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A comparative Analysis
Within only a few weeks in the first half of 2010, two last-instance opinions on the connotations of patent eligible subject-matter and the tests to be applied for distinguishing such matter from other material have been delivered on both sides of the Atlantic.
The Supreme Court of the United States in Bilski v. Kappos, No. 08-964, 561 U.S. (2010) had to deal with the issues of whether "a 'process' must be tied to a particular machine or apparatus, or transform a particular article into a different state or thing ('machine-or-transformation' test) to be eligible for patenting under 35 U.S.C.§101" and whether such test "which effectively forecloses meaningful patent protection to many business methods, contradicts the clear Congressional intent that patents protect 'method[s] of doing or conducting business', 35 U.S.C.§273" (Questions presented).
The points of law referred by the President of the European Patent Office in G 3/08 "Programs for computers" of 12 May 2010 to the Enlarged Board of Appeal were limited to "some of the finer aspects" of the exclusion of programs for computers (Press Release of 24 October 2008 on the EPO Website). Nevertheless, at least points 2 and 3 referred overlapped with the first question presented to the U.S. Supreme Court in that the sufficiency of merely mentioning the use of a computer or a computer-readable data storage medium for avoiding exclusion in the area of computer programs was challenged. This issue was indeed also raised and discussed before the U.S. Supreme Court (Transcript of oral argument, p. 33 ff.).
Both cases aroused high-wrought expectations of final clarifications. At first sight, those expectations may not have been met since the Enlarged Board of Appeal found the referral inadmissible and the U.S. Supreme Court contented itself with finding that the machine-or-transformation test is not the sole test for deciding whether an invention is a patent-eligible process (Part II-B-1, p. 8) and that business methods are not categorically excluded from patentability (Part II-C-1, p. 10). Any further development of judicial interpretation was thus left to "lower" instances, i.e. the Court of Appeals for the Federal Circuit and the Boards of Appeal of the EPO (in fact, the Enlarged Board of Appeal is not an instance above the Boards of Appeal but rather coordinate to the Boards). Nevertheless, despite some similarities the resulting status quo of jurisprudence seems to be fundamentally different in both legal systems.
1. Impact of G 3/08
1.1 In G 3/08 the Enlarged Board of Appeal decided that the President's referral was inadmissible under Article 112(1) (b) EPC since there were no different – in the sense of "conflicting" (G 3/08, Nos. 7.2.5, 7.3.1) – decisions on the questions referred. This finding has two immediate consequences:
(Ι) There is no necessity or even possibility for the Enlarged Board of Appeal to enter into a discussion of any merits or demerits of the established case law, all the more so since the legal development is on the hands of the Boards of Appeal and is neither the Enlarged Board´s nor the President's responsibility (Ibid., No. 7.3.8).
(ΙΙ) The status quo of European case law must be considered to be firmly established. Although the Enlarged Board mentions that a "rejection for lack of an inventive step rather than exclusion under Article 52(2) EPC is in some way distasteful to many people" (Ibid., No. 10.13), it refers several times (Ibid., Nos. 4.1, 10.7.1, 10.13.1, 10.13.2) to decision T 154/04-3.5.01 "Estimating sales activity/Duns Licensing Associates" of 15 November 2006 (OJ EPO 2008, 46). As laid out in this decision, an elaborate system for taking excluded subject-matter into account in the assessment of whether there is an inventive step has been developed. While it was not the task of the Enlarged Board in its Opinion to judge whether this system was correct, it appeared to the Enlarged Board "that the case law, as summarised in T 154/04, has created a practicable system for delimiting the innovations for which a patent may be granted".
1.2 Hence, the legal situation of computer-implemented inventions in Europe, at least as regards the central grant proceedings before the EPO, has in the end been decided to be on solid ground. As pointed out in T 154/04, No. 5, the constant jurisprudence of the Boards of Appeal may be summarised in the following principles:
(A) Article 52(1) EPC sets out four requirements to be fulfilled by a patentable invention: there must be an invention, and if there is an invention, it must satisfy the requirements of novelty, inventive step, and industrial applicability.
(B) Having technical character is an implicit requisite of an "invention" within the meaning of Article 52(1) EPC (requirement of "technicality").
(C) Article 52(2) EPC does not exclude from patentability any subject matter or activity having technical character, even if it is related to the items listed in this provision since these items are only excluded "as such" (Article 52(3) EPC).
(D) The four requirements of invention, novelty, inventive step, and susceptibility of industrial application are essentially separate and independent criteria of patentability, which may give rise to concurrent objections. Novelty, in particular, is not a requisite of an invention within the meaning of Article 52(1) EPC, but a separate requirement of patentability.
(E) For examining patentability of an invention in respect of a claim, the claim must be construed to determine the technical features of the invention, i.e. the features which contribute to the technical character of the invention.
(F) It is legitimate to have a mix of technical and "non-technical" features appearing in a claim, in which the non-technical features may even form a dominating part of the claimed subject matter. Novelty and inventive step, however, can be based only on technical features, which thus have to be clearly defined in the claim. Non-technical features, to the extent that they do not interact with the technical subject matter of the claim for solving a technical problem, i.e. non-technical features "as such", do not provide a technical contribution to the prior art and are thus ignored in assessing novelty and inventive step.
(G) For the purpose of the problem-and-solution approach, the problem must be a technical problem which the skilled person in the particular technical field might be asked to solve at the relevant priority date. The technical problem may be formulated using an aim to be achieved in a non-technical field, and which is thus not part of the technical contribution provided by the invention to the prior art. This may be done in particular to define a constraint that has to be met (even if the aim stems from an a posteriori knowledge of the invention).
The requirement of technical character is not met by "purely abstract concepts devoid of any technical implications" whereas technical character is implied by the features of a technical product or activity, or is conferred to a non-technical activity by the use of technical means (T 258/03 "Auction method/HITACHI" of 21 April 2004; OJ EPO, No. 4.5; see also T 154/04, Nos. 18 – 22). These principles are applicable for assessing the patentability of any subject-matter claimed.
1.3 In the field of business methods, this means
- that abstract business or financial concepts are not patent-eligible subject-matter, but
- that such concepts become (at least in principle) patent-eligible if they employ a technical means, e.g. if they are tied to a standard computer.
Whether they get over the second hurdle of inventive step depends on the obviousness of the combination of those features that contribute to the requisite technical character. As experience shows, business methods will not easily overcome this hurdle since they regularly amount to nothing more than the straightforward automation of a (possibly innovative) non-technical economic concept. However, applying principle (C) above, it cannot be excluded once and for all that business aspects might also contribute to the technical character and would therefore have to be taken into account when assessing inventive step (see also T 258/03, No. 5.8). Business methods will therefore only be patentable if they are tied to technical means and if those of their features that make a technical contribution involve an inventive step.
1.4 The Enlarged Board of Appeal did its best to foster harmonisation with national case law of the Contracting States by inviting two high-ranking national judges to the bench and citing various national decisions in its opinion. Whether this captatio benevolentiae will contribute to a favourable reception throughout Europe remains to be seen. It appears that recent decisions in Germany (see e.g. BGH X ZB 22/07 - Steuerungseinrichtung für Untersuchungsmodalitäten of 20 January 2009; Xa ZB 20/08 - Dynamische Dokumentengenerierung of 22 April 2010) are approaching the European position while the UK (at least up to now) follows a different line of argument (see e.g. [2008] EWCA Civ 1066- Symbian Ltd. v. Comptroller General of Patents of 8 October 2008).
2. Bilski and its ramifications
2.1 Before the Supreme Court of the United States, three arguments were advanced for the proposition that the claimed invention (a procedure of hedging against the risk of price fluctuations) was outside the scope of patent law:
(Ι) it was not tied to a machine and did not transform an article;
(Ι) it involved a method of conducting business; and
(ΙΙΙ) it was merely an abstract idea.
