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Integrity and Values Essay

Respectability is an idea of consistency of activities, values, strategies, measures, standards, desires, and results. Barbara Killinger off...

Saturday, May 23, 2020

Energy Is Consumed At Alarming Rates - 1607 Words

Energy is consumed at alarming rates. While humanity has, and still is, received multiple signs the current rate at which humanity uses in unsustainable. Climate change and the increased green house gas emissions are indications that it is time to change the energy wasting habits that humanity has developed. Many of these habits include the monumental amount of energy spent on heating. In 2014, 41% of the U.S.’s total energy consumption stemmed from the heating of residential and commercial spaces.1 Significant amounts of this energy is wasted upon heating empty spaces and inanimate objects. Personal thermal management is a method that has been proposed and put into limited effect. Personal thermal management is managing one’s own temperature rather than wasting energy heating empty space.2 The personal thermal management system should be able to be worn, to maximize the conservation and use of heat for the individual using it. Hsu et. al.’s paper Personal Therm al Management by Metallic Nanowire-Coated Textile discusses the use of fabric coated in a mesh on nanowires.2 This coating of nanowires creates a conductive network that can reflect the heat that the body reflects because the nanowire mesh is so small that the heat that is reflected back rather than escaping through the fabric. Nanowire-coated fabrics also have the ability to conduct heat; giving them the ability to produce heat as well.2 This study compares the effectiveness in heat reflection, and conductivity ofShow MoreRelatedChildhood Obesity Is Becoming A Major Public Health Crisis Essay1375 Words   |  6 Pagesdigestive and cardiovascular diseases as compared to children who are lean (Dehghan, Akhtar-Danesh, Merchant, 2005). The alarming increase in the prevalence of childhood obesity in the United States can be attributed to several factors including diet, physical inactivity, and family influence. What are the causes of childhood obesity? The alarming rise in childhood obesity rates throughout the past years has spurred numerous research studies that seek to determine the factors that predispose childrenRead MoreChildhood Obesity And The Health Of New Zealanders Essay1641 Words   |  7 Pagesand education can affect their weight. The essay finally looks at how the larger environment factors such as media and politics are affecting this crisis, the impact of the business drivers and decisions made by government that impact this alarming health issue. Immediate Environment The immediate environment of a child greatly influences their chances of obesity. This starts from birth. It has been proven that breastfeeding reduces obesity in children, especially those breast fed untilRead MoreObesity : Obesity And Obesity1472 Words   |  6 PagesObesity in our society continues to grow at an alarming rate. America is the richest country but has the largest population of obese people in the world. â€Å"Nearly 36.5% of American’s are obese (Adult Obesity Facts).† It is important to note that obesity is defined as having a Body Mass Index (BMI) of â€Å"30% or more† (The Socioeconomic Causes of Obesity). People become obese over times for many reasons like feeling there is less of a need to exercise and eat healthy. There are also more fast food selectionsRead MoreEffects Of Caffeine On People s Lives927 Words   |  4 Pages Caffeine is a huge part of North American culture, it is consumed in coffee, teas, chocolate, energy drinks and many other goods. Coffee is the main source of caffeine, and is frequently consumed socially. Because people rely on this substance so heavily, its side effects are often speculated. Peop le who tend to consume large amounts of caffeine notice shakiness, nervousness, irritability, and increased heart rate (Whiteman.) However, the positive effects are much greater, and some include decreasedRead MoreVirtual Electrical Panel For Ultra Modern Buildings And Industries Essay1130 Words   |  5 PagesRESEARCH DEVELOPMENT Page 199 A Novel Virtual Electrical Panel for Ultra Modern Buildings and Industries 1. Introduction Now a days, the measurement of power quality components and electrical protection are becoming more complex and costly also. As the rate of different equipments used in modern building and industries are getting costlier. So very efficient and low cost electrical panel system is required which can give continuous monitoring and measurement of power and also it can protect the wholeRead MoreClimate Change And Global Warming1354 Words   |  6 PagesAt the moment, greenhouse gases are entering the atmosphere at an alarming rate, and global warming is more of a problem than most people could ever realize. Climate change, while being a natural occurrence, is happening at an alarming rate because of the amount of greenhouse gas emissions everyone emits in their everyday lives without even knowing it. Luckily, if enough people are aware of the consequences of their actions, the rate of increase in temperature has the potential to slow dramaticallyRead MoreThe Impact of Technology on Our Lives1544 Words   |  6 Pagesthat it has affected and continues to affect society in a negative way. Today more people are working longer hours and utilizing more technology in their everyday life. As a result of these longer hours and increased use of technolog y, more energy is being consumed which negatively impacts the environment. Much of the technology is created to make daily task more efficient. The internet for instance, paying bills online, reading the daily news and shopping all without leaving home. Technology is amazing;Read MoreThe Causes for Climatic Changes 1121 Words   |  4 PagesAgency (USEPA), the earth is heating up and its average temperature has increased by almost 1.4 degrees Fahrenheit over the past century. This might not seem like a big change, but if we know the effects of this rise in temperature it would seem alarming. This slight increase in global temperatures has resulted in noticeable changes in rainfall which resulted in more floods, droughts or intense rain and also severe and frequent heat waves. Glaciers and oceans have seen a greater change due to thisRead MoreBenefits Of Plastic Water Bottles1003 Words   |  5 PagesApproximately 50 million plastic water bottles are consumed each year, using more than 17 million barrels of oil in America alone (BantheBottle). This shocking statistic may not seem like a great deal, but considering plastic water bottle sales have increased annually since their creation, alarming factors are starting to arise. Not only do they bring forth health hazards, they are also threatening to the environment, as only 23% of the bottles are recycled, creating tons of excessive wastes (BantheBottle)Read MoreTechnology Is The Most Advanced Species On Earth Essay1305 Words   |  6 Pagesthis success, there lies a serious issue: most technology must sustain the exponential growth of Earth’s population and must be powered by finite resources. Incidentally, the rapid increase of our population is depleting finite resources at critical rates. Are we capable of innovating technology that can accommodate more people while simultaneously limiting resource draining? Earth’s population has grown so much in a short period of time that technology has been improved immensely to sustain much larger

