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The Rubik’s Cube was just the beginning. Then came Cabbage Patch Kids (and Garbage Pail Kids), Trivial Pursuit, Transformers, Barney, Teenage Mutant Ninja Turtles, My Little Pony, Beanie Babies, and Pokémon, and many more along the way. One main offer per year. They went viral before it meant anything. The debate has always been, “Did the marketers force us to use these products or did the consumers go out in full force on their own without the help of the commercials?” Marketing geniuses, when they are lucky, like to point out their own efforts, otherwise how would they get the jobs? Consumers say they made the decision themselves. It’s probably a combination of the two, with a little more emphasis on marketing influences.

Then we come to the new Christmas season. New toys. New tricks. New products. “Which of these new toys is going to go viral?” is the billion dollar question that I would love to know the answer to. Even if they did well on a product for a year, they could be retired tomorrow.

Two toys from the 2016 shopping season seem to be making a comeback on the 2017 market: Fingerlings and Hatchimals.

Fingerlings are essentially puppets that wrap around the finger. They are small, cute, and fun for children under the age of seven or eight. Perhaps there will even be a branch for parents like My Little Pony had her Bronies. Yes, we hope not.

Hatchimal creatures start inside a large egg. When your child plays with the egg long enough, it hatches and a furry creature hatches. But it doesn’t end there. Talk, walk and dance. Your child should be able to nurture him during the infant, toddler, and toddler stages. (Sorry, no adolescent or adult stages)

So you are buying a pig in a shove, so to speak, it hatches and needs to be cared for in much the same way as the Tamagotchi digital pets from a few years ago. This year’s offer is called Surprise! You’ll get two eggs for the price of probably one and a half. Double the fun at less than double the cost. However, to be fair, they are cute creatures and your kids could spend a lot of time with them.

Marketers appear to be pushing these two toys this year, but no one can guess which toy will dominate the market. In fact, the market is ready for three or four viral toys.

We would like to think that we are stronger than ourselves and more emotionally stable than the next person, however that would be difficult to prove. Furthermore, it would be hard to believe. We all carry luggage and problems in our past that occasionally make us feel shaky and shaken.

There are very few of us who can honestly say that we are as stable and strong as we seem, for the rest of us it is a daily battle to find that balance. When people enter therapy it is for a reason, there is something in their lives that has become unmanageable. There is something that has been pressing under your skin like a splinter that has embedded itself and now it is an infection.

What is that splinter whose mucous pus is causing us so much pain in life? PERSONS! It is usually a person or a group of people. It’s amazing how much power we give others over ourselves. It never ceases to amaze me how we allow others to create fear and anxiety to such levels that we cannot function or become dysfunctional.

Dysfunctional is the clinical term for when our Begin’s engine is malfunctioning and some oil and TLC are needed. When we have allowed the action and behavior of ourselves and others to cause friction in different areas of our life, such as school, work, friendships, family, spirituality and health. We begin to throw stones at our engine, when we have built barriers or have poor boundaries with others.

We all have a personal limit, it is an imaginary line that surrounds you and protects you from situations and peoples by which you feel threatened. When the threat is real, this limit is essential for our survival, but sometimes the threats are not what they seem. Our past can make us imagine threats that do not exist, when we have learned to distrust and that everyone is an enemy.

When we have a hard time trusting, we see treats that aren’t always there. Our boundaries soon became barriers or walls that are likely causing us harm rather than providing protection. As children, we are not always taught healthy boundaries and are forced to allow people to come closer than we are comfortable with. We may have felt that those we have allowed to get close to took over our inner thoughts and feelings, abusing the lines that protect us, our limits.

As children we learn in situations like these, where personal limits were not respected, to build walls in their place. A learned situation could be something like your parents wanting to know if you are gay because of behaviors they have noticed, or being forced to date a guy to show you candor, but it could also be something as destructive as sexual or physical abuse. In any of these cases we will probably build walls as a coping mechanism.

Unfortunately, as we age, tools, like building excellent walls to survive the helplessness of childhood, became weapons in adulthood. If we cannot let our lover in and trust her, she will never feel like she is in a committed relationship and there will be no intimacy. I have noticed in my own past and hearing stories from my clients that when we have walls we are not emotionally available. For most of us it has been a life-long experience that we have not been aware of this tapping process. Chances are, you heard your partner call you “distant” or you felt a need for your partner that never seems to be satisfied.