2.2 According to the majority opinion of the U.S. Supreme Court, adopting the machine-or transformation test as the sole test for what constitutes a "process" violates statutory interpretation principles, in particular the principles of interpreting words as taking their ordinary, contemporary, common meaning and refraining from imposing limitations that were inconsistent with the text and the statute's purpose and design. Any suggestion in the U.S. Supreme Court's case law that the Patent Act's terms deviated from their ordinary meaning had only been an explanation for the exceptions of laws of nature, physical phenomena and abstract ideas which were not patentable. Concerns about attempts to call any form of human activity a "process" could be met by making sure the claim fulfilled the requirements referred to in 35 U.S.C.§101, including novelty, non-obviousness and full disclosure.
2.3 Section 101 similarly precluded the broad contention that the term "process" categorically excluded business methods. The term "method", which was within §100(b)'s definition of "process", might include at least some methods of doing business. The U.S. Supreme Court was unaware of any argument that the ordinary, contemporary, common meaning of "method" excluded business methods, nor was it clear how far a prohibition on business methods patents would reach. A categorical exclusion of business methods was further undermined by the fact that federal law under 35 U.S.C. §273 (b) (1) explicitly contemplated the existence of at least some business method patents. However, while §273 appeared to leave open the possibility of some business method patents, it did not suggest broad patentability of such claimed inventions.
2.4 Even though the petitioners' application was not categorically outside of §101 under the above-mentioned approaches (1) and (2) rejected by the Supreme Court in their categorical form, that did not mean it was a "process" under §101. Rather than adopting categorical rules that might have wide-ranging and unforeseen impacts, the Supreme Court resolved the case narrowly on the basis of its guidepost decisions in Gottschalk v. Benson, 409 U.S. 63 (1972) of 20 November 1972, Parker v. Flook, 437 U.S. 584 (1978) of 22 June 1978 and Diamond v. Diehr, 450 U.S. 175 (1981) of 3 March 1981, which showed that petitioners' claims were not patentable processes because they were attempts to patent abstract ideas. Hence, there was no need to define further what constituted a patentable "process".
2.5 Since the patent application could be rejected under the precedents on non-patentability of abstract ideas, the U.S. Supreme Court once again declined to impose limitations on the Patent Act that were inconsistent with the Act's text. However, nothing in the present opinion should be read as endorsing interpretations of §101 that the Federal Circuit had used in the past (see, e.g., State Street Bank & Trust Co. v. Signature Financial Group Inc., 149 F.3d 1368 (Fed. Cir. 1998) of 23 July 1998 or AT&T Corp. v. Excel Communications, Inc., 172 F.3d 1352 (Fed. Cir. 1999) of 14 April 1999). It might be that the Federal Circuit thought it needed to make the machine-or-transformation test exclusive precisely because its case law had not adequately identified less extreme means of restricting business method patents. In disapproving an exclusive machine-or-transformation test, the U.S. Supreme Court by no means foreclosed the Federal Circuit's development of other limiting criteria.
2.6 Hence, although the machine-or-transformation test established by the CAFC was rejected as the sole test for evaluating patent-eligibility, the U.S. Supreme Court indicated that it intended neither to de-emphasise the test's usefulness nor to suggest that many patentable processes might lie beyond its reach. Whereas abstract ideas are not patentable, business methods are not categorically excluded. Other limiting criteria in this respect had to be developed by the Federal Circuit.
2.7 In the end, what constitutes a patentable process has been left open. Nor do we know how a patentable process is distinguished from an abstract idea. In the U.S. Supreme Court's view, there may be patentable subject-matter beyond the limits set by the machine-or-transformation test, but possibly not very wide-ranging. Business methods may be patentable within certain limits to be established by some unknown test and/or applying the other patentability requirements more strictly. What this surplus over the machine-or-transformation test is, and where the line has to be drawn with respect to business methods, is now (again) left to the Federal Circuit with the advice to use the precedents of Benson, Flook and Diehr as guideposts and to forget about the State Street Bank approach as a fall-back alternative.
Whereas G 3/08 appears to settle the legal situation in the field of computer-implemented inventions in Europe for the time being and at least for some time to come, Bilski leaves important questions open in the United States. In consequence, both legal systems remain in a different state of legal certainty, and one can only speculate if and when the Federal Circuit might be able to close the existing gaps in legal construction.
From a European perspective, it is interesting to see that, on the one hand, abstract ideas are neither patentable in Europe nor in the United States and, on the other hand, business methods are not categorically excluded from patentability in both systems, in the United States because they fall under the broad meaning of "process" or "method" as patent-eligible subject-matter, in Europe because they are only excluded "as such". The delimiting criterion in Europe is the presence of technical character that is already realised by using any technical means. In so far process patentability in Europe is necessarily tied to a machine, which need not be a "particular" one. In the United States, machine involvement does not appear to be a sine qua non, while any other delimiting criterion is lacking for now. Finally, in Europe a strict weeding exercise is carried out at the second hurdle of novelty and inventive step, also hinted at by the U.S. Supreme Court in Bilski.
First published in BARDEHLE PAGENBERG IP REPORT 2010/III


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Consumer Protection in an Age of Uncertainty Panel 1: The Past & Future of the CFPB (Day 1)
Mar 21, 2019
In the wake of the financial crisis, Congress created the Consumer Financial Protection Bureau, spurring significant changes to the financial regulation landscape. A decade later, developments in the U.S. political system and innovations in financial technology have brought on more changes. ...

subset: commoncrawl


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Project Description
It was by the ministry of the disciples that Jesus' name began to be spread across the land of Israel, even reaching King Herod. Even now, Jesus becomes known, for good or bad, through the actions of Christians today. This is an enormous responsibility and pressure. In this message, Pastor Evan discusses how a follower of Christ can live out this responsibility in a way that conveys grace and not legalism.


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May 12, 2019 - 10:53
Yesterday, Hendrik competed again in Oberneuland. In the jumping class on M**-level he showed clear rounds with Casirus and Cadora, who finished ninth.
In the afternoon, Hendrik rode the Youngster-Tour for eight-year-old horses and became sixth with Casalido and seventh with Lady Cadora.
In the biggest class of the day, a jumping class on S*-level, Hendrik and Lady Lordana had no faults and became tenth. We are looking forward to the next days.


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139 years ago Gilbert and Sullivan's new comic opera HMS Pinafore or The Lass that Loved a Sailor almost bombed on its premiere at the Opera Comique in Westminster owing to a heatwave having discouraged audiences. On Saturday Mother Nature turned up the burners again in Chipping Norton, though the theatre remained remarkably unstuffy. I wonder whether librettist and composer would have recognised something familiar about its interior? The building began life as a Salvation Army 'Citadel' [church] in 1888, but the architect specialised in the building of Victorian Music Halls which would account for the its being perfectly proportioned for use as a theatre. By the 1950s it had dwindled into use as a furniture warehouse, before being rescued in the 1970s. Its interior now has a capacity of 213, and its Cotswold stone walls, its green-painted wood panelling and balcony, and its brass fittings and red lamps, is snugly period-authentic.
This is only the second ever performance by Abingdon-based Opera Anywhere of this operetta, created for their summer and autumn tour as a third G&S warhorse to inhabit the stable already occupied by The Pirates of Penzance and The Mikado. I think the G&S brand is having a bit of an identity crisis at the moment. The operettas are being a mite overshadowed by the big, punchy musicals with mass effects and rousing scores – on-the-nose pertinence swaddled by the passage of time and theatrical innovation. Yet Buxton Opera House attracts audiences of 20,000 to its annual G&S festival. Opera Anywhere is surely performing a cultural if not also a social service by offering a corridor into opera for people perhaps put off by the elitist label, the cost or the inaccessibility of the full-blown music form. Thus, of the three couples to whom I spoke at the interval, two were new to opera (one had never before heard of G&S).
