of hyperlinked information. These examples introduce a hopeless degree of subjectivity into the analysis and do not seem to address significant or relevant investor protection concerns.
For example, the Release states that "where a wealth of information as to a particular matter is available, and where the information accessed by the hyperlink is not representative of the available information, an issuer's creation and maintenance of a hyperlink could be an endorsement of the selected information."16 The Release provides no guidance, however, on how one might determine whether certain information is "representative of the available information" on a particular topic. Would Morningstar data be considered "representative of the available information" about mutual funds?
The Release also cites the layout of the screen containing a hyperlink, and the prominence, size, location, color, or type font or size used for a particular hyperlink as compared to others as potentially relevant considerations. The notion that the color of a hyperlink should influence whether the issuer is responsible for the hyperlinked information is especially unhelpful, or can we expect the Commission to provide guidance on which colors it prefers?
Finally, the Release states that "[w]here the method of presenting the hyperlink influences disproportionately an investor's decision to view third-party information, the hyperlinked information is more likely attributable to an issuer." 17 The Institute wonders how such a criterion might possibly be applied in practice.
B. Institute Recommendations
As the foregoing comments suggest, the Institute is very disappointed in the "guidance" set forth in the Release concerning responsibility for third-party information to which a mutual fund establishes a hyperlink. The Commission should revisit this issue, working with the NASD and the industry to develop useful and workable guidance for mutual funds. In particular, the Commission should establish objective criteria that mutual funds may rely on and provide real-world examples of the application of its positions in the mutual fund context, as opposed to making vague, open-ended theoretical statements that raise more questions than they answer.
II. Clarification of the Envelope Theory
The Release seeks to clarify certain aspects of the so-called "envelope theory," which deals with when electronically delivered documents are considered to be delivered together for purposes of the federal securities laws. In so doing, however, the Release creates problems and ambiguities for mutual funds.
First, the Release states that "if an issuer includes a hyperlink within a Section 10 prospectus, the hyperlinked information would become part of that prospectus. When embedded hyperlinks are used, the hyperlinked information must be filed as part of the prospectus in the effective registration statement and will be subject to liability under Section 11 of the Securities Act."18 These statements may create an inconsistency between electronic and paper documents. For example, in the paper context, issuers generally have the ability to define the boundaries of their prospectuses; information does not become part of the prospectus unless the issuer writes it in as part of the prospectus text or affirmatively indicates that it is incorporated by reference. Consistent with this, providing access to information through a hyperlink from a prospectus, as compared to in an envelope with a prospectus, should not result in a different liability standard, so long as appropriate steps are taken to make sure that the viewer understands where the prospectus begins and ends. While placing hyperlinks to third-party information within Section 10 prospectuses does not appear to be a common practice in the fund industry at present, the Commission should seek to avoid potential inconsistencies in regulatory treatment.19
Similarly, the Release raises issues in the area of permissible uses of mutual fund sales literature. Under Section 2(a)(10)(a) of the Securities Act, certain sales literature ("supplemental sales literature") is not considered a prospectus, as long as the material is preceded or accompanied by a Section 10(a) prospectus. Thus, for example, a mutual fund may place supplemental sales literature in an envelope with a Section 10(a) prospectus and send it to investors. The sales literature does not become part of the prospectus by virtue of being delivered with it.
Mutual funds also are permitted to use prospectus "wrappers," i.e., sales literature that is wrapped around the prospectus. Funds use various means to make clear to investors that the sales literature is not part of the prospectus. These means may include, for example, placing a legend on each page of the sales literature stating that it is not part of the prospectus, or using different paper stock, type size, and/or color to distinguish the sales literature from the prospectus.
Consistent with these uses of sales literature in the paper world, in an electronic environment, funds should be able to create hyperlinks from their prospectuses to sales literature – and vice versa – without the sales literature being considered part of the prospectus and subject to prospectus liability. The guidance in the Release would not accommodate this practice.
The Commission therefore should clarify that where a fund prospectus includes a hyperlink to sales literature (which may be a two-way hyperlink), the sales literature does not become part of that prospectus, so long as the fund takes steps to clearly differentiate the sales literature from the prospectus. 20
The Release also raises concerns as to whether material on a fund web site that is outside of a Section 10 prospectus (where the web site includes a Section 10 prospectus) would be considered (1) part of the prospectus and/or (2) "impermissible" free writing. For example, the Release notes that securities lawyers have raised concerns about whether, if a Section 10 prospectus is posted on a web site, the operation of the envelope theory causes everything on the site to become part of that prospectus. 21 The Release also indicates that concerns have been raised that information on a web site that is outside of the four corners of the Section 10 prospectus, but in close proximity to it, would be considered free writing.22 In addressing these matters, the Release states that "with respect to the free writing concern, the focus on the location of the posted prospectus is misplaced. Regardless of whether or where the Section 10 prospectus is posted, the web site content must be reviewed in its entirety to determine whether it contains impermissible free writing. The Commission staff will continue to raise questions about information on an issuer's web site that is either inconsistent with the issuer's Section 10 prospectus or that would constitute an 'offer to sell,' 'offer for sale' or 'offer under Section 2(a)(3) of the Securities Act."23
The discussion of these issues in the Release does not specifically address in any straightforward manner the situation where an issuer's web site as a whole and at all times is considered a form of advertising, as is the case for mutual funds. The Release also ignores the fact that SEC rules specifically allow mutual funds to provide forms of sales materials other than a Section 10(a) prospectus. 24 Moreover, the securities laws do not prohibit funds from providing non-offering material along with prospectuses and sales literature, so the notion of "impermissible" free writing seems misplaced in the mutual fund context. We recommend that the Commission clarify the application (or non-application, as the case may be) of its guidance in this area to mutual funds.
III. Other Topics
A. Consent Requirements
The Institute notes that Congress has recently passed the "Electronic Signatures in Global and National Commerce Act," which President Clinton is expected to sign into law. This legislation contains detailed consent requirements that will apply to most electronic disclosure documents. We are studying the impact of the legislation on the Commission's guidance in this area, and may have further comments at a later time.
B. Electronic-Only Offerings
The Release requests comment on whether the existing paper back-up delivery requirement should be eliminated for electronic-only offerings where investor participation is limited to those investors who consent to electronic delivery of all disclosure documents. We believe that it should be eliminated in these circumstances. For instance, a mutual fund offering effected entirely through electronic media, where investors consent to delivery of all disclosure documents electronically, would by definition involve only investors who have affirmatively chosen to conduct business with the fund in an electronic only environment. In this situation, no investor protection purpose would be served by mandating a paper back-up system, which would require funds to prepare paper disclosure documents that they otherwise would not have to produce.
C. Access to Historical Information
The Release requests comment on how to facilitate the availability of historical information on the Internet consistent with the federal securities laws. We believe that the best way for mutual funds to minimize investor confusion while providing investors with access to historical information is to archive historical information in a separate or distinct area on the fund's web site that is clearly marked as historical or archived material. Historical material segregated in such a fashion would clearly indicate to investors that it is not current material and therefore should not be deemed to be republished each day or each time that it is accessed by an investor.
D. Internet Discussion Forums
The Release invites comment on issues relating to Internet discussion forums. We have two requests for clarification in this regard. First, we request clarification that the Commission considers live online auditoriums or web casts to be oral communications that do not need to be filed pursuant to Section 24(b) of the Investment Company Act. As the Release recognizes, such online auditoriums are typically held in "real-time," led by a moderator and may feature a guest "expert" who provides spontaneous answers to participants' questions. The statements of the moderator and the expert at these online discussion forums are analogous to oral statements made by speakers at live seminars, which the Commission has determined do not trigger the filing requirements of Section 24(b).25 In these live moderated forums, the guest expert, like the seminar speaker, is not reading prepared sales material, but speaking generally in his or her area of expertise, and answering spontaneous audience questions. We therefore believe that online auditoriums should not trigger the filing requirements of Section 24(b).