When we are not emotionally available, we cannot commit and we also attract the emotionally needy. Human dynamics is an extraordinary thing where the magnets in our soul attract people who will continue to push the unruly monster within us as we will for them.

Here are some key steps to developing healthy boundaries:

1. Learn when others are not respecting your limits, for example when people are: too entangled, dissociated, there is excessive detachment, victimized or martyred, distanced or shy, cold and distant, always in your face / suffocation, and gift ‘Don’t respect their privacy.

2. Why do you let others do these things to you? Chances are, you have thoughts or ideas that you deserve it or that you are to blame in some way. At this stage, it is recommended to consult a therapist to help you overcome these maladaptive thoughts and the harmful self-confidence system.

3. Trade the old for the new! Get some healthier ideas and think to yourself if something isn’t working for you, let it go and try something new. For example, go from “maybe I deserve this abuse” to “I want people to respect me. I want a supportive partner.”

4. Identify behaviors that will help you stay healthy, for example, learn to say “NO” and “thank you but no thank you.”

5. Be consistent once you have decided to change. You have identified how to do it, now do it in all areas of your life. Remember that being healthy is a skill, so the more you do it, the more competent you will become. So practice!

You deserve the life you want and you deserve to be happy. Don’t let anyone treat you less.

Alex Karydi ~ The Lesbian Guru

Into Sports Betting

The Seneca Gaming Corporation is expanding into the New York sports betting market and plans to open a sports lounge inside the KeyBank Center. The Buffalo Bills have partnered with Seneca to offer their own sportsbook, which will be the exclusive partner of the franchise. The Buffalo Bills’ sportsbook is located at the del Lago Resort Casino. You can enjoy great odds at this New York sportsbook, where you can watch games from your favorite chair or even place a bet.

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The Seneca Gaming Corporation accepts only cash and validated wagering tickets for wagering. While electronic wagers are not currently accepted, they are being considered as legal at this time. Regardless of where you’re located, you’ll want to make sure you’re familiar with the sports betting regulations in NY. By following these guidelines, you can enjoy an enjoyable experience at the Seneca. While it’s not the only way to place a bet, it’s still worth looking into.

In addition to a sportsbook, Seneca Gaming Corporation also offers online betting. While this is a great option for players in New York, you’ll also be able to wager on games from anywhere else in the world. The Seneca’s mobile app will allow you to place bets legally, while on the go. Unlike the casino’s desktop site, the app will provide you with instant access to betting options wherever you may be.

Seneca Gaming Corporation Expands Into Sports Betting

In addition to the casino’s online sportsbook, Seneca Gaming Corporation has recently announced the creation of a sportsbook at its Point Place and Turning Stone resorts in Oneida. While these casinos are a long way away from opening, both are expected to open their doors by the end of the year. If the state approves sports betting, Seneca will be able to expand its online betting operations.

Despite the potential benefits of sports betting at Seneca casinos, the potential for losses in the industry is limited. It will be a small percentage of revenues, but it will be worth it for the casino to be able to cover the costs of advertising. If the casino is successful, it will be profitable. In fact, the Seneca gaming corporation will employ up to 100 new employees in the sportsbook industry.

If the state legalizes sports betting, Seneca will move into the online market. The casino will operate as a separate entity. The Seneca Gaming Corporation will control the sports betting operations at the casino. In addition, the Seneca has an agreement with Kambi. The two companies will supply the casinos with the sportsbook technology. Bragg will provide the casino management software and player account management systems. The casino’s online presence will allow it to expand in New York state, which is expected to happen as early as next year.

Find Povidone Iodine Nasal and Throat Spray

Povidone iodine nasal and throat spray is used to treat sinus infections. In India, it is the primary treatment of COVID-19. This medicine is not used for other purposes such as treating colds or flu. Nevertheless, the family has been using it for years. While the children in their family are fully vaccinated, their grandmother is not, and is unable to wait for vaccinations. Many hospitals in this region are experiencing severe shortages of vaccines and have to rely on the treatment of a patient.

A study published in JAMA showed that Povidone iodine nasal spray and throat spray works against the SARS-CoV-2 virus. Another letter to the Editor in the Journal of Otolaryngology-Head & Neck Surgery suggested that the spray be applied to the upper aerodigestive tract to treat SARS. Although this solution has been widely used for 20 years, research has shown that the treatment is not completely effective unless it reaches the nasopharynx. The ciliated cells of the nasopharynx have a receptor called ACE2, which is used by a novel coronavirus that can enter these cells and spread to the lungs.