HMS Pinafore has a thin plot even by Gilbertian standards, but then these G&S shows are never about narrative. The setting aboard the good ship HMS Pinafore has been updated to, I think, WW2 vintage, with the back projection representing the poop deck of perhaps HMS Hood or the Renown. There's a female chorus of sisters, cousins and aunts dressed as Wrens, and a Smith and Wesson revolver doing duty for a musket. Taken together with later references to the weekly shop and Marks and Spencer, I had a slight feeling the updating left the show occupying a bit of a no man's land between something contemporary and a traditional staging.
The set comprises little more than a couple of sticks of furniture and the music comes from Louisa Lam on keyboard and Nick Planas on flute, piccolo and clarinet. I suppose two persons just about a band do make, but despite their best efforts the sound was a trifle thin and the effect necessarily just a little repetitive. Tristan – now there's a fine operatic name – Stocks played the status-challenged sailor with innocent optimism and had a clear, light tenor voice. There was a capable chorus of sometimes three, sometimes four sailors including the imposing, gravelly-voiced Mark Horner as the lugubrious Dick Deadeye, and an even better band of Wrens including the accomplished Katie Blackwell and Rachel Falaise makes a lively and ingratiating Hebe. The ever-dependable Vanessa Woodward was the ludicrously-named Little Buttercup, the "rosiest, roundest, and reddest beauty in all Spithead".
Of the principals, Josephine the Captain's daughter, in love with a common sailor, was a spirited Amy Webber with plenty of carry to her soprano voice, and Mike Woodward a pleasingly thoughtless twit of a Sir Joseph Porter in his white ducks. The highlight was Miles Horner's (who also directed) beaming Captain Corcoran, a genial and democratic officer, who tippy-toed round the deck in ludicrous penguin steps and later, pace Gilbertian topsy-turvydom, was transformed by a S. Yorkshire accent. His bass-baritone had depth and control; a voice that might have launched a thousand ships.
Good fun, and the remaining 12 dates in Oxfordshire of the tour will be well worth checking out.


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Well into our third century of filmmaking, which of the new millennium�s American movies can be considered among the best of all time?
The American Film Institute earlier this week took three hours of CBS prime time to showcase its new list of the 100 best American movies, as picked by a jury of about 1,500 filmmakers and other creative artists.
If this sounds familiar, it�s because the AFI did this for the first time in 1998, including movies made up to 1996.
So the question is: What new kids of the last decade deserve all-star status, up there with long-acknowledged gems such as �Casablanca," �The Godfather" and �Citizen Kane"?
Of course, some of those from the first list will have to drop out if new ones get voted in, and some could, theoretically at least, have lost favor in the past several years.
But more likely, it�ll be a case of a newcomer bumping one of the dustier, more dated flicks, such as �Rebel With a Cause" or �The Jazz Singer," which could more rightly be termed �important" than actually great.
We asked a group of Tuscaloosa (and former Tuscaloosa) cinephiles to pick flicks from the recent past that belong on AFI�s list.
�The first movie that popped in my mind is 'Fight Club,�" said songwriter Blaine Duncan, leader of the punchy local band Blaine Duncan and The Lookers. �One of the few instances where the movie surpassed the novel."
Paul B. Crook, a UA graduate and assistant professor in theater at Louisiana Tech University School of Performing Arts, will be back in his hometown in a few weeks to direct �Smoke on the Mountain Homecoming" for Theatre Tuscaloosa. His picks range fairly widely, reflecting his status as a theater professional and family man.
�From the last 10 years, I would add 'Shrek,� 'Chicago,� 'Saving Private Ryan,� 'The Lord of the Rings� trilogy (well, definitely 'Fellowship� and 'Return,�) " Crook said.
Which brings up a question, as several people weighed in on Peter Jackson�s adaptation of J.R.R. Tolkien: Should �The Lord of the Rings" be considered as three separate movies, as released, or as one three-part, 10-plus-hour epic? Most of our voters judged them as separate movies.
UA senior theater major Rachel Wesley opted for some less-obvious choices, with defenses parenthetical:
� 'Titanic� (reached into the billions at the box office, highly decorated by the academy, a highly quotable movie, based on a historical event, good acting), 'Boys Don�t Cry� (addressed highly controversial issues in a gutsy way, brilliant acting), 'I Am Sam� (stellar ensemble cast), 'Girl Interrupted� (best collection of female acting in cinema), 'The Matrix� (innovative in special effects), 'American History X� (Edward Norton, dealt with the issue of race in a blunt way)," Wesley wrote.
Alison Tucker, a junior theater student, went for more flash and dazzle.
� 'Moulin Rouge.� That�s all I am saying," Tucker said, although it wasn�t. �And 'Nightmare Before Christmas� � brilliant. Then again, what isn�t that Tim Burton does?"
UA grad Graham Flanagan, working for CNN in New York City, has never been shy about his movie opinions, not when he was a teenager writing for The Tuscaloosa News� teen pages, nor when a columnist, film programmer and radio personality in college.
Here are Graham�s picks, with comments:� 'Saving Private Ryan� -- Reinvented the war movie. Still hasn�t been surpassed and probably won�t be.� 'Traffic� -- Simultaneously an insightful commentary on the drug culture and a compelling 'procedural� drama.� 'Finding Nemo� -- Best Pixar movie yet. Great animation, great story, great movie."
His younger brother, Ben Flanagan, is no less passionate, although perhaps more reticent about flaming those who disagree with him. He�s currently hosting a show on campus radio station WVUA 90.7 FM, 2-3 p.m. Sundays, all about movies.
Ben expressed his top pick in classic movie-fan form, with a line from the much-quoted Coen brothers� Raymond Chandler-esque stoner comedy �The Big Lebowski": �We vant ze money, Lebowski."
Other votes came in for �American Beauty," and there were repeated notes for �Saving Private Ryan," �Traffic" and �Shrek."
Tina Fitch, executive producer of Theatre Tuscaloosa, is used to thinking long-range, obviously, as she provided a lengthy discourse.
� 'Saving Private Ryan� tops my list," she said. �The perspective of the camera made us feel we were in the war."
She lauded that same year�s �Shakespeare in Love," winner of a hotly contest Best Picture Oscar, for its writing, costumes and acting, as � � a well-polished piece of art."
She also named �The Sixth Sense," �House of Sand and Fog," �Seabiscuit" (�I cried so hard I couldn�t see straight"), �Finding Neverland" (�The impact lingers long after the movie is over"), �Ray," �Million Dollar Baby," �Chocolat" (� � mainly because I liked all the chocolate in it"), �Crash," �Boogie Nights," �Pleasantville" and �The Green Mile."
And in case time has been kind to their memories, and AFI members might reconsider, she also added two favorites from 1996, �Sling Blade" and �First Wives Club."
None of those polled concurred with the one film Atlanta Journal-Constitution columnist Alan Smithee (a pseudonym for a critic or critics writing for the AJC) included as the �one film I can�t believe they left out" of the 400 nominees.
Smithee opined for 1998�s �The Thin Red Line."
�Terrence Malick has made three of the best American movies ever -- 'Badlands� (1973), 'Days of Heaven� (1978), and his mesmerizing World War II epic 'The Thin Red Line,� set in the Pacific theater," Smithee wrote.