Second, we request clarification that a fund would not have liability under the federal securities laws with respect to information posted on a bulletin board on the fund's web site in certain circumstances. Specifically, we believe that where a fund hosts a bulletin board, the fund should not be liable under Section 12 of the Securities Act of 1933 or Rule 10b-5 of the Securities Exchange Act of 1934 for communications posted on the bulletin board by third parties, under the following conditions: (1) the fund does not post its own messages on the bulletin board;26 (2) the fund does not control which messages are or are not posted on the bulletin board or edit the content of the bulletin board, except for legal compliance reasons (e.g., to comply with laws regarding copyright infringement, defamation, obscenity, etc.); and (3) the fund clearly informs participants that it does not control participation in the bulletin board, has no liability for the content or accuracy of the posted information, and does not edit the substantive content of the material. Under such circumstances, a fund is merely providing a forum for the free exchange of ideas and information, and is not offering its securities for sale. Consequently, the fund should not be liable under the federal securities laws for the content of communications posted by third parties. 27
* * *
The Institute hopes that the Commission will carefully consider our comments and, more generally, reconsider various positions taken in the Release, at least as they apply to investment companies. If you have any questions, please contact the undersigned at (202) 326-5815, Frances Stadler at (202) 326-5822 or Doretha VanSlyke Zornada at (202) 326-5819.
Craig S. Tyle
General Counsel
cc: Paul F. Roye
Alison M. Fuller
Assistant Chief Counsel
David W. Grim
Special Counsel
Division of Investment Management
Securities and Exchange Commission
Thomas M. Selman
Vice President
Investment Companies/Corporate Financing
NASD Regulation, Inc.
1 The Investment Company Institute is the national association of the American investment company industry. Its membership includes 8,051 open-end investment companies ("mutual funds"), 497 closed-end investment companies and 8 sponsors of unit investment trusts. Its mutual fund members have assets of about $7.009 trillion, accounting for approximately 95% of total industry assets, and over 78.7 million individual shareholders.
2 SEC Release Nos. 33-7856, 34-42728, IC-24426 (April 28, 2000), 65 Fed. Reg. 25843 (May 4, 2000) ("Release").
3 See SEC to Consider Issuance of Interpretive Release on the Use of Electronic Media, Fact Sheet, April 25, 2000, at 1.
4 SEC Release Nos. 33-7233, 34-36345, IC-21399 (October 6, 1995), 60 Fed. Reg. 53458 (October 13, 1995) ("1995 Release"); SEC Release Nos. 33-7288, 34-37182, IC-21945 (May 9, 1996) 61 Fed. Reg. 24644 (May 15, 1996).
5 See Letter from Thomas M. Selman, Director, Advertising/Investment Companies Regulation, NASD Regulation, Inc. to Craig S. Tyle, General Counsel, Investment Company Institute, dated November 11, 1997 ("NASD Hyperlink Letter").
6 See 65 Fed. Reg. at 25847, n. 41 (indicating that "[w]hen an issuer includes a hyperlink within a document required to be filed or delivered under the federal securities laws, we believe it is appropriate for the issuer to assume responsibility for the hyperlinked information as if it were part of the document"). See also 65 Fed. Reg. at 25849 (stating that "[i]n the context of a document required to be filed or delivered under the federal securities laws, we believe that when an issuer embeds a hyperlink to a web site within the document, the issuer should always be deemed to be adopting the hyperlinked information") (footnote omitted).
7 See Section 24(b) of the Investment Company Act. Pursuant to Rule 24b-3, most funds satisfy this requirement by filing sales material with the NASD.
8 The Release does mention, at the end of a lengthy footnote, that unlike other issuers, mutual funds "continuously offer and sell their shares to the public and, therefore, are continuously subject to the limitations on issuer communications under the Securities Act." 65 Fed. Reg. at 25850, n. 68.
9 The NASD Hyperlink Letter states that the NASD would not hold an NASD member responsible under the NASD Conduct Rules for the content or filing of information on a third-party web site to which the member establishes an "ongoing hyperlink" if: (1) the hyperlink is continuously available to investors who visit the member's site; (2) the member has no discretion to alter the information on the third-party site; (3) investors have access to the hyperlinked site whether or not it contains favorable material about the member; and (4) the linked site could be updated or changed by the third party and investors would nonetheless be able to use the hyperlink. In addition, a member may not establish a hyperlink to a site that the member knows or has reason to know contains false or misleading information about the member's products or services. The NASD Hyperlink Letter also indicates that NASD members would not be held responsible for the content or filing of an independent third party site that does not refer to the member or any of its affiliates and that is meant to educate investors about principles of investing or economic, tax, or financial issues.
10 65 Fed. Reg. at 25849.
11 This part of the Release implies that if a mutual fund web site includes generic information on a topic such as indexing or retirement issues, and provides a hyperlink to a third party site with a fuller discussion of these issues (that may support an assertion on the fund's web site), the content of the third party web site would be attributable to the fund. It is unclear how this result would promote any important policy objective. Moreover, it is inconsistent with the guidance provided in the NASD Hyperlink Letter.
12 65 Fed. Reg. at 25849. A footnote to this statement in the Release refers the reader to the discussion of presentation of the hyperlinked information which, as discussed below, has its own flaws.
13 Id. (footnote omitted).
14 Id. (footnotes omitted).
15 Letter from Doretha VanSlyke Zornada, Assistant Counsel, Investment Company Institute, to Thomas M. Selman, Vice President, Investment Companies/Corporate Financing, NASD Regulation, Inc., dated February 24, 2000. The NASD has not yet issued a response.
16 65 Fed. Reg. at 25849.
17 Id.
18 65 Fed. Reg. at 25847 (footnotes omitted).
19 Even if the Commission does not revise its general position on issuer liability for hyperlinks from Section 10 prospectuses to third-party information, the Commission should clarify its guidance on the placement of inactive uniform resource locators (URLs) to third-party web sites in prospectuses and other documents. In this regard, the Release states that "as with an embedded hyperlink, an issuer that includes a URL to a web site in a Section 10 prospectus or other document required to be filed or delivered under the federal securities laws is responsible for information on the site that is accessible through the resulting hyperlink." An exception is provided where a document provides an inactive URL to the Commission's web site or the issuer's web site, but the Release is silent as to whether this exception would also apply to an inactive URL address to a third-party web site. We can think of no valid policy reason for singling out the Commission's web site and the issuer's web site for this purpose. Thus, the Commission should clarify that its position on inactive URLs would extend to URLs to third-party web sites as well. Accordingly, as long as a fund takes reasonable steps to ensure that a URL to a third-party web site is inactive (for example, by removing "a>href" tagging) and includes a statement to denote that the URL is an inactive textual reference only, the information on the third-party web site should not be considered part of the document including the URL.
20 The Release raises another issue related to electronic supplemental sales literature in the context of discussing the ability of issuers and intermediaries delivering documents electronically to use portable document format (PDF). In particular, the Release clarifies that PDF may be used "if it is not so burdensome as to effectively prevent access." 65 Fed. Reg. at 25846. The Release also reminds issuers and intermediaries that the Commission will not consider an electronically delivered document to have been preceded or accompanied by another electronic document unless investors are provided with "reasonably comparable access" to both documents. Id. These statements may create ambiguity as to whether a fund prospectus in PDF that appears in close proximity to, or through a hyperlink from, supplemental sales literature that is in hypertext markup language (HTML), would be considered to precede or accompany the supplemental sales literature, such that the supplemental sales literature will not be deemed a prospectus, pursuant to Section 2(a)(10)(a) of the Securities Act of 1933. The Commission should clarify that a mutual fund could provide the prospectus in a different electronic format from the supplemental sales literature and still meet the "reasonably comparable access" standard. Thus, if investors seeking to access the prospectus are informed of the requirements necessary to access PDF documents and provided with any necessary software and technical assistance at no cost, investors would have reasonably comparable access to the prospectus and the supplemental sales literature. In these circumstances, the prospectus would be considered to precede or accompany the supplemental sales literature and the supplemental sales literature would not be deemed a prospectus.
21 See 65 Fed. Reg. at 25847.
22 Id.
23 Id. at 25847-48.
24 See, e.g., Rules 134 and 482 under the Securities Act of 1933.
25 See Tax Exempt Bond Fund for Minnesotans, Inc., SEC No-Action Letter (pub. avail. Mar. 10, 1981) ("an oral statement made at a seminar would not invoke the restrictions of Section 24(b) unless it communicates the contents of sales literature which has been transmitted through jurisdictional means such as the mails or interstate telephone ").
26 This condition should not preclude the fund from providing a topic for discussion on the bulletin board, so long as the fund does not participate in the discussion.
27 The same analysis and conclusion should apply to a fund's principal underwriter.
Copyright © 2017 by the Investment Company Institute