Tuesday, May 12, 2020

Psy Human Growth And Development - 1488 Words

Human Growth and Development Name: Institution Affiliation: Human Growth and Development Introduction According to Jean Piaget’s theory of Cognitive Development children’s cognitive development formal operations is established at the cognitive development stage of about age 12 to 15 years. This is reflected in the child’s ability to reason adolescence hypothetically and independently on concrete states of affairs, with the structures represented by the logical combination systems. The rates at which children will progress through the development succession developed by Piaget may vary from one culture to the other; in addition, different children vary in terms of the areas of functioning to which they do apply their†¦show more content†¦At this point Ponyboy does not understand why Darrel shouts at him, causing a misunderstanding between the brothers portraying Ponyboy’s egocentrism. He regards Darrel with his own way of thinking, failing to understand him from Darrel point of view. Darrel sacrifices everything to see to it that Ponyboy is succes sful in life, and believes Ponyboy will never fail to live up to his expectations, however, all these is beyond Ponyboy’s understanding (Ford, 1983). According Shi (2014), Ponyboy’s egocentrism seem to be cast off when the brothers are reunited in the hospital. Ponyboy sees Darrel crying with tears rolling downs his chicks, and he realizes all over sadden that Darrel does care about him as he is trying too hard to make something of his younger brother Ponyboy. It is at this point that Ponyboy accomplishes the task of de-egocentricity through the realization of the importance of understanding others. During this transformation, Ponyboy undergoes a great deal of frustration, by which he realizes the significance of understanding others. With the casting off of his bias against his brother, he manages to distinguish his thinking on his own thoughts, from the thinking about the thoughts of his brother in the process comprehending his brother’s viewpoint. Ponyboyâ₠¬â„¢s egocentrism gives rise to the breakdown of Soda his second brother in the film. Ponyboy might have loved Soda more than anybody else in their family; however, heShow MoreRelatedPsy / 280 Human Growth And Development1029 Words   |  5 PagesDeondra Braden January 19, 2015 PSY/280 Human Growth and Development Human Development Paper As a human race, in most circumstances we all go through similar stages of development. What most also be taken into account when assessing development is our ranging variations of individualism. Our individual development is subject to a never ending list on influences. Some influences we are born with and some are due to our own life experiences. Our personality comes from all that we are; weRead MoreMy Long Term Educational And Professional Goals952 Words   |  4 Pagesprimary setting. There are several ways in which the courses I have taken at Central Washington University have influenced personal growth for my educational goals. First, taking PSY 300 research methods, PSY 362 introductory statistics and participating in directed research has contributed immensely to my personal growth. Writing a research proposal in PSY 300 was very beneficial. I learned the different methods for specific types of research. This can help me in a couple different areas inRead MoreHuman Development Paper854 Words   |  4 Pages Human Development James West PSY/280 September 26 2012 Robert Keele Human Development Human growth and development starts from the moment a child is conceived and continues until the day we die. There are many different stages of development all depending on the person’s beliefs on how we develop. All theories explain a specific growth and development for a specific time for an individual starting from birth to the time of their death. Not all the theories are agreed on