The newest JAMA study looked at the anti-bacterial activity of povidone iodine nasal spray, as well as a study in humans that suggested that the spray should be applied to the upper aerodigestive tract. The nasopharynx is a complex area, and getting the solution to the nasopharynx is essential to the efficacy of the medication. The solution works on the surface receptor called ACE2 on the ciliated cells. This receptor is the same one that is used by a new type of coronavirus that uses the same receptor to spread infection.

How to Find Povidone Iodine Nasal and Throat Spray

A spray containing povidone iodine can cause skin and fabric stains. It can also stain teeth and fabrics. Unlike the vaccine, povidone iodine is a natural product that can cause a rash. It can irritate the lungs and may also trigger an allergic reaction. If you have a sore throat, Povidone iodine nasal and throat spray can be a good choice.

The use of povidone iodine nasal spray has been proven to reduce the risk of SARS in humans. It is also effective in preventing the spread of SARS-CoV-2. Researchers studied the effects of povidone iodine on the SARS-CoV-2 virus. Despite its broad spectrum effect, this antibiotic is recommended for people with a history of SARS.

This antibiotic has antimicrobial properties. It works against viruses, bacteria, and fungi. Intranasal preparations against MRSA have shown promising results. The antimicrobial effect of povidone iodine nasal spray on SARS has been studied for over 20 years. In vitro tests have shown that it has antiviral properties and is effective in preventing SARS.

When I search for information about something, I just type the word or phrase into Google and can usually find what I’m looking for on the first few pages of results. When I wrote “Healthy Dinner Recipes,” I was overwhelmed. Of course, there were a lot of results, so I clicked on the first one and got a list of dishes:

Appetizers, Drinks, Breakfasts, Sweets and Delights, Starters, Healthy Cookies, Cakes and Baked … Wraps, Sandwiches and Burgers.

The word ‘dinner’ doesn’t even appear, and looking at some of the foods, they didn’t even seem that healthy to me. The next site I tried was actually better, although I had to scan a lot of recipes to find something that appealed to me.

Criteria for a healthy recipe

If you’re like me, time is precious, so I have to find what I need pretty quickly. Unfortunately, when it comes to finding healthy dinner recipe ideas, you still have a lot to do. I try to scan the recipe and discard the ones that don’t meet my basic criteria for a healthy dinner. These are the things I look for when selecting a suitable dinner recipe:

– a generous helping of mixed greens

– a protein source such as lean meat, fish, or beans

– a carbohydrate source such as potatoes or brown rice.

Whole wheat bread, brown rice, and whole wheat pasta are healthier options than the white varieties. A green salad is always a healthy option.

If you are a vegetarian it is much easier to find a healthy recipe. However, what to look for is an adequate source of protein. Soy is a good alternative to meat, but it should be eaten in moderation. The Harvard School of Public Health has a good article on protein on their website. (http://www.hsph.harvard.edu/nutritionsource/protein.html).

Other sources

So where else can you find healthy food recipes? Another good online source is Amazon.com. If you search for the keyword ‘healthy dinner recipes’ you’ll find a lot of books listed (of course, this won’t help you make dinner tonight!). The only thing to keep in mind is that many of these books focus on weight loss diets, which are not necessarily good for you in the long run. However, Amazon is a good source of information.

If you have children, it is especially difficult to find nutritious and attractive recipes for them. This problem is compounded if you are trying to change your family’s eating habits. The CDC website (http://www.cdc.gov/nccdphp/dnpa/nutrition/nutrition_for_everyone/quick_tips/healthy_children.htm) has good information on preparing healthy dinners for children.

conclusion

In conclusion, there is a ton of information available, but trying to focus on the best healthy dinner recipes for you and your family will take time. You also need to be prepared to make a lot of changes until you find something that works for everyone. I used to joke about our children’s reaction to some of my dishes (Lima bean soup comes to mind) – if they don’t like it, it must be good for you!

However, seriously, there are plenty of good healthy dinner recipes available that everyone will love. You just need to be able to spend the time to find them and experiment a little in the kitchen.