�Only the first two films are under consideration for the AFI�s 100 list. What an over-sight. Malick�s lusciously filmed account of Guadalcanal is war as Rorschach inkblot, with inspired performances from Nick Nolte, Jim Caviezel, Sean Penn and others contemplating evil, conflict and military politics."
Smithee concurred with many of our panel that �The Lord of the Rings," or at least its third chapter, �Return of the King," from 2003, was among the best choices, along with �The Sixth Sense," �Saving Private Ryan" and �Shakespeare in Love."
Smithee went on to chronicle the worst possible new picks, among them Martin Scorcese�s �The Aviator," �Moulin Rouge," �There�s Something About Mary" and �Shrek" (�It emphasizes pop culture references and poop.")
Top 100 american movies
The AFI�s 2007 list of the greatest American movies:
1. �Citizen Kane,� (1941)
2. �The Godfather,� (1972)
3. �Casablanca,� (1942)
4. �Raging Bull,� (1980)
5. �Singin� in the Rain,� (1952)
6. �Gone With the Wind,� (1939)
7. �Lawrence of Arabia,� (1962)
8. �Schindler�s List,� (1993)
9. �Vertigo,� (1958)
10. �The Wizard of Oz,� (1939)
11. �City Lights,� (1931)
12. �The Searchers,� (1956)
13. �Star Wars,� (1977)
14. �Psycho,� (1960)
15. �2001: A Space Odyssey,� (1968)
16. �Sunset Blvd.,� (1950)
17. �The Graduate,� (1967)
18. �The General,� (1927)
19. �On the Waterfront,� (1954)
20. �It�s a Wonderful Life,� (1946)
21. �Chinatown,� (1974)
22. �Some Like It Hot,� (1959)
23. �The Grapes of Wrath,� (1940)
24. �E.T. the Extra-Terrestrial,� (1982)
25. �To Kill a Mockingbird,� (1962)
26. �Mr. Smith Goes to Washington,� (1939)
27. �High Noon,� (1952)
28. �All About Eve,� (1950)
29. �Double Indemnity,� (1944)
30. �Apocalypse Now,� (1979)
31. �The Maltese Falcon,� (1941)
32. �The Godfather Part II,� (1974)
33. �One Flew Over the Cuckoo�s Nest,� (1975)
34. �Snow White and the Seven Dwarfs,� (1937)
35. �Annie Hall,� (1977)
36. �The Bridge on the River Kwai,� (1957)
37. �The Best Years of Our Lives,� (1946)
38. �The Treasure of the Sierra Madre,� (1948)
39. �Dr. Strangelove,� (1964)
40. �The Sound of Music,� (1965)
41. �King Kong,� (1933)
42. �Bonnie and Clyde,� (1967)
43. �Midnight Cowboy,� (1969)
44. �The Philadelphia Story,� (1940)
45. �Shane,� (1953)
46. �It Happened One Night,� (1934)
47. �A Streetcar Named Desire,� (1951)
48. �Rear Window,� (1954)
49. �Intolerance,� (1916)
50. �The Lord of the Rings: The Fellowship of the Ring,� (2001)
51. �West Side Story,� (1961)
52. �Taxi Driver,� (1976)
53. �The Deer Hunter,� (1978)
55. �North by Northwest,� (1959)
56. �Jaws,� (1975)
57. �Rocky,� (1976)
58. �The Gold Rush,� (1925)
59. �Nashville,� (1975)
60. �Duck Soup,� (1933)
61. �Sullivan�s Travels,� (1941)
62. �American Graffiti,� (1973)
63. �Cabaret,� (1972)
64. �Network,� (1976)
65. �The African Queen,� (1951)
66. �Raiders of the Lost Ark,� (1981)
67. �Who�s Afraid of Virginia Woolf?�, (1966)
68. �Unforgiven,� (1992)
69. �Tootsie,� (1982)
70. �A Clockwork Orange,� (1971)
71. �Saving Private Ryan,� (1998)
72. �The Shawshank Redemption,� (1994)
73. �Butch Cassidy and the Sundance Kid,� (1969)
74. �The Silence of the Lambs,� (1991)
75. �In the Heat of the Night,� (1967)
76. �Forrest Gump,� (1994)
77. �All the President�s Men,� (1976)
78. �Modern Times,� (1936)
79. �The Wild Bunch,� (1969)
80. �The Apartment, (1960)
81. �Spartacus,� (1960)
82. �Sunrise,� (1927)
83. �Titanic,� (1997)
84. �Easy Rider,� (1969)
85. �A Night at the Opera,� (1935)
86. �Platoon,� (1986)
87. �12 Angry Men,� (1957)
88. �Bringing Up Baby,� (1938)
89. �The Sixth Sense,� (1999)
90. �Swing Time,� (1936)
91. �Sophie�s Choice,� (1982)
92. �Goodfellas,� (1990)
93. �The French Connection,� (1971)
94. �Pulp Fiction,� (1994)
95. �The Last Picture Show,� (1971)
96. �Do the Right Thing,� (1989)
97. �Blade Runner,� (1982)
98. �Yankee Doodle Dandy,� (1942)
99. �Toy Story,� (1995)
100. �Ben-Hur,� (1959)
Everybody's a critic
Well into our third century of filmmaking, which of the new millennium�s American movies can be considered among the best of all time?


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I just finished reading Eaustace Mullins book the "New History of the Jews" again. I was looking for more information and came accross an article by a fellow named Willie Martin. He's done a lot of research and his article seems to be backed up by records going back many centuries. Below is an excerpt from it and there is much more at this link.
The History of Jewish Human Sacrifice
At the dawn of civilization, the blood rite, in which human blood is drunk from the body of a still-living victim, was known to many tribes. However, only one people, that has never progressed beyond the Stone Age, has continued to practice the blood rite and ritual murder. This people are know to the world as Jews. Arnold Toynbee, a noted scholar, has called the Jews "a fossil people."
In so doing, he must have been aware of the fact that they still practice ritual murder and the drinking of human blood (especially Christian blood). As a scholar, he could not have failed to note the many attested incidents of this practice of the Jews, for hundreds of example of ritual murder by the Jews are cited in official Catholic books, in every European literature, and in the court records of all the European nations.
It is the official historian of the Jews, (Josef Kastein, in his History of the Jews, who gives the underlying reason for this barbaric custom. On page 173, he says, "According to the primeval Jewish view, the blood was the seat of the soul."
Thus it was not the heart which was the seat of the soul, according to the stone-age Jews, but the blood itself. They believed that by drinking the blood of a Christian victim who was perfect in every way, they could overcome their physical short comings and become as powerful as the intelligent civilized beings among whom they had formed their parasitic communities. Because of this belief, the Jews are known to have practiced drinking blood since they made their first appearance in history.
Jewish Murder Plan Against White Christians Exposed
The Murderous People: The Jews are under a terrible suspicion the world over, and for good reason. Anyone who does not know this, does not understand the Jewish problem. Anyone who merely see the Jews as "a tribe which secures its existence with exchange and old trousers, and whose uniforms are the long noses," is being misled. But anyone who knows the monstrous accusation which has been raised against the jews since the beginning of time, will view these people in a different light. He will begin to see not only a peculiar, strangely fascinating nation; but criminals, murderers, and devils in human form. He will be filled with holy anger and hatred against these people of Satan. (John 8:44)
The suspicion under which the Jews are held is murder. They are charged with enticing White Christian Children (and sometimes blacks to keep them under control - and if necessary they will run black children down in the streets with automobiles to show the blacks their power, and that the blacks had better mind their manners or the same will happen again and again. We all witnessed this a few years ago in New York city when the car of Rabbi Shneerson ran over a black child. And as usual the Jews bought off the blacks who were inciting the mobs against them; if they had been unsuccessful in this they would have had the blacks who dared not be controlled murdered) and at time White Christian adults, butchering them, and draining their blood. They are charged with mixing this blood into their masses (unleaven bread) and using it to practice superstitious magic. They are charged with torturing their victims, especially the children; and during this torture they shout threats, curses, and cast spells against non-Jews. This systematic murder has a special name, it is called,
Ritual Murder
The knowledge of Jewish ritual murder is thousands of years old. It is as old as the Jews themselves. Non-Jews have passed the knowledge of it from generation to generation, and it has been passed down to us thorough writings. It is known of throughout the nation. Knowledge of ritual murder can be found in even the most secluded rural villages. The grand-father told his grand children, who passed it on to his children, and his children's children, until we have inherited the knowledge today from them.