becauseRead MoreEssay about Human Growth and Development1057 Words   |  5 PagesHuman Growth and Development Peter Nyarkoh PSY/280 July 17, 2010 Khurshid Khan Human Growth and Development Human growth and the life span perspective begin from the day of conception and continue throughout the life span. It is a lifelong process which involves periods and domains of very great importance. Psychologist, sociologist, and others have done many researches into the life span of humans and have made various conclusions as to how humans behave at any given time in the life spanRead MoreCognitive PsychologyFINAL PAPER724 Words   |  3 Pagesï » ¿ Cognitive Psychology Definition Paper Cesar Larios PSY 360 December 1, 2014 Terry Blackmon Cognitive Psychology Definition Paper The human mind is full of complexity, with it we have the ability to breath, have a heartbeat, and also process what we see around us. Many experts in the field of psychology had tried to explain the full complexity of our brain’s actions and thoughts. According to Galotti (2014), cognitive psychology studies our thoughts such as what we perceive, attend, rememberRead MoreInfluence on Behavior and Psychological Disorders Essay658 Words   |  3 PagesRunning head: INFLUENCES ON BEHAVIOR AND PSYCHOLOGICAL DISORDERS Presentation Influences on Behavior and Psychological Disorders Presentation Jocelyn F. Oatman Sofia Moran University of Phoenix Introduction to Psychology PSY 103 Michelle McCoy-Williams October 29, 2008 Influences on Behavior and Psychological Disorders Presentation The previous evaluation on the pathophysiology of anxiety constantly records the requirement for more examination on biological characteristics of childhoodRead MorePrenatal Development782 Words   |  4 PagesPrenatal development is the period in development from conception to the onset of labor. Perinatal period is the period beginning about the seventh month of pregnancy and continuing until about four weeks after birth. Postnatal development is the period in development the follows directly after birth. The germinal stage is the stage lasting about ten -fourteen days following conception before the fertilized egg becomes implanted in the uterine wall. The embryonic stage is the stage in whichRead MoreBiological and Humanistic Approaches to Personality Essay747 Words   |  3 PagesBiological and Humanistic Approaches to Personality Valerye Rogers PSY/250- Psychology of Personality Michael Moore, Instructor February 21, 2011 Biological and Humanistic Approaches to Personality In the following, the author will discuss and analyze the biological and humanistic approaches to personality. Maslow’s hierarchy of needs will be discussed and examined. The author will describe biological factors that influence the formation of personality. The author will examine the relationshipRead MorePrenatal and Postpartum Scenario Essay714 Words   |  3 PagesPrenatal and Postpartum Scenario PSY/280: Human Growth and Development November 18, 2010 Professor Donald Collins Memo To: Pregnant and Postpartum Women From: Developmental Psychologist Dr. Sanchez Date: November 18, 2010 Subject: Prenatal and Postpartum Activity List Taking care of your health is essential not only for your own personal benefit but also to the well being of your growing baby. The importance of a healthy diet and exercise cannot be more critical during the pregnancyRead MoreThe Diverse Nature Of Psychology1157 Words   |  5 Pages The Diversity Nature of Psychology Anna Van Norton PSY/490 June 29, 2015 Dr. Edna Foster The Diverse Nature of Psychology Psychology is a diverse area of study; it is not an easy task. The field of psychology is so diverse and is always changing and evolving. Because of the always expanding of nature, there is not just only one theory that can explain and answer all of the questions that are associated with psychology. Psychology has always been defined by its diversity. It is the