text:
|Publication number
|Publication type
|Application number
|Publication date
|Jan 20, 2009
|Filing date
|May 8, 2008
|Priority date
|Oct 11, 2001
|Fee status
|Also published as
|Publication number
|Salvo Aliffi, Filomena Ferrara
|Original Assignee
|International Business Machines Corporation
|Export Citation
|BiBTeX, EndNote, RefMan
|Patent Citations (19), Referenced by (3), Classifications (16), Legal Events (3)
|External Links: USPTO, USPTO Assignment, Espacenet
This application is a continuation of application Ser. No. 10/491,385, filed Aug. 27, 2004, status awaiting publication.
The present invention relates to a method and system for reducing the storage occupation of a color bitmap, particularly for use in those system where a bitmap must be stored or transmitted through a network.
Bitmap size is a critical parameter, particularly when the bitmap is to be stored or transmitted over a network. The storage occupation in the first case and the speed of transmission in the latter can be heavily affected. For this reason many techniques have been developed for reducing the size of bitmaps and consequently their storage occupation and speed of transmission. One kind of application, even if not the only one, where this need is extremely important is "remote control". Remote control programs are a special category of communication applications; they go beyond just connecting a computer with another computer to actually taking control of it. By connecting through phone lines and modems or through LAN connections, these programs can put all the resources of one data processing system (e.g. a personal computer or a workstation), usually called the target, under the complete control of another data processing system (e.g. a personal computer or a workstation, connected with a LAN), usually called the controller. The controller screen duplicates the target one. The keyboard of the controller can enter characters directly on the target data processing system; the mouse of the controller can move the mouse pointer on the target screen. The controller screen constantly receives data from the target data processing system screen. Likewise, the keyboard of the controller sends data to the target data processing system every time a key is hit. For all practical purposes, the controller user may as well be sitting in front of the target data processing system.
This kind of remote control software can be useful in a number of circumstances. Just as an example an office personal computer system can be controlled and operated from home personal computers. If the office PC is left connected (e.g. to a modem), the control can be taken from the home PC and all the resources of the target PC can be controlled and used remotely. A more specific use is to dial in (e.g. via modem) to a network—connected PC at the office, log in, and run network applications or update shared files an the network.
The bottleneck caused by transmission lines can have a significant effect on the speed of remote control operations. To boost performances, remote control programs try to reduce and minimize the amount of data that needs to be transmitted over the communication lines (e.g. LAN or telephone cables). The refresh of the video image on the display screen of the target PC, which should be duplicated on the controller PC, constitutes the main factor in the transmission speed, due to the large quantity of information which has to be transferred. In the past, remote control programs worked by sending and refreshing the entire image of the target PC screen to the remote PC every fraction of a second. The constant rate at which the screen images were sent to the controller PC was called the screen refresh rate. The controller PC screen accurately reflected the target PC screen as changes at the target PC would be included in the next screen refresh. This approach was, of course, not very satisfactory in terms of speed, because of the enormous amount of data to be transmitted at each refresh.
Often, a change of the image is limited to a small section of the screen (e.g. pulling down a menu, highlighting an object) and only the changed data need to be refreshed. The controller system can use the screen data previously received and just refresh the modified part of the screen. By cutting out redundant screen refresh data, a remote control program can improve the response time. Cache memories speed the performance of hard drives and memory chips, and can also be useful for remote control programs. The idea behind a cache is to keep recently used data in a temporary storage area that is quickly accessible. If the data are soon needed again, it is much quicker to access them from a fast-access temporary storage area than to retrieve from the original source. According to this technique, elements of a recently displayed screen are saved as a cache in extended memory. The entire page redraws from the controller PC screen cache, eliminating the need to transfer large amounts of information over the modem from the target to the controller PC. Screen elements that are often redrawn from a screen cache include bitmaps, text and fonts.
In the transmission of a bitmap image, one of the heaviest information to send is the color of each pixel. In the well known RGB format, the color of each pixel is represented by three octets (i.e. three bytes having 8 bits each), one for the Red, one for the Green and one for the Blue. The maximum possible number of different colors is 16,777,216, i.e. 2**24. This representation with all the possible colors is called "true color".
In remote control systems (as in many other circumstances) this detailed color representation is not always needed and the transmission of all this information frequently constitutes an unwanted burden. Usually for the scope of the controller system, a poorer color image would be enough. For this reason, many remote control systems use color reduction algorithms to reduce the color representation from 24 (or 16) bits to 8 bits or even 4 bits. An example of a function implementing these algorithms is GetDIBits from Microsoft. A drawback of prior art color reduction functions is that they require a relatively long computation time to perform this color reduction, mostly due to the effort of creating a reduced image as close as possible to the original one. In remote control system, where these operations must be performed very often at a very high speed rate, the color reduction delay is unacceptable. An alternative reduction mechanism is the one implemented by Tivoli Remote Control by International Business Machines Corp and described in GB Patent Application 9917455.9. This mechanism has the advantage of a faster processing, balanced by a reduced precision in the correspondence between the resulting "reduced" colors and the original ones. This reduced precision is normally acceptable, particularly in remote control systems, and preferrable to a delay in computation. A method combining the speed and easiness of processing with the precision of the results would therefore be highly welcome.
It is an object of the present invention to provide a technique which overcomes the above drawbacks.
According to the present invention we provide a method for reducing the size of a bitmap, the bitmap representing a plurality of pixel each pixel being represented by a bit pattern, the method including the steps of:
Also according to the present invention we provide a computer program including program code means for performing the method above when the program is run on a computer.
Various embodiments of the invention will now be described in detail by way of examples, with reference to accompanying figures, where:
The data processing system 105 is the controller and can alternatively take the control of one of the other data processing system 103, 107 and 109.
Data processing systems 103, 105, 107 and 109 can be personal computers or workstations available on the market. They preferably include a display unit and a keyboard, coupled in a manner well known in the art. Additionally, the data processing systems include a processor system unit which may serve to mount a fixed disk drive and a diskette drive in addition to the main processor and memory. Further, in order to facilitate the utilization of a graphical user interface, the data processing systems preferably include a graphic pointing device, such as a mouse, which may be utilized to manipulate the position of a pointer within a visual display on the screen.
Those skilled in the art will appreciate that data processing systems described above may be implemented utilizing any state of the art personal computer, such as the Personal Computer manufactured by International Business Machines Corporation.
Data processing systems are usually provided with a graphical user interface (GUI) to allow a user to control the data processing system and to present the results of user actions on the system display. In a graphical user interface, applications and data are generally presented as objects depicted on a user interface. A user is then provided with a graphical, intuitive interface to a complex data processing system which permits graphic selection of depicted objects and manipulation of applications corresponding to those objects.
There are a number of different graphical user interface environments commercially available which utilize the arrangement described above. These environments include the System 7 operating system developed by Apple Computer, Inc. (System 7 is a trademark of Apple Computer, Inc.), the Windows graphical user interface developed by the Microsoft Corporation (Windows is a trademark of Microsoft Corporation) and the OS/2 Presentation Manager developed by International Business Machines Corporation (OS/2 and Presentation Manager are trademarks of International Business Machines Corporation).
The window environment is generally part of the operating system software that includes a collection of utility programs for controlling the operation of the computer system 100.
In the example shown in
As mentioned above, one of the heaviest information relating to bitmaps is the color of each pixel of the original image. In remote control system, the level of precision requested is not usually very high and sending complete color information would waste transmission time. According to RGB format, the color of each pixel is represented by three octects (i.e. three bytes having 8 bits each), one for Red, one for Green and one for Blue. A subset of 256 of the possible 16,777,216 colors is usually enough for any applications. For remote control system, 16 colors are sometimes an acceptable compromise. These reduced representation make use of a sort of index (palette) which contains all the possible colors, usually in a "true-color" representation (i.e. three bytes). Another possible representation used in state of the art systems is the 64 k color bitmap. In a 64 k-color bitmap each pixel is represented by two bytes. These two bytes are not in this case an index in a 64 k long palette, but represent themselves the color. The sixteen bits are divided in three five-bit long groups. One bit is ignored. Each of these groups identifies the intensity of one of the basic colors: red, green, and blue.
However it may happen, and it normally happens, that most of these colors are never actually used. The number of colors that a bitmap supports determines only the number of bits that are used in that bitmap to represent the color, and not necessarily the number of colors that are really in use. In other words, one thing is the theoretical number of colors that could be found in the bitmap and another thing is the number of colors really used in the bitmap.
In theory a 256 colors bitmap could even have only 1 color if it is an area that has been painted with a "solid brush"; 2 colors if it is an area painted with a 2 color brush, or containing some writings. This is a very usual occurrence in a remote control systems, because it is the classic case of a big portion of a written page (i.e. when a word processor is displayed on the screen). The same concept can be extended to 4 colors as well as 16. The method and system according to the present invention could be used even with bitmaps having a bigger numbers of colors, but the advantages could be reduced or even vanished.
According to the present invention, when one of the above circumstances arise (i.e. only a limited number of colors are really used within a bitmap) the original bitmap can be substituted by a "normalized" version which addresses only the colors actually used. In the example made in
In bitmap 301 the pixel values 00 and FF have been substituted by 0 and 1, because the bitmap was actually using just two colors (corresponding to the first (00) and last (FF) hexadecimal entries of the color palette 203). The original bitmap 201 of
The example above shows how the original bitmap could be theoretically reduced to one eighth of the original size with a very simple operation and without loosing the precision of the original representation. In this case it is enough to replace all the occurrences of the byte 00 with a bit value of 0 and all the occurrences of the byte FF with a bit value of 1. The new bitmap is therefore meaningful when coupled with its 2nd level palette. It is by the 2nd level palette that it is possible to rebuild the original bitmap.
In the example made before the system uses a 256 color representation and a corresponding palette 203 (see
Palette entries
No. of colors
Bits per pixel
3 or 4
4 < x <= 16
x > 16
It should be noted that, in the first case no bitmap should be really transmitted, because only the single color is needed to reproduce the picture, while in the last (>16 colors used) there would be no advantage with the method of the present invention.
According to a preferred embodiment of the present invention the second level palette is obtained with the following steps:
The present invention has been described in details with reference to a starting bitmap having a 256-color representation. Those skilled in the art will appreciate that this is just an example and the same techniques can be applied to various representations without big differences. Another possibility, in case the original bitmap uses a color representation with a bigger number of colors, is to perform a color reduction step before the normalization process of the example above. In many cases this wouldn't be an additional burden, because, as mentioned above, a color reduction technique is often used in state of the art remote control systems. According to a preferred embodiment of the present invention, a color reduction technique, as disclosed in GB Patent Application 9917455.9, is used to convert a 64 k-color bitmap (or even a "true-color" bitmap) to a 256-color bitmap. When this kind of color reduction is performed the whole bitmap is scanned pixel by pixel. A preferred embodiment of the present invention, takes advantage of this scanning for additional operations:
The same information can be obviously retrieved without necessarily modifying the color reduction algorithm, but it is reasonable to do so for higher efficiency.
The following are examples of the way the method steps described above could be implemented in a preferred embodiment of the present invention.
Counting the Number of Colors.
In the case of a 256-color bitmap, it is enough to allocate a 256 byte long array and a counter. Initialize the array and the counter to zeros. To count the number of colors you need to scan the bitmap. Every time that a new pixel is scanned, use the pixel as the index to this array. If the corresponding element value is still at 0, change it to 1 and increment the counter. When the scanning is complete the counter indicates the number of colors really used by the bitmap.
Normalization of the Bitmap.
In the case of a 256-color bitmap, it is enough to allocate a 256 byte indirection array. Again, it is obvious that this scanning, when possibly, should take advantage of a scanning of the existing method. A variable is needed that indicates which new entry in the indirection index array is being added. This array represents the translation of the corresponding palette entry in the 2 nd level palette. Therefore it turns out that only N entries will be used, where N is exactly the number of colors. The value that the other entries assume is meaningless. Those entries will never be accessed since there is no pixel in the original bitmap pointing to those locations. Every time a new color is encountered the pixel value itself is used as the index to this array (similar process used when counting the colors) and the corresponding entry is updated with the new value of the pixel in the normalized bitmap. The counter is then incremented. The same counter used to count the colors can be used if the two processes are combined together. Once this array is made, it is easy to build the second level palette and to perform the normalization of the bitmap, replacing all the occurrences of the original pixel with the corresponding entry of the indirection index.
While the indirection index is used in the normalization bitmap process, the second level palette is used to perform the reverse process. For this reason, the second level palette must be transmitted together with the normalized bitmap, so that the original bitmap can be obtained with a reverse process.
The second level palette is an output of the normalization process, and an input to the reversed normalization process.
In a normalized bitmap a pixel is represented with less bits than the original bitmap. The pixel is interpreted as an index to the 2nd level Palette where the expanded or original value of the pixel in the non-normalized bitmap is stored.
Reverse Normalization Process.
This process is supposed to restore the original bitmap from the normalized bitmap and the 2 nd level Palette. The process is exactly the reverse of the normalization one. Given the number of bits per pixel used by the normalized bitmap, the process is to replace the occurrence of each value with the corresponding entry of the 2nd level Palette.
It must be noted that the performances of method and system described above, when implemented in state of the art systems which store or transmit color bitmaps (e.g. remote control systems) could be affected by compression algorithms. It is therefore difficult to give an exact absolute dimension of the improvement in performances when using the present method. It has been estimated anyway that, when a limited number of colors is used in a bitmap (e.g. less than 16 in a 256 color representation), an average decrease of 20% in the size of the bitmap is obtained, with consequent reduction in transmission speed rate.
|Cited Patent
|Filing date
|Publication date
|Mar 20, 1998
|Sep 26, 2000
|Fujitsu Limited
|Color image transfer processing apparatus and method, color image reconstruction processing apparatus and method, and color image transfer system
|Apr 11, 2000
|Feb 18, 2003
|International Business Machines Corporation
|Enhanced compression of gray-level images
|May 12, 2000
|Jul 29, 2003
|International Business Machines Corporation
|Color reduction for a remote control system
|Aug 12, 1997
|Sep 16, 2003
|Thomson Licensing S.A.
|Memory efficient compression apparatus in an image processing system
|Jul 21, 1999
|Aug 3, 2004
|Fujitsu Limited
|Image processing apparatus and pattern extraction apparatus
|Jul 13, 1999
|Sep 14, 2004
|Oc�-Technologies B.V.
|Method and apparatus for converting non-printable color values to printable color values
|Dec 11, 2002
|Oct 26, 2004
|Zebra Atlantek, Inc.
|Security code verification for identification cards
|Mar 12, 2001
|Mar 8, 2005
|The Regents Of The University Of California
|Perception-based image retrieval
|Oct 9, 2001
|May 31, 2005
|Nec Corporation
|Image data storage method
|Apr 24, 2000
|Dec 20, 2005
|The Regents Of The University Of California
|Color image segmentation method
|Nov 12, 1997
|Jun 27, 2002
|Jun Zhao
|Generating and using a color palette
|May 24, 2001
|Jan 9, 2003
|Bossut Philippe J.
|System and process for automatically determining optimal image compression methods for reducing file size
|Feb 11, 2003
|Aug 7, 2003
|Canon Kabushiki Kaisha
|Generating and using a color palette
|Title not available
|Title not available
|Title not available
|Title not available
|Title not available
|Title not available
|Citing Patent
|Filing date
|Publication date
|Dec 11, 2009
|Jun 24, 2014
|Microsoft Corporation
|Accelerating bitmap remoting by identifying and extracting 2D patterns from source bitmaps
|Apr 15, 2010
|Jul 1, 2014
|Microsoft Corporation
|Accelerating bitmap remoting by identifying and extracting patterns from source bitmaps through parallel processing techniques
|May 23, 2014
|Mar 8, 2016
|Microsoft Technology Licensing, Llc
|Accelerating bitmap remoting by identifying and extracting 2D patterns from source bitmaps
|U.S. Classification
|382/166, 382/232
|International Classification
|Cooperative Classification
|European Classification
|Sep 3, 2012
|Maintenance fee reminder mailed
|Jan 20, 2013
|Lapse for failure to pay maintenance fees
|Mar 12, 2013
|Expired due to failure to pay maintenance fee
Effective date: 20130120