Considering the RUP, there are four phases of the life cycle of a project: initiation, elaboration, construction and transition. As an OBIEE developer, you will work primarily during the design, development, testing, and implementation phase. Sometimes there is participation in the requirements gathering phase, but there is more scope to work on refining the requirements.

You can define the life cycle of the OBIEE project as follows:

The startup / initiation phase: creation of a business case, project planning and feasibility study.

The development / planning phase: resource planning, requirements gathering and analysis

The execution / development phase: Design and development. This is where I worked the most as an OBIEE developer.

The transition / closure phase: implementation, operations and maintenance.

The normal software development life cycle is also very similar to this.

These are the default steps in SDLC:

• Study of the system

• System design

• Software development

• Implementation of the system

System design:

• Known as the “How” phase, the system design determines how to implement the system study solutions. This involves:

Exit requirements:

Determine the output medium, such as printed or soft output.

Entry requirements:

Exit is determined first as it dictates entry requirements.

Determine the input source, such as databases, data entry by keyboard, mouse or screens (monitors), data filtering, voice, data communications, etc.

Storage requirements:

Define the databases.

Records and fields

System controls and backup:

Determine “the scenarios that can go wrong.”

Unauthorized access, determine security measures for software and hardware.

Lost or damaged databases (bank vaults of information), determine the backup on the site.

Disasters, determine off-site database storage, computer processing, and communications network backups (AT&T, MCI, and Sprint).

• Develop system specifications for programmers.

Software development:

• Build software programs according to design specifications.

Make or by decision.

Write programs in-house or purchase software packages.

Purchase Considerations:

Customization – Programs you write will meet or exceed design specifications. On the other hand, software packages need to be customized to meet your specifications.

Extensive customization should be avoided for two reasons. First, it is expensive and time consuming. Second, implementing software package patches requires customization changes to be reapplied, which in some cases is not easily accommodated.

Reengineering – An alternative to customization in which the company changes its procedures to meet the specifications of the software package.

Note: The SDLC must be completed regardless of the purchase or deed decision.

System implementation:

• Test the system.

Alpha tests until the system stabilizes.

Beta testing by system users.

“What if” tests by the system analyst.

• Fill in the databases.

• Develop procedures for the user.

• Train users.

• Some approaches to powering up the system:

Direct – Shut down the old system and start the new system.

Parallel – Run the old and new systems side by side until the new system has proven to be reliable. It should be avoided when there are not enough users to keep both systems running.

Phased: parts of the new system are phased in separately.

Pilot: the system is used by a limited number of users such as a department, a district, a region, etc.

Lake Kariba in Zambia is the largest man-made lake in the world. Completed in 1959, it was designed to provide hydroelectric power to Zambia and Zimbabwe. 280 km of river became a huge 5200 km2 lake! Chete Island appears from Lake Kariba. Historically, the construction of Lake Kariba was surrounded by much debate: thousands of BaTonga villagers were immediately displaced and much of the wildlife drowned despite the initiative of ‘Operation Noah’ to save and relocate the animals to as the waters rose. However, that was fifty years ago and today the lake is home to rich aquatic and fish life, and its shores are rich in wildlife and beauty. This is a place to fish, a place to quietly relax in amazing natural surroundings, and a place to come on safari, a kind of three-for-one experience!

Chete Island is a private wildlife reserve and bird sanctuary and is the largest island in the lake (27 km2). It’s a remote southern island, very isolated except for the glimpse of kapenta (Limnothrissa miodon) fishing gear in the distance.

Known as a “wild water wilderness”, this is a place where game and birds thrive, fully protected and unadulterated. Despite the small size of the island, their game is not tame. Although populations are not as dense here as they are in other Zambian national parks (Luangwa and some areas of Kafue), animal sightings are still exciting here.

There are

• a resident herd of elephants of around 80-100,
• a pride of lions
• possibly half a dozen leopards
• a herd of eland
• lots of impala, waterbuck and bushbuck
• some kudu
• a wide variety of birds: 378 species recorded to date
• And of course lots of crocodiles and hippos!

The island has a feeling of solitude, charm and nature that only a wild island can give. Away from the adrenaline junkie motor boats of the shores of Lake Kariba, this remote island is largely unknown and virtually unvisited by the tourist world.

Some would define solitude as paradise, but for those wanting a bit of action, activities are another optional ingredient.