It is also befalling other nations. The accusation is loudly raised immediately, anywhere in te world, where a body is found which bears the marks of ritual murder. This accusation is raised only against the Jews. Hundreds and hundreds of nations, tribes, and races live on this earth, but no one ever thought to accuse them of the planned murdering of children, or to call them murderers. All nations have hurled this accusation only against the Jews.
And many great men have raised such an accusation. Martin Luther wrote in his book "Of The Jews And Their Lies:"
"They stabbed and pierced the body of the young boy Simon of Trent. They have also murdered other children...The sun never did shine on a more bloodthirsty and revengeful people as they who imagine to be the people of God, and who desire to and think they must murder and crush the heathen. Jesus Christ, the Almighty Preacher from Nazareth, spoke to the Jews: ? Ye are of your father the devil, and the lusts of your father ye will do. He was a murderer from the beginning..."
"He (Martin Luther) accused them (the Jews) of all those fictitious crimes which had made Europe such a hell for them. He, too, claimed that they poisoned the wells used by Christians, assassinated their Christian patients, and murdered Christian children to procure blood for the Passover. He called on the princes and rulers to persecute them mercilessly, and commanded the preachers to set the mobs on them. He declared that if the power were his, he would take all the leaders of the Jews and tear their tongues out by the roots." (Stranger than Fiction, p. 249)
The Struggle of Der Sturmer: The only newspaper in Germany, yes, in the entire world, which often screamed the accusation of ritual murder into the Jewish face, was Der Sturmer. For more than ten yeas Der Sturmer led a gigantic battle against Judaism. Which caused Der Sturmer to be under constant attack by the Jews. Dozens of times it has been confiscated and prohibited.
Its workers, most of all its editor Julius Streicher, were dragged into court hundreds of times. They were convicted, punished and locked into prison. Der Sturmer came to know the Jew from the confession which Dr. Conrad Alberti-Sittenfeld, a Jew, wrote in 1899 in No. 12 of the magazine Gesellschaft:
"One of the most dangerous Jewish qualities is the brutal, direct barbaric intolerance. A worse tyranny cannot be practiced than that which the Jewish clique practices. If you try to move against this Jewish clique, they will, without hesitating, use brutal methods to overcome you. Mainly the Jew tries to destroy his enemy in the mental area, by which he takes his material gain away, and undermines his civil existence. The vilest of all forms of retaliation, the boycott, is characteristically Jewish."
The Der Sturmer was not stopped for several years. Just in Nuremberg alone there have been fought dozens of Talmudic and ritual murder cases in the courts. (Now you know why the Nuremberg trials were held against the German Military leaders, it was retribution by the Jews on their hated enemies the Germans). Because of the Jewish protests the attention of the world was focused on these cases. Thereafter heavy convictions followed. At first no judge had the courage to expose the Jewish problem. Finally in 1932 (court case lasting from October 30th to November 4th) Der Sturmer won its first victory. The jury found the following:
1). Der Sturmer was not fighting against the Jewish religion; but against the Jewish people.
2). The Talmud and Schulchan aruch are not religious books. They have no right to be protected under the religious paragraphs.
3). The laws of the Talmud which are quoted and published in Der Sturmer are exact quotations from the Talmud.
4). The laws of the Talmud are in harsh contradiction to German morals.
5). The Jews of today are being taught from the Talmud.
With this verdict Der Sturmer brought about the first big breach in the Jewish/Roman Administration of Justice, which was given the job before the National Socialist revolution to protect Judaism and its government. The jews, of course, became greatly agitated about this. But for De Sturmer this success was an omen of the victory yet to come. Of course, Der Sturmer did not stop half way. It knew what had to be done. It was their duty, or so they believed. To frustrate the gigantic murder plot of Judaism against humanity. It was their duty! To brand this nation before the world, to uncover its crimes and to render it harmless. It was their duty! To free the world from this national pest and parasitic race. Der Sturmer would fulfill its mission. It would, for a time, light up the darkness with the truth which shall eventually rule the world. And it would always direct itself according to the following proverb: "He who knows the truth and does not speak it truly is a miserable creature."
The Laws of The Talmud: If one wishes to learn and understand why the Jews can commit such insane crimes as ritual murder, they must know the Jewish secrets. They must know the teachings of the Torah (The Talmud), and the Schulchan aruch. These laws and teachings are proof that the Jews feel themselves superior to all nations, that it has declared war on all other races, and that it is the sworn enemy of the whole of non-Jewish humanity. Even Tactius, the Roman historian who lived shortly after Christ (55-120) A.D.) wrote:
"The Jews are a race that hate the gods and mankind. Their laws are in opposition to those of all mortals. They despise what to us is holy. Their laws condone them in committing acts which horrify us." (Historian V. 3-8)
The Jew knows that when the non-Jewish world knows his laws and sees through his plans that he is lost. Therefore, by threat of death he forbids their translation and publication. A well known Jewish scholar (Dibre David) writes:
"If the Gentiles (non-Jews) knew what we are teaching against them, they would kill us."
The Jewish secret laws are based on the fundamental principle which states: Only the Jew is human. In contrast all non-Jews are animals, they are beasts in human form. Anything is permitted against them. The Jew may lie to, cheat and steal from them. He may rape and murder them. There are hundreds of passages in the Talmud which the non-jews are described as animals. Some of them are as follows:
1). "The Jews are called human beings, but the non-Jews are not humans. They are beasts." (Talmud: Baba Mezia 114b)
2). "The Akum (Negro) is like a dog. Yes, the scripture teaches to honor the dog more than the Akum." (Ereget Raschi Erod. 22
3). "Even though God created the non-Jew they are still animals in human form. It is not becoming for a Jew to be served by an
animal. Therefore he will be served by animals in human form." (Midrasch Talpioth, p. 255, Warsaw 1855)
4). "A pregnant non-Jew is no better than a pregnant animal." (Coschen Hamischpat 405)
5). "The souls of non-Jews come from impure spirits and are called pigs." (Jalkut Rubeni gadol 12b)
6). "Although the non-Jew has the same body structure as the Jew, they compare with the Jew like a monkey to a human." (Schene
Luchoth Haberith, p. 250b)
So that the Jew will never forget that he is dealing with animals, he is reminded by eating, by death, and even by sexual intercourse constantly. For The Talmud teaches:
1). "If you eat with a non-Jew, it is the same as eating with a dog." (Tosapoth, Jebamoth 94b)
2). "If a Jew has a non-Jewish servant of maid who dies, one should not express sympathy to the Jew. You should tell to the Jew:
?God will replace ?your loss,' just as if one of his oxen or asses had died." (Jore Dea 377, 1)
3). "Sexual intercoms between non-Jews is like intercourse between animals." (Sanhedrin 74b)
It is written in the Talmud about the murder of the non-Jew:
1). "It is permitted to take the body and the life of a non-Jew." (Sepher Ikkarim IIIc, 25)
2). "It is the law to kill anyone who denies the Torah (Talmud - Sanhedrin 59b). The Christians
belong to the denying ones of the Torah (Talmud)." (Coschen Hamischpat 425, Hagah 425, 5)
3). "Every Jew, who spills the blood of the godless (non-Jew), is doing the same as making a sacrifice to God." (Bammidber Raba, c 21 & Jalkut 772)
These laws of the Talmud were given to the Jews over 3000 years ago. They are just as valid today as they were back then. This is how the Jews are taught from childhood. The results of this stands before us. It is Jewish Ritual Murder.