subset: commoncrawl


text:
Need a quote?
Save time and we'll contact 5 reputable Cornice fixing companies for you
Click here!
Unit 2c, The Wend, Coulsdon, Surrey, CR5 2RA, United Kingdom
Davuka GRP Ltd Cornice, Coving internal decorative features of all types
39 Westhall Road, Warlingham, Surrey, CR6 9BJ, United Kingdom
Suppliers of mouldings, both interior and exterior. A huge range of coving cornice, dado and skirting boards available for next deay delivery. Other products range from ceiling roses, columns and pilasters to central heating pipe boxing and many more products.


text:
Dear NH Insider Team,
Does this US economic crisis concern you? We must get the word out about our country's debt before it's too late! Our new documentary uncovers Obama's failing economic policy.
Watch Reagan school Obama in economics!
Join us in the fight against Obama-nomics!
• Watch the "I Want Your Money" teaser trailer: http://bit.ly/iwantyourmoney.
• Sign the Debt-Free America petition: http://bit.ly/debtfreepetition
• Post the Trailer and a link to the Petition on your own websites, blogs, Facebook and Twitter.
If you'd like more information on the film, please visit http://bit.ly/IWYMsite or feel to contact us at: firstname.lastname@example.com.
Thanks for joining our fight to keep America debt-free!
Obama's Economic Catastrophe; Sign the Debt Free Petition!
Dear NH Insider Team,