• Hikes with an island guide are an obvious and must-see experience
• Bird watching will happen by accident, but an organized session can be arranged.
• Since it’s surrounded by water, bird watching and canoeing takes another twist.
• Many have said that lake water fishing is worth a trip here on its own.
• And sunset and boat cruises will relax your mind and body, like it or not!

Chete Island offers a luxurious tent camp with only 8 Meru style tents. A place where elephants choose to roam idly, where the unforgettable sound of the bellowing of hippos travels across the bay and where the magnificent African sunset amazes the few visitors who are lucky enough to ever step here.

Note: If you want to publish this article on your website, blog, etc. you can do so as long as the article remains in its entirety; including links and author’s resource box.

According to The Washington Post; “A record 7 million Americans are 3 months behind on their car payments,” February 2019. That title says it all. In other words, if you file for bankruptcy and haven’t paid your car payments, but you still want to keep your car, you are not alone.

The Credit Union Journal has a recent article in the May 2019 issue titled; “By avoiding subprime auto loans, are credit unions shunning their roots?” It turns out that auto loan defaults are once again at all-time highs. This is a problem nationally for lenders, and not just locally here in Ventura County or Los Angeles County.

There are legal remedies that you can implement to prevent your car from being repossessed. Many consumers do not realize that under Chapter 7 and Chapter 13 Bankruptcy Law you can temporarily prevent recovery by your lender. This is because during bankruptcy proceedings, the court issues an “Automatic Stay” that prohibits and prevents the lender from repossessing your car. The lender can ask the court to remove the ‘automatic stay’ and, if the court agrees, the lender can take possession of the car anyway, but this temporary stay may be all it takes to get the lender’s attention to work. with you and your attorney on a modified payment plan.

The best way to deal with this situation is to be in contact with your car lender, and it is better to do it through a bankruptcy attorney, it carries more weight. It also prevents the lender from trying to intimidate you. Your attorney can renegotiate the terms and help you establish a new payment structure, which will allow you to keep your car in bankruptcy.

Consider if you want lenders to really not want to repossess cars, they are not in the auto business, they are in the loan business, they just want to get paid, based on the original agreement. If they realize that this is not going to happen, they will weigh their options and consider what is best for them. Perhaps a reduced interest rate, a reduced balance, or renegotiated terms are better for the lender than a salvaged used car with a low resale market value due to wear and tear and depreciation. Face it, lenders don’t want to lose more money than is absolutely necessary.

Another important point that you must remember; The ‘automatic stay of bankruptcy’ is only temporary, and if you haven’t made the payments on time, once your case is closed, you can expect the lender to demand the return of the car or to get it back. Also note that the suspension is only valid during the bankruptcy process, which for Chapter 7 lasts about 3 months.

What is the best way to prevent a car repossession during bankruptcy proceedings?

• Make payments

• Get back your late payment

• Make a payment plan, ask the court to approve it

• Stay in touch with the lender through your attorney.

• Ask for help maybe paying interest for just a couple of payments

• Renegotiate the car loan

• Ask the court if you can buy your car back for its fair market value (Trade in your car under Chapter 7 of the Bankruptcy Law).

• Ask Your Bankruptcy Attorney About Chapter 13 Bankruptcy “ Reduction ” Strategies

What can you do if your car is repossessed before your bankruptcy date?

Ask your bankruptcy attorney to help you develop a payment plan so that the lender can receive late payments. If this has happened to you, and your car has already been repossessed, don’t delay. Call Your Bankruptcy Attorney Now! That is probably the best advice of all.

Summing everything up!

You need to know your rights and understand your lender’s motivations. You need a good solid bankruptcy attorney to work for you, one who has dealt with the local lenders here in Ventura and Los Angeles County. An attorney who succeeds and has decades of experience. With the right strategy, you can keep your car, avoid humiliation, and avoid losing your transportation. After all, we live in California and you need a car.

Headlights are probably the most fundamental part of a car, along with the wheels and engines. From the very first vehicle released by Karl Benz to this day, all cars have had headlights. But the days of reflective halogen headlights are over. Now, thanks to more and more advanced technological innovations, the market has been flooded with all new types of headlights, from high intensity discharge lamps, also known as HIDs, to LED headlights and now laser lights, as seen on newer Audi, BMW. and even Mercedes.

Let me guide you through the bewildering array of headlights, outlining the pros and cons of each, so I can help you justify which one best suits your driving needs.