Wednesday, May 6, 2020

Swot Apple Case Study Free Essays

While competitors do everything they can to keep costs down, Apple does what It can to make Its products deferent. In 2007, for the third year In a row, Apple was named as The Most Innovative Company by Businesslike. ; Strong leader. We will write a custom essay sample on Swot Apple Case Study or any similar topic only for you Order Now CEO Steve Jobs is â€Å"a legend for his design sense†. He is essential to the promotional aspect and public relations of Apple, especially when it comes to the pod. He is the â€Å"public face and champion of the brand†. He is also an expert when it comes to talking with the press, maintaining relationships with magazine editors, and creating new relationships. Jobs has the ability to think of Ideas that he is extremely passionate and energetic about and is always ready to share that idea to gain exposure. * Customer relationships (responsiveness to customer feedback). This ties into Steve Jobs’ strong leadership as he takes action in response to customer feedback to show that the brand is listening and concerned. * Brand Exposure. Part of Apple’s marketing strategy is Its retail stores. Apple has opened more than 200 retail stores located worldwide. Apple’s retail stores contributed an estimated $200 million, 15 to 16% of Its profits during the past two years. The reasoning behind the stores is the belief that the more people can touch an Apple product and see also offer free group workshops, personal training, and personal assistance for Apple customers. * Strategic partnerships with well-known brands: Apple has created marketing agreements with Volkswagen of America, Burton Snowboards, Nikkei and Struck. This ties into consumer confidence as well as exposure through marketing partner advertisements. * Product design and features. Products that show superior qualities, that are easy to use and that have a high quality format, but mainly that show a clear product differentiation. * Strong financial performance: throng sales and potential growth, strong cash flows, an increasing net income, decreasing debt and controlled inventory. Weaknesses * Profit per song is low: Even though tunes is simply used as a means to boost the sales of pods, phones and Apple TV’s, Apple makes only approximately 10 cents per * Unpopular Apple TV features: users are not able to download a movie from song. Tunes directly to their TV; they have download it to their PC first. Apple TV requires a HDTV, but the movies that can be downloaded are of such low resolution that the picture looks fuzzy and old-fashioned, and lastly, it has no DVD drive. Hard time finalizing contracts with move studios because of pricing disputes. * Struggle with maintaining good supplier relationships. Many companies have expressed frustration working wit h Apple because Steve Jobs is very clear on his vision for his products and can tend to be controlling. Incompatible software in computer and digital music format. * 1% of the global cell phone business. Opportunities * Brand exposure through retail stores. * International growth and expansion. Apple is pursuing opportunities to sell the phone globally. It already has partnership agreements with cell phone carriers in France, Germany, and Great Britain. It has also entered the Middle East and Africa regions, ranking fifth next to Monika, Research In Motion, ETC, and Motorola. Apple is also trying to penetrate the Japanese market since it is one of the world’s largest and most demanding mobile phone markets with almost 100 million mobile phone users. * Expansion in product line. Apple is trying to expand its product line to include media and software in addition to hardware. * Expansion in customer base. Apple is also trying to reach many different consumers rather than its traditional of tech- savvy consumers. Improvements in compatibility. * Improvements in strategic partnerships. Apple needs to search for more strategic partnerships and better its relationships with its suppliers so effective agreements can be reached. * Growth in new user segments Threats * Competitors’ threats. Realizations sought a price war with Apple by dropping the price to $0. 