text:
|06 Sep 2012
Turn back on Microsoft products update?
sorry if this is a really dumb question but i cannot for the life of me figure how to turn this back on.
I accidentally unchecked the 'Give me updates for Microsoft products and check for new optional Microsoft software when I update Windows'
I've searched all over the net but no luck
|My System Specs
|06 Sep 2012
Windows 8.1 Pro x64
Hello Robwan and welcome to the forums
There is no such thing as a dumb question, if you learn something from it then it's quite the opposite
You'll be glad to hear it does have a simple solution though. Open Windows Update and in the panel on the left you will see a few links, click on Change settings. Tick the box that is second from the bottom
|My System Specs
|06 Sep 2012
Hi, thanks for speedy reply
I have posted some images of what i get when attempting this.
Image 1 shows that the option is completely missing, it was there before i opt out.
And on image 2, if i click 'find out more' it just links me to this Microsoft Update
basically telling me how to do normal updates.
I think i had this problem about a year ago, however the 'find out more' actually worked then. you think they've possibly changed something?
Thanks for your help again
|My System Specs
|06 Sep 2012
Hello Robwan,
Not sure what may have happened, but take a look at step 7 in the tutorial below to see if it may be able to help.
Windows Update Settings - Change
Hope this helps,
|My System Specs
|06 Sep 2012
Hi Shawn, thanks for the reply.
I checked my features and Internet Explorer 9 is on, i unchecked and rechecked it, but still no luck :-/
|My System Specs
|06 Sep 2012
When you click on the Find out more link in Windows Update and it takes you to the Microsoft site, does it allow you to check the I ageee box and click on Install?
|My System Specs
|06 Sep 2012
That's the part which i'm not getting, it just looks like this.
it opens in internet explorer then shoves the normal Windows update window in front of me as if it wants me to try and update. I don't get any prompts from explorer asking me to download or unblock anything either.
this is what its linking me to Microsoft Update
|My System Specs
|06 Sep 2012
Odd. Do you have cookies enabled? You usually see that MS site when it's already installed.
What happens when you close Windows Updates, reopen it, and click on "Change settings". Do you have the "Microsoft Update" option available then?
If not, then you might consider using OPTION THREE in the tutorial below to reset Windows Update completely, and try again.
Windows Update - Reset
|My System Specs
|06 Sep 2012
Finally, i got it!
i went to microsoft.com and manually searched for 'microsoft update' i ended up at this page Windows Update - Windows 7 features - Microsoft Windows
installed silverlight and it asked me to turn on microsoft updates and bingo.
slightly odd that i had go out my way and do it like that but it gave me all the options back again
This solution may come in handy if anyone else experiences the same problem.
Thanks for all your help guys!
|My System Specs
|06 Sep 2012
Odd, but I'm happy to hear you got it sorted. Thank you for posting back with your results and solution.
|My System Specs
|Thread Tools
|Similar help and support threads
The top bar for my microsoft 2010 products became too large .
As you can see , the top bar is too big and its getting annoying because Im using a Tablet PC and I can't write properly on the screen because of this issue . Does anyone have a solution to resolve this matter ? Thanks in advance ! :D
|Microsoft Office
Blank Page when when trying to update other microsoft products.
Hi guys, I've been trying to get updates for microsoft office. If I open up Windows Updates and choose " Get updates for other products" It takes me to a blank page at Microsoft Update I have never had this issue in the past. I have last night restored my computer back to factory settings. I...
|Windows Updates & Activation
cannot enable updates for other microsoft products
Hello. I just reinstalled win7 on a asus eeepc 1005pe. I modified the iso with rt7lite and removed some components (like multi-media in IE). I wanted to make it lighter, as this is a pretty crappy PC. Anyhow. I installed, all is working fine. No bugs/problems, except for the fact I cannot...
|Windows Updates & Activation
Windows Update is disabled and will not turn back on
I am using a Windows 7 32 bit computer. My windows update has been disabled and when I try to check for updates I get the 'Windows update cannot currently check for updates, because the service is not running. You may need to restart your computer.' report. Restarting the computer does not work. I...
|Windows Updates & Activation
Google vs. Microsoft Isnt Just a Battle of Products,
Epicenter - Mind Our Tech Business*| Wired.com
How do i report a bad seller of microsoft Products
How do i report a bad seller of microsoft Products? I bought windows 7 professional off Amazon through Razor software Norwich and the Product key has been blocked by Microsoft. I don't want anyone else to recieve bad software conditon was new full pc 1 user 32 bit and 64 bit.:mad:
|Windows Updates & Activation
|Our Sites
|Site Links
|About Us
|Find Us
Windows 7 Forums is an independent web site and has not been authorized, sponsored, or otherwise approved by Microsoft Corporation. "Windows 7" and related materials are trademarks of Microsoft Corp.
© Designer Media Ltd
All times are GMT -5. The time now is 19:32.


text: I'm experiencing this bug in 11.10 with an ATI Mobility Radeon HD 3650. It happens regardless of the number of monitors I have connected (0-1). It's mildly annoying in that it hinders my ability to debug the shutdown process. I had a script that was blocking shutdown. Normally I would be able to read the script name live on the screen while it's being blocked, however with this bug I had to wait to reboot and check the logs. -- You received this bug notification because you are a member of Ubuntu Foundations Bugs, which is subscribed to plymouth in Ubuntu. https://bugs.launchpad.net/bugs/573483 Title: Overlapping text messages in boot screen Status in "plymouth" package in Ubuntu: Confirmed Bug description: During the boot-up process of Ubuntu 10.04, an error message appears on the boot screen (just below the "ubuntu" logo and below the blinking white/red dots). However, another message with instructions on how to proceed appears exactly on top of the error message, making it nearly impossible to read the error message. This bug is about the two messages overlapping. See attached screenshot. This bug occurs both when using the Nvidia proprietary driver, and ALSO when using the free nvidia driver. It seems unrelated to the driver used by X. --- Architecture: i386 DefaultPlymouth: /lib/plymouth/themes/ubuntu-logo/ubuntu-logo.plymouth DistroRelease: Ubuntu 10.04 InstallationMedia: Ubuntu 10.04 LTS "Lucid Lynx" - Release i386 (20100429) MachineType: Dell Inc. Dell XPS420 NonfreeKernelModules: nvidia Package: plymouth 0.8.2-2ubuntu2 PackageArchitecture: i386 ProcCmdLine: BOOT_IMAGE=/vmlinuz-2.6.32-22-generic-pae root=UUID=7e3ac1f6-e465-4673-93a6-79547bfa7d86 ro quiet splash ProcEnviron: PATH=(custom, no user) LANG=en_US.utf8 SHELL=/bin/tcsh ProcFB: 0 VGA16 VGA ProcVersionSignature: Ubuntu 2.6.32-22.36-generic-pae 184.108.40.206+drm33.2 Tags: lucid TextPlymouth: /lib/plymouth/themes/ubuntu-text/ubuntu-text.plymouth Uname: Linux 2.6.32-22-generic-pae i686 UserGroups: dmi.bios.date: 03/27/2008 dmi.bios.vendor: Dell Inc. dmi.bios.version: A04 dmi.board.name: 0TP406 dmi.board.vendor: Dell Inc. dmi.chassis.type: 7 dmi.chassis.vendor: Dell Inc. dmi.modalias: dmi:bvnDellInc.:bvrA04:bd03/27/2008:svnDellInc.:pnDellXPS420:pvr:rvnDellInc.:rn0TP406:rvr:cvnDellInc.:ct7:cvr: dmi.product.name: Dell XPS420 dmi.sys.vendor: Dell Inc. To manage notifications about this bug go to: https://bugs.launchpad.net/ubuntu/+source/plymouth/+bug/573483/+subscriptions


text:
Every former player and current player, critics and fan has something to say about Sachin Tendulkar. Here are some of the quotes by legendary players on the Little Master.
I saw him playing on television and was struck by his technique, so I asked my wife to come look at him. Now I never saw myself play, but I feel that this player is playing much the same as I used to play, and she looked at him on Television and said yes, there is a similarity between the two... his compactness, technique, stroke production... it all seemed to gel: Sir Donald Bradman. In terms of technique and compactness, Tendulkar is the best: Desmond Haynes. I have watched a lot of Tendulkar and we have spoken to each other a lot. He has it in him to be among the very best: Sir Garfield Sobers. He is 99.5 per cent perfect. I'd pay to see him: Sir Viv Richards. Technically he stands out as the best because of his ability to increase the pace at will: David Boon. There is no shame being beaten by such a great player, Sachin is perhaps only next to the Don: Steve Waugh. Sachin is cricket's God: Barry Richards. India's fortune will depend on how many runs the little champion scores. There is no doubt Tendulkar is the real thing: Sunil Gavaskar. A complete batsman. He's the best in the business: Mohinder Amarnath. Sachin is an attacker. He has much more power than Sunny. He wants to be the one to set the pace. He has to be on top. That's the buzz about him: Jeff Thompson. If I've to bowl to Sachin, I'll bowl with my helmet on. He hits the ball so hard: Dennis Lillee. You take Don Bradman away and he is next up I reckon: Steve Waugh. I'll be going to bed having nightmares of Sachin just running down the wicket and belting me back over the head for six. He was unstoppable. I don't think anyone, apart from Don Bradman, is in the same class as Sachin Tendulkar. He is just an amazing player: Shane Warne. When it comes to judging the best among these fabulous band of batsmen, my vote goes to Tendulkar. He has an uncanny ability to come out on top under different circumstances and under different conditions, whether it is Test cricket or one-day internationals. And more importantly, he has done this so young: Shane Warne. Don't bowl him bad balls, he hits the good ones for fours: Michael Kasprowicz. Hell, if he had stayed, even at 11 an over he would have got it: Allan Border (after India won the Coca-Cola cup in Sharjah). He is a perfectly balanced batsman and knows perfectly well when to attack and when to play defensive cricket. He has developed the ability to treat bowlers all over the world with contempt and can destroy any attack with utmost ease: Greg Chappell. It's scary, where the hell do we bowl to him: Allan Border. Yeah mate, but that's with all great players: Ian Chappell. I'd like to see him go out and bat one day with a stump. I tell you he'd do okay: Greg Chappell. Sachin's better; Lara is more risky outside the off stump: Mark Waugh. You have to decide for yourself whether you're bowling well or not. He's going to hit you for fours and sixes anyway. Kasprowicz has a superior story. During the Bangalore Test, frustrated, he went to Dennis Lillee and asked, "Mate, do you see any weaknesses?" Lillee replied, "No Michael, as long as you walk off with your pride that's all you can do: Shane Warne. He's a phenomenon. We have to be switched on when he plays allow him no boundries, for then he doesn't stop: Mark Taylor. Tendulkar is the most complete batsman I have stood behind. I saw the hundred in Perth on a bouncy pitch with Hughes, McDermott and Whitney gunning for him he only had 60-odd when No 11 came in. I've seen him against Warne too: Ian Healy. Harder he works, the luckier he gets: Ian Chappell. He has defined cricket in his fabulous, impeccable manner. He is to batting what Shane Warne is to bowling: Richie Benaud. Sachin's the best. I've had this view since I saw him score that hundred in Sydney in 1992. He's the most composed batsman I've ever seen: Mike Coward. He's better than Ben Hur: Paul Wilson. The pressure on me is nothing as compared to Sachin Tendulkar. Sachin, like God, must never fail. The crowd always expects him to succeed and it is too much pressure on him: Mark Waugh. I still think Tendulkar is the best batsmen in the world ahead of Steve Waugh and Lara: Glenn McGrath. He is currently the best batsman in the world: Sir Gary Sobers. There's no doubt about it. He is the best: Tony Grieg. Technically, you can't fault Sachin. Seam or spin, fast or slow nothing is a problem: Geoffrey Boycott. Sometime back I had written a piece that said that Sachin's the master and Lara a genius with his head high up somewhere. That's it: Peter Roebuck. A little genius. Reminds me of Sunny Gavaskar: Kieth Fletcher. He is Sachin Tendulkar. I hope he stays Sachin Tendulkar. We need a new player, a player in his own way. He has a technique which is the hallmark of a great player. Everything indicates that he will be a great player and I am sure he will prove me right. Reminds me of Barry Richards: Eddie Barlow. Destined to be a great: Barry Richards. What we (Zimbabwe) need is 10 Tendulkars: Paul Strang.
Topics : Cricket
Get the latest Sri Lanka vs India 2017 news, check Sri Lanka vs India 2017 schedule and live score. Like us on Facebook or follow us on Twitter for more Sri Lanka vs India 2017 updates. You can also download the NDTV Cricket app for Android or iOS
Show Comments