HALOGEN

Ah, the good old reliable halogen headlight. It has been a familiar sight in many cars, both old and new. I can list ten makes and models that still use halogens in their vehicles, just at the top of my head. And there’s good reason it’s still in use, even in this age of high-tech light sources. It is cheap. Halogens cost less than HID bulbs on average, both to replace and repair. They also provide one of the best high beam lengths of any other light source, making them a preferred bulb for those who live in the country. Now, the cons. Halogens may have great high beam capabilities, but their low beams are particularly poor, especially compared to newer types of headlights. All halogen lighting patterns are scattered and sometimes they rarely focus on the road, which means they often lose focus on what they are supposed to illuminate. Note that with HID bulbs, they often have sharp cuts, rather than shining the light all over the place. Low beams also have an incredibly low light range, making them a real problem in dark areas of the state.

HIGH INTENSITY DISCHARGE (HID)

Now don’t get me wrong. I love all lighthouses equally. I’m not picking any favorites … but with that said though, if I had to pick a favorite, it would be the HID headlights. It may not be your favorite (I think you’re wrong, but hey, free country) but I definitely love HIDs. These newly developed headlights were once the stuff of high-end German vehicles. As an example, the first HID headlights fitted to a conventional vehicle were the $ 300,000 AUD BMW 750il, and even then it was an optional extra! Soon these headlights started to fall on more mainstream and affordable cars, like the Toyota Camry, the Honda Civic, you name it. HID lights are preferred by many manufacturers as they often take up less space than normal halogen lights, provide better range and visibility at night, and focus the light source on the road, without excessive interference or light scattering. Its minimal space also allows car designers more flexibility with the contours and shapes of the vehicle. These lights are also praised by other drivers, who find that the more focused beam on the road means they have fewer people blinding them at night. These bulbs are also the first port of call with adaptive cornering headlights, the lights that come on when the steering wheel is turned. Since the rays are so focused and the housing is incredibly small, it has allowed many vehicles to be equipped with cornering headlights. However, HIDs are not without their problems. First of all, they are expensive to repair. Despite being more energy efficient and consuming less energy, they are generally more expensive and difficult to replace or perform a bulb change. Second, they are known for their less-than-perfect high-beam quality, with the light somewhat dull and restricted.

Before moving on to the next lighthouse shape, a quick note. While many may see an HID unit, it is worth mentioning that they come in two different bulbs. One, which is used primarily in many vehicles today, is Bi-Xenon HID bulbs. These bulbs contain an industry standard 4300K ​​lighting, but many of the aforementioned affordable vehicles (Toyota Camry and Honda Civic) contain only HID halogen bulbs. Bi-Xonnes are the most preferred, as their light source adapts better to the color of natural light or, better yet, to bright white.

Led

Like Uber’s high-end luxury barges of the 1990s, LED headlights have been considered just a feature of higher-end German vehicles. The first vehicle to offer it was the Lexus LS600hL, before it was featured in the Audi A8 flagship and the BMW 7 Series, and now it has reached the most affordable cars, such as the Honda Accord, Subaru Liberty and Toyota. CH-R. LED headlights, while they have a fantastic range for both low-beam and high-beam headlights, are undoubtedly expensive to replace and repair. However, as the market becomes more and more diluted with manufacturers of LED lights, it will soon become a standard feature in many cars.

LASER HEADLIGHTS

It has damn lasers!

Unfortunately, if you were hoping to live out your James Bond super villain fantasy, you’ll have to keep looking elsewhere. These are not lasers that can shoot and destroy the idiot driving in the outer lane, instead he is doing 10km under the limit. Laser technology has been developed for the use of headlights to provide a longer, brighter and longer range. While they are a relatively new development in the automotive industry, they are already available in higher model offerings from Audi, BMW, Mercedes Benz, and other high-end luxury automakers. It is not difficult to see why laser headlights are becoming popular. Its range helps extend visibility up to 600 meters and has been shown to increase stopping time by up to 5 seconds, which is an incredible amount. While these damn lasers are gaining popularity, it’s worth mentioning that they are incredibly complex pieces of technology, requiring a great deal of time and effort to manufacture. Laser headlights are different from LEDs, HIDs, and halogens in that they generate more heat, which means that they require special cooling fans to keep them at an optimal temperature. Since they are difficult to manufacture, you should expect a hefty repair bill if they decide to buy them. While the theory of laser headlights sounds incredible, it will be quite a while before we see it seep into more mainstream vehicles.