49 per song and $4. 99 per album compared to Apple’s price of $0. 99 and $9. 99 respectively. Realizations also launched technology called Harmony, which allows Realizations users to translate songs purchased from Relapse music to be played on Microsoft formats. Wall-Mart launched its own online music store and is currently the number one music retailer in the nation, followed by * Technology and entertainment industries are constantly and rapidly tunes. Changing so Apple has to find a way to keep its reputation related to innovative design. * Threat of start-up companies and competitors. The risk of new entrants is high in the player and music service businesses as well as in the mobile phone market, particularly from large, established consumer electronics companies, such as Cassia, Sony and Toshiba (for players) or from on-line companies like Yahoo and Microsoft or retailers like Virgin Music (for downloads). Given the attractiveness of these markets, new competitors are likely to enter because of low barriers to entry. The notable acceptance and profit made by RIM’s Blackberry demonstrate the potential of new entrants to increase rivalry. Due to the success of the phone and the Blackberry, other producers will undoubtedly attempt to imitate their appealing features and functional applications in order to create customer value and compete effectively with their own smart phones. In addition, Apple’s exclusive use of Cingular/AT;T does not prevent the phone service provider from entering potentially harmful agreements with the company’s competitors, such as its threatening relationship with rival Palm. * Apple’s dominance and relative power in the music industry (as well as Jobs’ reputation for control) may build resistance among film producers who are accustomed to maintaining their own levels of control over content. * Price sensitivity. The company’s entrance into the mobile communications industry with the introduction of its phone has placed Apple in another highly competitive industry, where several large, well-funded, and experienced competitors operate. Price sensitivity on the part of consumers is very strong, and rivalry is especially fierce in this market. * A close look at Apple’s competition reveals that the company is confronted by aggressive opposition in all areas of its business. The markets for consumer electronics, personal computers, related software and peripheral products, digital music devices and related services, and mobile communication devices are intensely competitive. They are characterized by rapid technological advancements, which have substantially increased the abilities and use of PC’s, digital electronics, and mobile communication devices. As a result, a variety of new products with competitive price, feature, and performance characteristics are being introduced into the marketplace. Price competition in Apple’s main product markets has been particularly fervent. Continuous downward pressure on Apple’s margins as it is common for competitors selling personal computers based on other operating systems to aggressively cut prices and accept lower product margins to gain or maintain market share. * Other than price, key competitive factors in the computing market include product treasures, relative price/performance, product quality and reliability, design innovation, availability of software and peripherals, marketing and distribution capability, service and support, and corporate reputation. As the industry and its customers become more reliant on Internet connectivity, alternative (even substitute) devices are becoming increasingly smaller, simpler, and less expensive than traditional PC’s. These devices compete for market share with Apple’s desktop and content providers to offer integrated solutions that produce more value or exclude Apple from access to content. How to cite Swot Apple Case Study, Free Case study samples