text:
We were in the process of emigrating so we had a lot of luggage. The staff were very kind and allowed us to store this luggage on the day of check in and also the day of check out.
Easy walking distance from shops and restaurants! Great having own kitchen would cut down cost of a more longer stay would definitely stay there again!
All the aspects of this accommodation were excellent! The apartment is located in the middle of the town center and is minutes away from York Minster and all the main attractions! Made our stay in York unforgettable!
Everything about this apartment was brilliant. From the decor to the comfy bed. The location was within walking distance to all the pubs and restaurants and was also very clean. Great value for money,
The Minster apartment was very clean and being on the ground floor even better plus located in the town so everything to hand . Staff were very helpful and friendly it has everything you need including cleaning products the only downside was the bed being very hard and the shower head you could not adjust to a suitable height and no shower slip mat so very dangerous as it is a deep bath. .. The chairs were also uncomfortable as needed after all the walking you do…. Please do not be put off by these things as on a whole it is a lovely place just needs a few bits sorting out and it will be the best apartment in york and we will be back and as a added bonus the price was excellent so happy days
Right by the city walls, great location near to the restaurants (and a Tescos!) Smart yet comfortable, well kitted out for our needs.
The apartment itself was lovely I couldn't fault it at all, but the sound from people in the apartments above was very noisy you could hear what the people were saying never mind the loud music. They definitely should have carpets to absorb noise not wooden floors !!!
Excellent location, friendly staff, monks loft not huge but very well set out with everything you need, kitchen even had a dishwasher, lovely and clean. Excellent bathroom with both a bath and shower. It is just a couple of minutes away shops and pubs, but is just behind main road meaning it is still nice and quiet.
Lovely clean, modern apartment in a great location. Handy for restaurants, bars and shops and only a short walk away from the Minster and the Shambles. We arrived in the morning and were able to leave our luggage and again could do so on leaving. Would definitely stop here again.
Great location, well furnished, very clean, good facilities. Friendly and helpful staff – easy check in and check out. Very happy and helpful with our enquiries. Comprehensive guest book. Overall, a very happy stay. Definitely recommend.
Apartment was very clean, nicely decorated and fully equipped. It was centrally located and easy to find. Good value for money.
We were given a large apartment which comprised a master bedroom, a kitchenette, large bathroom and a living room that doubled up as a bedroom with two single sofa beds. The location wasn't easy to find at first but the proprietor gave us clear instructions and once we were there, we realised what a gem of a location this was. Only a 5 min walk to York Minster and Shambles. That is as central as central gets! Now, about the apartment, this was possibly the most well-equipped holiday apartment I've ever stayed in. Forget the usual stuff, wifi, towels, tv… that's not hard to do. But for family use, they also had plates, cutleries, a fridge, dishwashing liquid, sponge, microwave… and believe me, that made all the difference. You see, we tend to takeout and eat in… it firstly saves some money and secondly it's nice to be able to eat in at a home away from home where we can just relax and be ourselves. So their plates and cutleries, glasses and utensils all came in handy. Coming to the toilet, they provided high quality shower gel, shampoo, and all sorts of accoutrements that give it a touch of poshness. We really enjoyed our stay and next time, we'll stay for more than just one day. Amazing place, and I highly recommend it. You won't regret it.
The apartments were lovely, and in a fantastic position within walking distance of everywhere we wanted to go in town. The staff were lovely on arrival, and as one of the apartments was ready (we had booked three) allowed us to check in early and use that apartment to leave our luggage, which was much better than dragging them around town!
Great location and lovely clean spacious apartments. Couldnt fault anything…except the rain hahha;-) Will defo be back. Thankyou
Fantastic location. You do have to pay for parking nearby but everything is within walking distance including supermarket.
The apartment was very clean and tidy.and was equipped with everything needed for a busy family.would defiantly stay again
the apartment had everything you need even down to teabags, coffee,sugar,milk,shampoo,shower-gel,washing-up-liq ect, all you really need for a few days stay is your clothes. nice lay out, very compact and modern.


text:
Get notified when new sales are live
Subscribe to our notifications so you don't miss out on our new sales!
Billabong Men's Low Down Splice Thong - Blue / Black
Billabong Men's Low Down Splice Thong
Just $9.99 for an Aussie wardrobe essential!
Durable footwear for the beach or street!
Available in men's sizes - see size chart for correct fit!
Designing for beach lovers everywhere, Aussie label Billabong effortlessly blends on-the-minute trends with quality materials. Famous for their surf and skatewear, young, vibrant styling is what this brand is all about. Surf's up!
- Billabong Thongs
- Style: Low Down
- Colour: Blue/ black
- Men's sizing
- Soft and bouncy
- Flexible and durable
- Footwear for the beach or the street


text:
Conversion of ALBM Photo albums to JPG image. ALBM to JPG converters.
It might be possible that individual pictures from photo albums (*.albm) can be extracted and exported to a JPEG file. However, because so many programs used or are still using *.albm files it is not clear whenever this is really possible.
Unfortunately, there is no detailed software record in the database for this conversion.
Additional links: albm file extension details, jpg file extension details
Back to conversion search


text:
Pumpkin-Pecan Squares
READY IN: 1hr 45mins
Recipe by Steve_G
A layer of pumpkin filling is in between a buttery crust and nutty topping.
Top Tweak by PAULAJEAN
This was good. It tasted like pumpkin pie. The 26 step instructions made it very confusing and difficult to follow. I got so lost I ended up opening a can of sweetened condensed milk instead of evaporated milk. After I realized my mistake I left out the addition of sugar to even out the sweetness of the milk and it turned out pretty good.
Ingredients Nutrition
For the pastry
- 18 tablespoons unsalted butter, at a cool room temperature (2 sticks plus 2 tb, 255 gms)
- 3⁄4 cup light brown sugar, firmly packed (165 gms)
- 1⁄2 teaspoon pure vanilla extract
- 1⁄2 teaspoon salt
- 2 cups unbleached all-purpose flour (290 gms)
- 1 cup cake flour (145 gms)
For the filling
- 1 (15 ounce) can pumpkin puree
- 1 (12 ounce) can evaporated milk
- 3⁄4 cup sugar (150g gms)
- 2 eggs (100 gms)
- 2 egg yolks
- 1 teaspoon ground cinnamon
- 1⁄2 teaspoon salt
- 1⁄2 teaspoon ground ginger
- 1⁄4 teaspoon ground cloves
- 1⁄4 teaspoon ground nutmeg
- 1⁄2 teaspoon pure vanilla extract
For the Topping
- 1 cup packed light brown sugar (217 gms)
- 1 cup chopped toasted pecans or 1 cup walnuts (4-6 oz)
- 1⁄4 cup demerara sugar
- 1 cup whipping cream
- 1 tablespoon sugar
- 1 dash pure vanilla extract
Directions See How It's Made
- Optional- substitute 2 1/4 tsp pumpkin pie spice in lieu of the cinnamon, ginger, nutmeg and cloves.
- Optional- substitute 3 cups (435 gms) of bleached all-purpose flour for the unbleached& cake flours.
- Line a 9x13 aluminum baking pan with heavy duty foil.
- Leave 2-3 inches of foil sticking out of the pan on the short sides to aid in lifting the finished product out of the pan.
- FOR THE PASTRY: In a small bowl or plastic bag measure and mix flours and salt.
- In the bowl of an electric mixer fitted with the paddle attachment (can be done with a hand mixer), mix the butter, vanilla extract and sugar on medium speed until light and fluffy, about 2 minutes.
- Add flours 1 cup at a time, on medium speed, mixing until fully incorporated after each addition.
- Continue mixing until the dough begins to come together in large clumps.
- Press dough into prepared pan about 1/4-inch thick.
- Prick the pastry with the tines of a fork or a wooden skewer.
- Chill until firm, about 20 minutes.
- While the pastry is resting, Place rack in center of oven.
- Preheat to 375 degrees F.
- Spread nuts on a cookie sheet and roast for 5-10 minutes, unitl hot and aromatic (do not burn them!) Allow to cool Bake pastry until golden brown, 18 to 20 minutes.
- Lower oven temp to 350 degrees.
- FOR THE FILLING: Mix spices, salt and sugar in a small bowl, whisk to combine.
- Whisk pumpkin, eggs, yolks, extract, evaporated milk in a large bowl until smooth.
- Slowly add sugar/spice mix and beat until well combined.
- Pour over HOT crust.
- Bake for an additional 20 minutes or until just set and still jiggles in the center.
- FOR THE TOPPING: Combine topping ingredients, when filling has set remove bars from oven and evenly sprinkle topping over filling.
- Bake for 20-30 minutes, you just want the topping to be browned and about 1/2 melted The filling may start to crack and get a bit puffy.
- Cool on a wire rack for several hours, refrigerate overnight, remove from pan, cut into 24 squares, sprinkle sugar on bars.
- Keep in refigerator until ready to serve with a dollup of slightly sweetened whipped cream.