The Jews' Bloody History: The Jew is not only the murderer of the Christians in theory. His history proves that he practices what he preaches. The history of the Jewish people is an unbroken chain of mass murders and blood-baths. It started before Christ and has continued with Linen, Trotsky, Sinowjeff, Stalin and etc., up to today:
1). The extreme to which the Jews will go was shown in Persia where the Jew Mordecai and the Jewess Esther had 75,800 Persians murdered. They hanged the Persian King Xerxes' minister Haman along with his ten sons. They celebrated this bloody victory and to this day still celebrate it during the Feast of Purim. (Book of Esther 9:6)
After Christ in the years 115-117, on the island of Cyrene, the Jews revolted under their leader Bar Kochba. They murdered 220,000 Romans, sawed and chopped them, drank their blood, and ate their bloody raw flesh. (Dio Cassius: Roemische Jeschichte XVIII, 32)
The Jews revolted in Russia in 1917 and established bolshevism under the leadership of Trotsky, Sinojeff and other Jews, a total of 35 million Christians were shot, slayed, tortured, and starved to death. In Hungary, under the leadership of the Bolshevik Jew Bela Kuhn, a horrible massacre was prepared in which tens of thousands of Christians were murdered.
"'The Jewish Establishment": 'In the early 1930s, Walter Duranty of the New York Times was in Moscow, covering Joe Stalin the way Joe Stalin wanted to be covered. To maintain favor and access, he expressly denied that there was famine in Ukraine even while millions of Ukrainian Christians were being starved into submission. For his work Duranty won the Pulitzer Prize for journalism. To this day, the Times remains the most magisterial and respectable of American newspapers. How imagine that a major newspaper had had a correspondent in Berlin during roughly the same period who hobnobbed with Hitler, portrayed him in a flattering light, and denied that Jews were being mistreated, thereby not only concealing, but materially assisting the regime's persecution. Would that paper's respectability have been unimpaired several decades later? There you have an epitome of what is lamely called 'media bias.' The Western supporters of Stalin haven't just been excused; they have received the halo of victim hood for the campaign, in what liberals call 'the McCarthy era,' to get them out of the government, the education system, and respectable society itself. Not only persecution of Jews but any critical mention of Jewish power in the media and politics is roundly condemned as 'anti-Semitism.' But there isn't even a term of opprobrium for participation in the mass murders of Christians. Liberals still don't censure the Communist attempt to extirpate Christianity from Soviet Russia and its empire, and for good reason, liberals themselves, particularly Jewish liberals, are still trying to uproot Christianity from America. It's permissible to discuss the power of every other group, from the Black Muslims to the Christian Right, but the much greater power of the Jewish establishment is off-limits. That, in fact, is the chief measure of its power: its ability to impose its own taboos while tearing down the taboos of others, you might almost say its prerogative of offending. You can read articles in Jewish-controlled publications from the Times to Commentary blaming Christianity for the Holocaust or accusing Pope Pius XII of indifference to it, but don't look for articles in any major publication that wants to stay in business examining the Jewish role in Communism and liberalism, however temperately." (The Jewish Establishment, Joseph Sobran, September 1995 issue)
In Jewish-Bolshevik Soviet Russia mass murders are even now (1997) are being carried out. The executioners are mostly Jewish men and women. In inventing new methods of torture the Jews are past masters. To let Christians die under torture give them the greatest pleasure. English reporters write that the Chinese executioners frequently would not carry out their tortures and executions; they shouldered and could not continue. Therefore, Jews and Jewesses took their place.
"The Jews were now free to indulge in their most fervent fantasies of mass murder of helpless victims. Christians were dragged from their beds, tortured and killed. Some were actually sliced to pieces, bit by bit, while others were branded with hot irons, their eyes poked out to induce unbearable pain. Others were placed in boxes with only their heads, hands and legs sticking out. Then hungry rats were placed in the boxes to gnaw upon their bodies. Some were nailed to the ceiling by their fingers or by their feet, and left hanging until they died of exhaustion. Others were chained to the floor and left hanging until they died of exhaustion.
"Others were chained to the floor and hot lead poured into their mouths. Many were tied to horses and dragged through the streets of the city, while Jewish mobs attacked them with rocks and kicked them to death. Christian mothers were taken to the public square and their babies snatched from their arms. A red Jewish terrorist would take the baby, hold it by the feet, head downward and demand that the Christian mother deny Christ. If she would not, he would toss the baby into the air, and another member of the mob would rush forward and catch it on the tip of his bayonet.
"Pregnant Christian women were chained to trees and their babies cut out of their bodies. There were many places of public execution in Russia during the days of the revolution, one of which was described by the American Rohrbach Commission: 'The whole cement floor of the execution hall of the Jewish Cheka of Kiev was flooded with blood; it formed a level of several inches. It was a horrible mixture of blood, brains and pieces of skull. All the walls were bespattered with blood. Pieces of brains and of scalps were sticking to them. A gutter of 25 centimeters wide by 25 centimeters deep and about 10 meters long was along its length full to the top with blood. Some bodies were disemboweled, others had limbs chopped off, some were literally hacked to pieces. Some had their eyes put out, the head, face and neck and trunk were covered with deep wounds. Further on, we found a corpse with a wedge driven into its chest. Some had no tongues. In a corner we discovered a quantity of dismembered arms and legs belonging to no bodies that we could locate.'" (Defender Magazine, October
There is much more at this link http://www.thewatcherfiles.com/jewish_sacrifice.htm


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What it is: A trace element that's found in food and plays a big role in brain development and the creation of thyroid hormones.
Why you need it: Iodine is one of the most important minerals a fetus needs for brain and nervous system development. It also helps maintain normal function of the thyroid, a gland in the base of your neck that regulates the hormones that control core body functions, including metabolism, heart rate and body temperature. Iodine does so much for your body, but it's easy to get the amount you need. Deficiency of iodine during pregnancy is the most preventable cause of intellectual disability in the world, according to the World Health Organization (WHO) and the Centers for Disease Control and Prevention (CDC). Keep your growing baby on track by adding some of these yummy things to your diet.
How much you need daily: 150-250 mcg and no more than 1,100 mcg, as intake of this amount has been linked to thyroid cancer, according to the National Institutes of Health (NIH)
Where you can get your fill: Baked cod, plain yogurt, milk, shrimp, egg, canned light tuna, creamed corn, cheddar cheese and iodized table salt
Recipes to Try:
Related Stories:
- More Pregnancy Nutrients Week-by-Week
- Learn to Eat Well During Pregnancy
- Everything You Need to Know About Pregnancy Health


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About this time last year, members of the Outreach committee put out the word to collect as many Christmas cards as possible. Many stores have them on sale at up to 75% off or more. Some people donated their own stash of extra Christmas cards and the result was over 1000 cards! The Stewpot allowed us to distribute the cards at their facility for the homeless in downtown Dallas. We were there for two full days and nearly all of the cards were snapped up. The clients at The Stewpot were so excited to be able to be send cards to friends and family. We brought the cards and The Stewpot paid the postage. In order to continue this heartwarming ministry, we need to start collecting cards again right now. Please get out there and find some real deals on boxes of cards and bring them to Kandy Burdette. And if you want to help man the distribution table next year, sign up now. It's an amazing experience.