Saturday, May 2, 2020

Australia Law of North V Marra Developments Ltd †Free Samples

Question: Discuss about the Australia Law of North V Marra Developments Ltd (1981). Answer: introduction The leading case of North V Marra Developments Ltd (1981) was decided by the High Court of Australia on 9th December 1981. The Honble Stephen, Mason, Murphy, Aickin and Wilson JJ decided the case against the Appellant and in favor of the Respondant. Facts of the case As per the fact of the case, the Appellants are the member of a stock broking firm (Sydney Stock Exchange Ltd). The Appellants were initially trading in the name of NORTHS but are now considered as J. J. NORTH. In 1954, Marra (Respondent) was incorporated as a public company. There were various rural properties that were acquired by Marra in 1974 in New South Wales. Its ninety three percent issued and paid up capital was held by 5 families. The shares of the company were listed on Sydney Stock Exchange. But, prior to 1974 the true value of the company assets were not depicted with the help of the balance sheets of the company or the market value of the assets. Considering with the situation, the Appellants in around December 1972-February 1974 submitted that there is a need that market capitalization of the asset must be done so that the true value of the Marra assets can be determined. There were three recommendations that were given by the Appellant and all the three were accepted by the Respondent. It is alleged by J. J. NORTH that they have provided advisory services regarding the reorganization of the capital of Marra Developments Ltd. ("Marra") and advised on the takeover of Marra upon Scottish Australia Holdings Ltd. ("Scottish") and thus they are eligible for remunerations and the interest thereon from the Respondents. (Jade, 2017) Issue Thus the main issue that was developed from the facts of the case was whether the Appellant is liable to claim the remuneration with interest from the Respondent. Now, because of the acts that are undertaken by the appellant and the Respondent, the major duty that was violated is submitted herein under. The duties/responsibilities breached That the agreement amid the Appellant and the Respondent to carry out the scheme and the carrying out the scheme itself (of capitalization and takeover) are in violation of section 70 of the Securities Industry Act 1970 of New South Wales. The scheme itself and its conduct both are illegal in nature. (Armson, 2009) Because of the act, there is violation of section 1041A (Price Manipulation) and section 1041B of the Corporation Act 2001 (False Trading and Market Rigging). Reasons why the duties were breached The main reason because of which the duties were considered to be violated are: The acts of the appellant were against the statutory prohibition (section 1041A and section 1041B of the Act) and thus the actions were illegal so they are not permitted to take advantage of any statutory wrong; The Appellant presented a plan which was approved by the Respondents, wherein, share capital is restricted and the takeover must be on the basis of share to share basis. The prices of the shares are increased by appellant involvement of buying the shares. The three documents that are made by the appellant to the stock exchange proceed of the shares were also not true and are found to be misleading in nature. The actions of the Respondent and the appellant have resulted in enhancing the market price of the company so that there is completion of takeover. That the agreement that is submitted by the Appellant is illegal and is not enforceable as it is in violation of section 70and71of theActand the common law; Decision of the Court Supreme Court of New South Wales The Appellant filed a case, however, the same is rejected by the Supreme Court of New South Wales. It is submitted but Meares J, that the argument of the defendant that the acts of the Appellant involves illegality is valid as the acts are in violation of section 70 of the Securities Industry Act 1970. Court of appeal The Appellant filed an appeal to the Court of Appeal. The Court of Appeal also dismissed the appeal of the appellant, Against the decisions of the Court of Appeal, the Appellant filed the present appeal. High Court On 9th December 1981 the Honble Stephen, Mason, Murphy, Aickin and Wilson JJ submitted that the proposal which is recommended by the Appellant and which is later carried out by both the appellant and the defendant regarding the purchase/sale on the Stock Exchange in the Respondent is not found to be legal. It is decided that the agreement to carry out the scheme and the carrying out the scheme itself are in violation of section 70 of the Securities Industry Act 1970 of New South Wales. The scheme itself and its conduct both are illegal in nature. The court also held that the actions of the parties are not such which resulted in considering the same as conspiracy to deceive. Thus, the amount that is claimed by the Appellant cannot be recovered and the appeal stands dismissed. Reasons for the decisions and critically analyses of the decision The High Court decided that the amount that is claimed by the Appellant cannot be recovered and the appeal stands dismissed. The main reasons that are attributed by the High Court which form the basis of the decision is submitted below and is critically analyzed: (O'Connell, 2013) In the Corporation Act 2001, considering the observations that are made Mason J and the changes under the 1980 Act, few variations were made regarding the market rigging and the false market provisions. There were few amendments that were made to section 998 of the corporation Act 2001. It was found that the Respondent considered itself vulnerable to takeover mainly because its net assets value per share was slightly more that its existing market price. It is on the advice of the Appellant that it proposed bonus issues and the merger. The merger was on the basis of share to share and the shares of the takeover company was at a better price and thus it is required that the shares of the Respondent company must be boosted. The assume share price of the Respondent was used to calculate the share exchange ratio. The stockbrokers (Appellants) keep on buying the shares of the company in small volumes in order to increase the price of the respondent company and finally the takeover was successful. Later the Appellants claimed