text:
Welcome to WebmasterWorld Guest from 22.214.171.124
Forum Moderators: lawman
We have decided to break down the responsibilities by the Categories listed on the home page.
RCJordan : The Webmaster World
Littleman : The SEO World (you were just drafted)
Marcia : The Local Forums
NFFC : The Search Engine World
That gives us room for growth and keeps us from trying to do the same task at the same time.
Thank you Marcia and Littleman for contributing.
Thanks so much for the encouragement and the kindness. Being part of this community is cherished, and it's a privilege to be able to contribute whatever I can.


text:
Color Choices
Posts - 31 ProShield Choices
Clamps - 31 ProShield Choices
Components - 31 ProShield Choices
Polyethylene - 11 Choices
Permalene - 14 Choices
TenderTuff - 2 Choices
Color is an important decision, and our playgrounds are available in many color options. Use our carefully curated palettes like Color Palette AV shown above, or work with our design team to create your own color combination. Contact your local playground consultant to learn more.See more color palettes
Product Lines
Project Price Range
*Custom prices vary. For international and exact pricing, please contact your local playground consultant.
Age Ranges
- 2 to 5 Years
Design Standards
Min Area Required
Max Fall Height
A Wild West theme captures the attention of all who visit the Folsom Park playground in Folsom, California. Created in partnership with Shane's Inspiration, this inclusive playground welcomes kids of all abilities. Now all children ages 2 to 5 can board the covered wagon, pull up to the Stagecoach Depot and play with the interactive train panel, shop the General Store and check in at the Hotel. Not only is this playground unique, but it sparks young imaginations with creative play ideas.
Product Lines Featured in this Playground
Ages 5 to 12 Years
The PlayBooster® playground structure, the original post-and-clamp system, combines exciting ground-level components with climbing events and overhead activities for kids ages 5 to 12. The PlayBooster family includes the interconnected cables of Netplex®, the contemporary Vibe®, the nature-inspired Tree House and the double-decker PlayOdyssey® Tower.
Related Links
Freestanding Play
Ages 2 to 12
Freestanding Play events add fun and excitement to new and existing playgrounds! Revitalize your current playground or create a playground design that's completely unique using Freestanding Play components for kids ages 2 to 5 and 5 to 12.
Related Links
We can help you create playground designs unique to your community! Everything in our custom design process is driven by your goals and ideas. Together, we'll create a destination playground that's as individual as your imagination!
Related Links
Proud to partner with our playground consultant covering California (All counties except Kern, Imperial, Los Angeles, Orange, Riverside, San Bernardino, San Diego, San Luis Obispo, Santa Barbara and Ventura). Congratulations to Ross Recreation, Landscape Structures' 2015 Rep of the Year!
Ross Recreation Equipment Company, Inc.
100 Brush Creek Rd
Suite 206
Santa Rosa, CA 95404
Phone 707-538-3800


text: To get from Arcore to San Cataldo by train you can catch one of the 3 trains that everyday travel between these two cities. The first train to San Cataldo leaves from Arcore at 07:34 and the last train departs at 17:14. If you choose a local train the trip lasts on average 07:01 hours. For your trip from Arcore to San Cataldo by train you can choose to leave from one of Arcore main stations: Arcore On Wanderio you can compare all schedules, fares and railway companies to San Cataldo and book the best itinerary starting from Arcore.


text:
This website and all its contents, including text, images and animations, databases, programs, etc.., is protected by copyright. Pursuant to Article L. 122-4 of the French Intellectual Property, it is prohibited to reproduce, copy, modify, transmit, distribute in any way whatsoever, even partially, on any media type, any element from this site (for example, but not limited to: text, logos, images, sounds, videos, software, icons) without the explicit prior consent of CynSIS SAS. Any reproduction, representation or authorized use of a constituent element of the website must display the following acknowledgment: © CynSIS 2015 All rights reserved.
Pursuant to Article L.122- 5, first paragraph, of the Code of Intellectual Property, the reproduction of a part of this site for personal and private use is authorized.
CynSIS SAS is the sole recipient of any personal information that you provide them. Accordance with the Data Protection Act of 6 January 1978 modified, you have the right to access and rectify information concerning you by writing to the address mentioned in the contact section.
Headquarters: Espaces Antipolis, 300 route des crêtes, 06560 Valbonne Sophia Antipolis
RCS Grasse n° 794 791 749, code APE 6201Z
Phone : +336 75 06 84 91
Publishing Director: Pierre-Marie Sarant
Site hosted by OVH SAS Headquarters: 2 rue Kellermann - 59100 Roubaix - France.


text:
We help you find a Marianglas harmonica tutor. Harmonica lessons are the perfect way to learn an entertaining new hobby, pick up a new talent and attain confidence in harmonica. Use our service to search for Marianglas harmonica teachers and select which matches your requirements so you can start your harmonica lessons in Marianglas today!
This is the best way to find Marianglas harmonica teachers in the UK, helping you find Marianglas harmonica tuition close to home and Marianglas teachers to help with any instrument such as piano, violin or guitar. We can help you find Marianglas harmonica lessons or a one-to-one Marianglas harmonica tutor to prepare for harmonica exams and develop your harmonica skills! We order Marianglas harmonica teachers local to you by their lesson charges and distance from you.
If you are a harmonica teacher and would like to offer your harmonica tuition services in Marianglas or throughout the UK, please register with First Tutors: Music or find out more about us here. Becoming a Marianglas harmonica tutor is a fantastic way to re-affirm your own knowledge by providing harmonica tuition while helping someone else, all in the Marianglas area!


text: The Frozen Lands used to be the site of the southern icecap. However, this icecap melted, due to the impacts of both industry and the Siberian Traps eruptions, and this state of melting is well underway at the beginning of the eruptions. Thus, by the time covered by most of the Permian Extinction: Civilization timeline, the name is actually a misnomer (for the most part), and the land might more accurately be called the Lakelands, for all of the lakes filling holes due to melting permafrost.


text: The SAEA champions innovative educational approaches for sustainable agriculture through the development, application, and research of teaching and learning practices.The SAEA exists to serve and connect educators, teachers, students, staff, and administrators who focus on the teaching and learning of sustainable agriculture at the adult level.Our activities include hosting participatory conferences, collecting sustainable agriculture educational program listings, and developing a digital curriculum library.We are driven by volunteers who firmly believe in sustainable agriculture – for now and into the future. We invite you to join us! Field LessonsSteering Council HighlightJanuary 25, 2017Jennifer Blesh: Member RepresentativeA member of the SAEA since it was founded, Jennifer Blesh is thrilled to be back on …Read More »Follow up from Joanna Ory's presentation at the 2016 SAEA ConferenceOctober 8, 2016During the 2016 Sustainable Agriculture Education Association Conference, I presented preliminary findings from the Organic Farming Research Foundation (OFRF) report, …Read More »Field Lessons from: Leelanau ConservancyMarch 15, 2016Our agricultural landscape is in a time of transition. The average age of established farmers in the United States is …Read More »Twitter MEMBERSHIP DRIVE kicks off this month! First 50 new and renewing members get an organic tote bag as a thank you.... https://t.co/Wd7uyFZPAP, Apr 6Ready to get your hands dirty? There are just a few spots left with #RogueFarmCorps for the 2017 season!... https://t.co/TkSQj2O59S, Mar 13Looking for an opportunity to join a team of ecological researchers and technicians to uncover how agriculture is... https://t.co/LcDs1GAjh5, Feb 23 Follow @SustainableAgEd Our ProjectsAcademic Degree Program Listings- Search for Bachelor, Masters, and PhD programs in Sustainable Agriculture Student Farm & Garden Listings- Find institutions with Student Farms and Gardens Curriculum Library- Soon you will be able to share syllabi, degree program documentation, lab and field exercises and assignments Join the SAEA Steering Council and help us move our work forward. Nominations are now being accepted for open positions on SAEA's Steering Council. Read more about it and get on board- Share your expertise with the SAEA!Join Us! 2016 Conference7th SAEA National Conference Looking for conference proceedings from this past summer at UC Santa Cruz?Check out the links below to view our notes, videos and evaluations. Conference VideosOpen Space NotesEvaluation Results Follow Us


text:
Stores »
go keg-o-rator! now you can drink your cheep beer cold at your dorm parties...well worth the investment.
You have your pint glasses so now you can properly serve an honest-to-goodness Irish stout. The Guinness family has been brewing Ireland's most popular beer since the 1700's. That's a pretty good track record.
We are a community of shoppers sharing our best finds from across the web.
© 2017 ThisNext, Inc. ThisNext is a member of BUZZMEDIA Entertainment, a division of BUZZMEDIA.