In an editorial on the Supreme Court case eBay v. MercExchange, Los Angeles Times [May 17, B12] set:

[A]n short appeals [the Court of Appeals for the Federal Circuit, “CAFC”] ruled that MercExchange was automatically entitled to a court order against EBay.

In a unanimous ruling, the justices disagreed, not just with the appeals court but with a nearly 100-year Supreme Court precedent on patent law. That case, which arose out of a dispute over paper bag making techniques, held that a court order was mandatory in almost all cases of patent infringement, disproportionately rich license agreements.

On the “nearly 100-year-old” Supreme Court case, Justice Thomas wrote in the unanimous opinion on eBay:

Tea [district] The categorical rule of the court is also in tension with Continental Paper Bag Co. v. Eastern Paper Bag Co., 210 US 405, 422-430, 28 S. Ct. 748, 52 L. Ed. 1122, 1908 Dec. Comm’r Pat. 594 (1908), which rejected the argument that a court of equity does not have jurisdiction to grant injunctive relief to a patent owner who has unreasonably refused to use the patent.

Thomas’ opinion did not disagree with the Continental Paper case, contrary to what the Los Angeles Times said.

The CAFC did not state that MercExchange was automatically entitled to a permanent injunction. The CAFC went through the traditional 4-factor analysis to grant a permanent injunction and disagreed with the district court’s findings. The CAFC was wrong in suggesting that permanent injunctions be issued in the absence of exceptional circumstances.

The Times editorial also noted:

The patent office is also questioning some MercExchange patents, pointing to a fundamental issue that the Supreme Court did not address. The system generates too many bad patents, especially when it comes to business methods. Proposals that would significantly strengthen

the process has been repressed in Congress. Now that the Supreme Court has begun fixing the patent quagmire, lawmakers must finish the job.

On the subject of reexamination, I wrote in the February 2006 issue of Intellectual Property Today:

One of the reasons eBay provided the Supreme Court for the public interest factor in the 4-factor test on injunctions was the uncertain status of the validity of business method patents. In support, eBay’s brief noted that following the district court’s decision, the PTO had declared the claims for US 5,845,265 invalid. [In re-exam 90/006,956, filed by eBay under 37 CFR 1.510 on March 5, 2004, after the district court decision of August 6, 2003 in 275 F.Supp.2d 695, the PTO issued a non-final Office Action (signed on Feb. 11, 2005 but mailed March 24,

2005) rejecting claims 26-29 under 102(e) and claims 1-25 under 103 over US 5,664,111, the same art found not invalidating in the CAFC decision of March 16, 2005 (401 F.3d 1323).] To suggest that this was a more pervasive problem, eBay’s report stated that 74% of the time the PTO finds “the patent invalid” or

restricts claims. The eBay report did not mention that new examinations occur in only a fraction of the percentage of issued patents. The eBay report also quoted Cecil Quillen, 11 Fed. Cir. BJ 1, 3 to “estimate the rate of patent approvals by the PTO at 97%”. Sadly, Quillen and his co-author Ogden Webster never

estimated that the patent approval rate is 97%. Rather, they placed the Grant Rate in the range of 80% to 97%, with the upper limit of 97% invalidated by its recognition in footnote 17 that a patent can be issued from both a continuous application and a the corresponding main application. Although not mentioned in the

In the eBay summary, Quillen and Webster corrected their view of the subsidy rate number estimates the following year (12 Fed. Cir. BJ 35 (2002), discussed in 86 JPTOS 568 (2004)). In eBay’s report, the 97% number is not an accurate representation of what Quillen and Webster said or an accurate statement of the

patent grant fee at the PTO.

An earlier story in the Los Angeles Times had said:

The 9-0 decision in the closely watched case reversed a

court ruling that judges must almost always order the interruption of ordinary activities when it is determined that a company has infringed a valid patent.

The problem here is that only eight judges voted on eBay v. MercExchange.

The Los Angeles Times was wrong on many of the facts in the eBay case, even though it was wrong on matters related to the embryonic stem cell discussion. [Ebert, Lawrence. “Los Angeles Times Article Way Off Base on Stem Cell Issues.” EzineArticles 12 April 2006]