Christmas Card Ministry


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This is our Harmony Ball Gift Set, including one harmony ball and one harmony ball pendant, delivered in this nice golden case, perfect for the holidays. Free gift box; after this one is gone, we will send it two separate smaller gold 'foil' gift boxes.
Sunreed Meditation Tips!
Imagination is a powerful tool to create the potential for desired effect or outcome!! For a meditation, wave them softly around your head, ears, body, and auric field, or that of your client. Imagine they are 'sweeping the field,' or 'entraining' the field to higher, clearer states, or vibrations. Use your intention and imagination to affect a 'felt' outcome in your practice. Breath with the sound of the ball as it jingles around you. You will feel an uplifting that matches your intention and imagination as the ball moves around you.


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The penultimate home meet saw the Bainbridge High School track and field team continue in their so-far stellar season, setting new personal and school records and snagging top spots in many events on both the men and women's side.
Athletes from Eastside Catholic and Cleveland converged at the island stadium Thursday, April 26.
Highlights among the island women included seven of the top nine finishers in the 100-meters: Emma Brundige (first), Morgan Dierickx (second, 14.02, a personal record), Elana Dorsey (third), Capri Fain (fourth), Sarah Salot (fifth), Mataya George (sixth, 15.55, a personal record), and Elena Conklin (eighth).
BHS also sported eight of the top 10 finishers in the 200-meters: Emma Brundige (first), Morgan Dierickx (fourth, 28.46, a personal record), Natalie Taylor )fifth, 28.52, a personal record), Elana Dorsey (sixth), Reese Hill (seventh), Hannah Tonsman (eighth, 30.17, a personal record), Capri Fain (ninth, 30.57, a new school record), and Zoe Lim (10th).
All three of the top finishers in the 400-meters were also Spartans: McKenzie Korican (first, 1:02.83, a new school record), Reese Hill (second, 1:06.79, a personal record), and Zoe Lim (third, 1:08.63, a personal record).
In the 800-meters, Anna Scott took second place and set a new school record (2:27.64), and Mataya George (third, 2:45.12) and Elena Conklin (fourth, 3:08.04) both set personal records as well.
Hannah Tonsman took first in the 1600-meters (5:28.25); Capri Fann took second in the 300-meter hurdles (56.99); Charlotte Bourgeois took first in the shot put and set a personal record (64-07) in discus; Brooke Taylor took fourth in the high jump; Keegan Daniels and Alathea Pippinger finished first and third, respectively, in pole vault; and Emma Brundige and Charlotte Bourgeois finished first and second, respectively, in the long jump.
Highlights among the island men included Andrew Frankie Owen and Evan Kimmerlein finished first and second (12.14, a personal record), respectively, in the 100-meters. Five of the top 10 finishers in the 200-meters were from Bainbridge (and all set personal records); Evan Kimmerlein (second), Kyle Hammer (fourth), Christian Nong Kingombe (sixth), Ari Jabloner (seventh), and Akio Hansen (ninth).
Bainbridge boasted four of the top 10 finishers in the 400-meters: Carlo Ruggiero (first, 51.09, a personal record), Kyle Hammer (second), Leander von Specht (fourth, 53.36, a personal record), and Sean Lindsey (seventh, 55.92, a personal record).
Aidan Cantine finished first in the 800-meters, and Jacob Tomer (2:20.57, a personal record) and Micah Glasby (2:30.49, a personal record) finished fifth and sixth, respectively.
Four of the five top finishers in the 1600 were from Bainbridge: Steven Albergine (first, 5:16.37, a personal record), Micah Glasby (second, 5:21.28, a personal record), Ethan Glasby (fourth, 5:52.82, a personal record), and Josiah McDaniel (fifth, 6:16.31 a personal record).
Jacob Mathisen set a new personal record (41-05.50) and took first place in the shot put.
Akio Hansen and Casey Langsjoen finished first and second in the triple jump.


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2016-02-03 13:30 - Louzel Lombard
Cape Town - SANParks Honorary Ranger Japie Claassen has spotted the iconic Common Cuckoo in the Karoo National Park, enriching the already abundant birdlife in the park with one more interesting sighting option.
Claassen, from Karoo Birding Safaris, says that while patrolling along the Park's boundary fence on the Loxton Road outside Beaufort West at the end of January, he stumbled across the beautiful Common Cuckoo (Cuculus canorus) and formerly known as the European Cuckoo – the first sighting of this bird in the Park.
The Common Cuckoo has been the centrepiece of cuckoo clocks since the early 1600's – with its signature call striking on the hour, every hour.
Claassen says they are relatively quiet - not heard often in South Africa. They originate in Europe and are seldom seen in the Karoo areas. They feed on large, hairy black and white caterpillars, usually found on Acacia trees.


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The French Social Security System – Family Benefits
Under Section L. 512-1 of the Social Security Code, "any French or foreign person residing in France with one or more dependent children also residing in France, is entitled to family benefits for those children".
Family benefits are awarded to persons acting as the real and ongoing custodian (food, housing, clothes) for legitimate, illegitimate, adopted, or foster children up to the age of:
Finally, a flat-rate allowance is awarded to offset the financial loss incurred by families with three or more children when the eldest child reaches the age of 20. This is paid for a maximum of one year.
Formula used for the calculation of family benefits: family benefits are calculated as a percentage of the monthly family benefit base (BMAF). The BMAF is currently set at €407.84 as of April 1st, 2017. The BMAF is uprated on 1st April each year in line with the anticipated change in the average annual consumer price index excluding tobacco.
Family benefits include:
Family benefits are paid from the 2nd dependent child residing in France. They are paid without any employment criteria. As from July 1, 2015, family benefit rates are based on the income of the household or person with dependent children (See amounts in the appendix).
This allowance is payable to families with at least 3 dependent children whose child benefit is reduced when one of the children reaches the age of 20 (the age limit for child benefit) and is not earning more than €907.19 in monthly income. To qualify, the family must be entitled to child benefit for at least 3 children, including the child who has reached their twentieth birthday. The allowance is paid on behalf of the concerned child for a period of 12 months, beginning on the first day of the month of the child's 20th birthday up to the month preceding their 21st birthday.
The monthly rate of this allowance is €82.52 as of April 1st, 2017. Essentially, as for family benefits, this amount is divided by 2 or by 4 depending on household income (year N-2). However, a supplement can be paid on a sliding scale if household income for calendar year N-2 is slightly higher than the applicable income ceiling.
This is a means-tested benefit payable to families with at least 3 children aged between 3 and 21 years. The income ceiling varies based on number of dependent children and household makeup. To be eligible for this benefit in 2017, net household income in 2015 must not have exceeded:
The amount of the family supplement comes to either €169.87 or €237.89 per month (amounts applicable as from April 1st, 2017) based on income bracket. The amount is the same whether the family has 3 dependent children or more.
This allowance is a non means-tested allowance payable for any dependent child under the age of 20 who has lost a parent, any child not regarded as a legitimate child of either or both parents, or any child whose mother and/or father fail(s) to provide adequate support. If the child works, his/her net monthly income must not exceed €907.19.
This allowance comes to:
The various benefits to offset the costs due to the arrival of a child and help pay for the cost of childcare are grouped together under the early childhood benefit program (Paje).
Early childhood benefits include:
This means-tested allowance is paid at birth or upon the adoption of a child under 20 years of age. The amount of the grant is €927.71 for a birth and €1,855.42 for an adoption. It is intended to cover the expenses related to the birth or adoption of a child.