text:
Sign In
Shop Ink
Search Millions of Items...
Sign In
Shop Ink
Pickup today,
Out of stock online
Available online only
Out of stock online
Available in-store only
Free Shipping
Skill Builders are great tools for keeping children current during the school year or preparing them for the next grade level.
Carson-Dellosa™ "Multiplication and Division" Resource book for grades 4 - 5 offers additional skill practice and basic skills. Full color book with 80 pages is ideal for improving basic skills of new learners that leads them towards progress.
Media FormatPrinted Book
School GradeElementary
Education Subject MatterMath
The product was not found. Please verify the sku and try again.


text: Frank G September 22, 2010 3:52 AM Last Edited 2497 days ago I personally would love to see RB and the Williams team make it to the podium this season! I think they deserve it for all there hard work and for running a Cosworth engine in it's first year back to the sport. Reply Report abuse 2 agree 1 disagree


text:
Tell us your story
If you met someone wonderful through eHarmony, we'd love to hear your news
Get started now. Simply fill out this form and take the questionnaire to receive your matches.
Karen & Matt
Eventually though I told him that I could only spend the rest of my life with him...
Scott & Sarah
Colwyn Bay
Sarah really has filled a big void in my life with her love, personality and humour...
Emily & Rob
It seems I was unable to choose the right person for myself but eHarmony did it in a month...
Dave & Judi
There was no doubt in my mind from the very first time that we met...
Sue & Steven
We are planning to marry later this year, exactly one year from the day we met....


text:
Compare MetLife vs. Trusted Choice Inc. Landlord Insurance
What's the difference between MetLife Landlord Insurance and Trusted Choice Inc. Landlord Insurance? See how our editors compare the two companies below.
Select 2 landlord insurance companies to compare
#4 in Landlord Insurance
Key Facts
- Rental property coverage
- Liability coverage
- Multiple structures
- Covers private structures
- Coverage for medical payment
- Legal fees coverage
- Umbrella liability
- National disaster coverage
- Covers loss of rent
- Rental business insurance
Final Verdict
Trusted Choice Inc. Landlord Insurance has a higher overall rating than MetLife Landlord Insurance. Trusted Choice Inc. scores better than MetLife across: Coverage, Premiums, and Discounts. However, MetLife scores better on Structures Covered, and Customer Support. Both companies score similarly on Benefits.


text:
I've been looking everywhere for a decite website that teaches Cantonese. So far I haven't found a single one!! I really want to learn and I was hoping that this site might have some Cantonese but it appears that there's only Mandarin here. I would become a huge fan of this site if there were a weekly Cantonese series teaching the basics/fundementals along with Cantonese-style pinyin. In fact, I would probably become a subscriber to this site just for that alone.
Not sure if your comment is appropriate? Check our Commenting Policy first.
New lesson idea? Please contact us.


text:
Dr. Thomas J Maronick
Maronick Associates
Towson , MD 21252
Fax: 410-532-2904
Thomas J. Maronick, DBA, JD, is a federal and state court-qualified expert in consumer behavior, marketing, advertising, and Lanham Act matters. Also an expert in survey research, including on-line survey methods. Conducted over 350 consumer surveys related to advertising, marketing practices, trademark and trade dress issues for plaintiff and defendant clients on subjects as diverse as advertising claims, packaging, telecommunications, insurance/annuities, software marketing,internet domain names, trademark and trade dress. Former in-house marketing expert for the Bureau of Consumer Protection, Federal Trade Commission.
Dr. Maronick has a DBA in Marketing from the University of Kentucky and a JD from the University of Baltimore School of Law. He is an inactive member of the Maryland Bar. He is currently a Professor of Marketing at Towson University in Baltimore where he has taught and published in the areas of marketing research, marketing strategy, and public policy for over twenty years. He is also on the Editorial Review Board of the Journal of Consumer Affairs, the Journal of Marketing and Public Policy, and International Marketing Review. His publications include articles on research in litigation, environmental claims in advertising, consumer perceptions of country of origin claims, and the use of on-line surveys in advertising and trademark litigation.
For more information see www.adexpert.net.
Areas of Expertise
- Advertising
- Marketing
- Public Opinion & Survey Research
- Trademarks
Expert Background
- Q: Please list your professional accreditations, degrees, licenses, and certificates granted:
- A: BA- Philisophy
St. Thomas Seminary, Kenmore, WA (1964)
MSBA - Marketing
University of Denver (1966)
DBA - Marketing
University of Kentucky, Lexington, KY (1974)
JD - University of Baltimore, Baltimore, MD (1980)
Maryland Bar (1980)
- Q: Please list your affiliations or memberships in any professional and/or industry organizations:
- A: American Marketing Association
Association for Consumer Research
Decision Sciences Institute
Academy of Marketing Science
Global Business and Technology Association
Public Policy and Marketng Association
Maryland Bar Association
- Q: Please list any teaching or speaking experience you have had, including subject matter:
- A: Teaching: Marketing Research
Advertising Research
Marketing Strategy
Senior Seminar
Marketing & Policy Seminar (grad)
Marketing Communication Strategy (grad)
Head, Office of Impact Evaluaiton
Bureau of Consumer Protection
Federal Trade Commission
Washington, DC (1980-1997)
- Q: Have any of your accreditations ever been investigated, suspended or removed? (if yes, explain)
- A: Never. My degrees can be verified by contacting the universities I have attended.
My FTC experience can be verified by contacting the Bureau of Consumer Protection at the FTC.
My teaching experience can be verifed by contacting the universities.
- Q: On how many occasions have you been retained as an expert?
- A: In-house marketing expert for Bureau of Consumer Protection at the FTC for 16+ years
Retained as expert over 60 times since leaving FTC
- Q: For what area(s) of expertise have you been retained as an expert?
- A: Marketing, Advertising, Retailing, Pricing, Marketing of Insurance & Investments, Software Marketing, Travel Promotion, Telecommunications, Internet Marketing, Direct Marketing, Dietary Supplements, Senior Citizens,Trademarks/Tradedress
- Q: In what percentage of your cases were you retained by the plaintiff?
- Q: In what percentage of your cases were you retained by the defendant?
- Q: On how many occasions have you had your deposition taken?
- A: over 50 in past six years
- Q: When was the last time you had your deposition taken?
- A: January,2013. I was deposed 10 times in 2012.
- Q: On how many occasions have you been qualified by a court to give expert testimony?
- A: I have been qualified as an expert in court on 10 occassions. My declarations have been accepted by the Court in all instances where submitted.
- Q: On how many occasions have you testified as an expert in court or before an arbitrator?
- A: Seven-eight
- Q: For how many years have you worked with the legal industry as an expert?
- A: Forty, including 16+ years as the FTC's in-house marketing expert and 25 years since leaving the Commission in 1997.
- Q: What services do you offer? (E.g.: consulting, testing, reports, site inspections etc.)
- A: Consulting, survey research, analysis of advertising and advertising research, reports, testimony (deposition, trial, arbitration).
- Q: What is your hourly rate to consult with an attorney?
- A: Contact me to discuss rates.
- Q: What is your hourly rate to review documents?
- A: Contact me to discuss rates.
- Q: What is your hourly rate to provide deposition testimony?
- A: My rate for testimony is the same as for consulting (after being retained) and for review of documents.
- Q: What is your hourly rate to provide testimony at trial?
- A: My rate is the same for any testimony (deposition, trial, hearing).
- Q: Please list any fees other than those stated above (E.g.: travel expenses, copy fees, etc.)
- A: Travel expenses at 1/2 of consulting/testimony rate. Expenses are as incurred.
Deborah Lodge
Patton Boggs
Washington, DC
(202) 457-6030
Tommy O'Reardon
Blood Hurst & O'Reardon
San Diego, CA
Patty Syverson
Bonnett Fairbourn
Phoenix, AZ
(602) 776-5925