remuneration for their services provided. Because of the above facts, it is submitted by Mason J that any activity which gave the market false or misleading appearance is prohibited under statue. The acts of the appellant were against the statutory prohibition and thus the actions were illegal so they are not permitted to take advantage of any statutory wrong; That there is a plan that is presented by the appellant and which was approved by the Respondents. The plans include that there should be restricting of the defendants share capital, that they would establish the share price of the Respondents on the Sydney stock exchange @$16.50 or thereabouts and the takeover must be on the basis of share to share basis. The prices of the Respondent shares are increased because of the appellant involvement of buying the shares so that the takeover takes place adequately. These actions of the appellant were not regarded as legal in concern with section 70 of the 1970 act (E.T. Fisher Co. Pty. Ltd. v. English Scottish and Australian Bank Ltd.(1940). Also, the three documents that are made by the appellant to the stock exchange proceed of the shares were also not true and are found to be misleading in nature. The price of the share @$16.50 was referred as the "market sale price", sale price",, "market price" and "market value". Even though theses terms were used there is no evidence to the extent and the nature of the appellants actions in the market and thus it can misguide the reader of the document regarding the importance that is attached with the price of the shares((Scott v. Brown, Doering, McNab Co.(1892). That the court found that section 70 aims at protecting the market for securities against any kind of manipulation or artificial dealing. There must be true demand and supply by the parties to the stock exchange. It is not true that the aim of the section is only to curb colorable or fictitious transactions. Those transactions which are not on the face of it are found to be colorable but are in fact are on the nature that they might mislead or create a false market price of the shares will defiantly come within the preview of section 70 of the Act. The actions of the Respondent with the help of the appellant which has resulted in enhancing the market price of the company of the respondent so that there is completion of takeover is an act which in contract to the provisions of section 70 of the Act. Thus, an illegal act cannot justify any benefits to be accrued in favor of the default. So, the appellant itself at fault cannot claim remuneration for an illegal act. The court held that the appeal of the appellant is not found to be favorable not because the agreement in which they are relying is in violation of section 70 but mainly because the actions in which they indulged into are itself illegal in nature. It is submitted by the court that the main object of the plaintiff in buying shares of the Respondent at premium so that they can deceive the public but in fact it is the Respondents themselves who are buying the shares in the shield of the Appellants. The main object of the purchase is to cheat the public by providing a false image of the share price of the Resonant. So, on those grounds it is decided by the High court that the appellant is not rightful in suing the Respondents and claim their remunerations on the basis that the acts in which they indulge into are itself illegal in nature. The relevance of the decision to the development of Australian corporations law In the leading case there were series of observations that were made in relation to section 70 of the 1970 Act. Mainly the interpretation of the section signifies that there must be presence of some element in order for the application of the section. Thelaw submitted by Majon J is now not applicable in the current law. however, based on the observations that are made by the Honble Judhe there were changes that were brought in Securities Industry Act 1980 (Cth) (1980 Act). (O'Connell, 2013) In the Corporation Act 2001, considering the observations that are made Mason J and the changes under the 1980 Act, few variations were made regarding the market rigging and the false market provisions. There were few amendments that were made to section 998 of the corporation Act 2001. The words of the section 998 (1) submits that [a] person must not create, or do anything that is intended or likely to create the requisite false or misleading appearance. With the introduction of these changes the fundamental of likelihood is introduced; Few changes were also made under section 998 (5); However, again the market rigging and the false trading provisions were amended by the Financial Services Reform Act 2001 (Cth). The main changes that are brought in are that civil penalty provisions are made under Part 9.4B which includes few misconduct provisions inclusive of market rigging and false trading in (section 1041B of the corporation Act 2001) This change has reflect a doubt that it is very troublesome and expensive for the law to be applied by applying criminal standard of proof and it is more efficient and appropriate to apply the civil sanctions. Thus, now civil case can be brought which is based on the violation of section 1041B (1) by complying with civil standards of the balance of probabilities and there is no need for the establishment of any kind of fault or intention. Now if there is violation of section 1041 B (1) then a liability of @ $200,000 be imposed to an individual and @ $1 million for a body corporate. Thus, the leading case of North V Marra Developments Ltd and with the current reforms that are brought in then there is no need for the establishment of any kind of fault or intention. References Books/Articles/Journals Ann O'Connell (2013) Protecting the Integrity of Securities Markets What is an Artificial Price?: DPP (Cth) v JM, Melbourne Law School. Emma Armson (2009) False Trading and Market Rigging in Australia,Corporate Law Teachers Association Conference, ANU College of Law. Legislation Companies Act 1961. Securities Industry Act 1970 (NSW) Case laws E.T. Fisher Co. Pty. Ltd. v. English Scottish and Australian Bank Ltd.(1940) 64 CLR 84 North V Marra Developments Ltd (1981). Scott v. Brown, Doering, McNab Co.(1892) 2 QB 724 Online Material Jade (2017) North V Marra Developments Ltd (1981) (Online). Available at: https://jade.io/article/66955. Accessed on 1st October 2017.