To qualify, the expectant mother must prove that she has submitted to the first routine prenatal examination performed during the first 14 weeks of pregnancy. The income ceiling depends on the number of children in the family and the number of babies expected. The ceiling is higher when both parents are working and for single parents. As of 1st January 2017, the family's annual income for 2015 must not exceed €35,872 for a family expecting one child or €45,575 for two working parents or a single parent.
The basic allowance helps with the child's maintenance and educational expenses and is paid after the birth/adoption grant. It is a means-tested benefit (the income ceilings being the same as those for the birth grant) paid from the date of the child's birth to the last day of the month preceding their third birthday.
In the case of adoption, the basic allowance is paid during the three years following the child's arrival, provided that the child is under 20 years of age.
As from April 1st, 2017, depending on income, the basic allowance comes to €185.54 at the full rate and €92.77 at the partial rate.
3) Shared child-rearing benefit (PreParE)/ Supplement for free choice of working time (CLCA)*
The shared child-rearing benefit (granted for children born or adopted from 2015) and the supplement for free choice of working time (granted for children born or adopted prior to 2015) are not means-tested and are intended to allow a parent to stop working or work less in order to look after their child. These two benefits can be paid separately or, when the parent fulfils the income conditions, on top of the basic allowance.
They are payable from the first child and are conditional on the parent having accrued 8 quarters of old-age insurance over:
Duration of Benefits
The shared child-rearing benefit (PreParE) is paid to each parent for 6 months for a first child, 24 months to each parent for a second child and 48 months for any additional children.
The supplement for free choice of working time (CLCA) is paid for 6 months for a first child and up to the 3rd birthday for a second child and any additional children.
The monthly amount of the PreParE/ CLCA (from April 1st, 2017 to March 31st, 2018) comes to:
For adopted children, the supplement for free choice of working time is paid for a minimum period of one year - even for children over three - and up to the age of 20.
*The supplement for free choice of working time (CLCA) only applies to children born or adopted prior to 1st January 2015.
4) Supplement for free choice of childcare (Complément de libre choix du mode de garde - CMG)
The CMG is paid to a couple or parent using the services of a registered childminder or a childminder in the home to care for a child under age 6. It is awarded either as a separate benefit or, if the parent(s) fulfil(s) the income conditions, on top of the basic allowance.
This benefit includes:
1) Education allowance for a disabled child (Allocation d'éducation de l'enfant handicapé/ AEEH)
The education allowance for a disabled child is a non-means tested allowance paid to parents of a severely disabled child under 20 years of age (regardless of the child's order of birth in relation to their siblings) and with a permanent disability rating of at least 80%, or between 50% and 80% if the child is in institutional care or receives care at home.
This allowance is not payable for children placed in residential schools, for which all costs are paid by the health insurance system, the state or social welfare.
The amount of the allowance is €130.51 per month. Children with a disability rating of at least 80% are eligible for an allowance supplement, the amount of which varies according to their needs or degree of disability. To determine the amount of the supplement, the child's condition is classified by a Committee for the Rights and Self-dependency of Disabled Persons (CDAPH) in one of six categories, using a rating scale that assesses the special care needs and costs, the financial consequences arising from the disability and/or loss of income for a parent staying at home to look after the child, and the need for a paid carer.
The monthly amounts of the supplement (from April 1st, 2017 to March 31st, 2018) are as follows:
On a category-by-category basis, this top-up comes to:
AEEH is awarded for a period of 1 to 5 years, depending on the child's state of health. This period can be extended if the child's disability is not expected to improve.
Families claiming basic Aeeh can choose:
For more information on the disability compensation benefit (PCH), visit the website of the National Solidarity Fund for Autonomy (Caisse nationale de solidarité pour l'autonomie).
This means-tested allowance is payable for any child enrolled in school and between the ages of 6 and 18. The amount payable depends on the age of the child to reflect actual needs.
The allowance is payable to families or persons whose income is below a certain level (upper limits vary based on family makeup and number of dependent children). It is paid as a lump sum in August of each year. If the family's income is below the assessment ceiling, the allowance is paid at the full rate. If the family income is slightly above the assessment ceiling and below another limit decided by government order, a supplemental allowance is paid.
The full-rate allowance for fall 2017 is:
3) Daily parental attendance allowance (Allocation journalière de présence parentale/ AJPP)
The daily parental attendance allowance is paid to any person looking after a child under 20 and suffering from a disease or severe handicap requiring constant assistance and attendance. To qualify, the beneficiary must be obliged to take time off work and be granted parent's attendance leave. A doctor's certificate attesting to the child's medical condition must be furnished to the medical board of the relevant Health Insurance Fund.
The amount of the daily allowance is €43.35 if the beneficiary is part of a couple and €51.51 for a single parent. It is paid for each day of leave from work, up to a maximum of 22 days per month.
The beneficiary is entitled to 310 days of paid leave, paid on a daily basis and to be taken over a three-year period depending on the child's needs.
If the monthly expenses necessitated by the child's condition exceed €110.89, a supplement of €110.89 is payable to families on incomes below a certain level, on production of the relevant receipts.
4) Family housing allowance
This allowance is a family benefit intended to help families pay their housing costs. Payment of the allowance is contingent on the characteristics of the property in which the family is housed (surface area and conditions), the rent paid and the family's income.
The moving allowance is a means-tested benefit payable to families with at least 3 children and who are entitled to housing benefits for their new home. The bonus is equal to the actual moving expenses. The maximum amount of this award is €978.82 for families with 3 children, plus €81.57 for each additional child.
Important information: All family benefits, except the special education allowance (AEEH), are subject to a 0.5% CRDS tax. The tax is collected directly by the Family Benefit Funds.
For more information, visit the CAF website.
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Gavin Williamson, MP for South Staffordshire, officially opened the refurbished clubhouse at Essington Rugby Club recently.
The opening coincided the beginning of the Rugby World Cup when England faced Fiji and triumphed 35-11.
Gavin gave a speech to players and supporters of the club who had gathered to watch the beginning of the World Cup Campaign and see the unveiling of the club house for the first time since its refurbishment.
The club is a centre for the community, not only providing a home for rugby, but also is used by a local dog club, karate club and also used for family events such as birthdays and engagements. The clubhouse has also hosted a number of charity events in the past few years, such as Sport Relief.
The club signed the lease on the facility in early 2008 which means that solid plans to upgrade the grounds, club house and facilities can be put in motion. In addition, the signing of the lease means the club can apply for support from the RFU and develop the facility into a greater resource for rugby and the community.
After opening the club house Gavin said: "I had a fantastic time at Essington Rugby Club. It was brilliant to see so many players so enthusiastic about the sport and the World Cup. The work that the club puts into the community is so important to promote and enjoy the game of rugby in a safe and happy environment. I look forward to hearing more about their success of the club in the future."


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An Australian pedophile, who was caught filming himself torturing, raping and killing children before sending the videos of his sick crimes to pedophile ring around the world, may have the death penalty reintroduced, just for him. 54-year-old Peter Gerard Scully is currently held in a Philippine prison charged with some of the vilest acts known to humanity. The father of two from Melbourne has been described as the "world's most depraved pedophile" after investigators had to receive counseling after reviewing evidence in the cases against him. His crimes are so severe in fact, that the Filipino legislators are working with Australian government officials lift the maximum penalty for his crimes so the courts can execute him. Scully was selling extreme child pornography through a darknet website he was running called "No Limits Fun" where he was live streaming the death, rape, and torture of children to elite pedophiles around the globe for $10,000 per view.
Read more at: http://www.neonnettle.com/features/1268-death-penalty-to-be-reintroduced-for-world-s-worst-child-torturing-pedophile
© Neon Nettle