In a large number of situations both insurers

In a large number of situations both insurers â€Å"In a large number of situations both insurers and the courts recognise that the doctrine of subrogation in insurance may have unfortunate results and is wasteful. It is clear that the doctrine no longer serves any useful purpose†. Discuss. INTRODUCTION It has been recognised that fundamentally it is tort law that ensures compensation for loss in terms of compensation within the concept of the tortfeasor restoring loss through damages being paid to the person wronged[1]. In terms of insurance this liability can be revealed through the idea behind third party liability, the first party being the insured, the second party being the insurer, and the third party relating to any potential for restitution needing to be paid to anybody not included within the terms of the contract who might have met some sort of loss through the actions of the insured person, eventually becoming incorporated into the law of liability. Meanwhile, subrogation[2] has been defined as â€Å"the substitution[3] of one person in place of another with reference to a lawful claim†[4] or, more simply, the recognition in law that a lawful claim may be pursued by a third party in accordance with the principles of substitution[5]. Various types of subrogation are recognised, revealed as legal, statutory and conventional subrogation, the latter relating specifically to the terms of a contract, the legal revealed in allowing one individual to assume the rights over another and the statutory occurring as a result of the law being applied in terms of legal subrogation. This essay, focuses on the tenets of insurance law through which the principle of indemnity is revealed through the doctrine of subrogation in terms of its conventional interpretation within its statutory framework, i.e. as a remedy in â€Å"what might be classified as unjust enrichment in a legal system that is based upon the civil law†[6]. Subrogation originates from both common law and the laws of equity and it is also through both equity and common law that it continues to be administered, with the law of restitution recognised as a quasicontract within common law rather than incorporated into the laws of contract[7] or the law of tort. It has, however, become clear that this doctrine of subrogation no longer serves any useful purpose and has by been recognised both insurers and the courts that, in many situations, it may have unfortunate results and is wasteful. This essay discusses the issues surrounding the concept of subrogation and presents an argument that suggests that the function of this doctrine is, indeed, outmoded, inefficient and costly. DISCUSSION No Profit Rule Any capricious risk reassigned through a contract of insurance is subject to various fundamental assumptions, one of which is the factor surrounding that risk’s arbitrary nature. Through the element of ‘utmost good faith’[8] it is expected that the person to be insured discloses everything that could be relevant to the risk that the insurer is taking when it has agreed to insure the client[9]. Similarly, the client may not be put at a disadvantage by any actions the insurer may undertake, with a number of regulations to ensure that the insurer adheres to acceptable practices and the insured does not, through any misrepresentation, preclude any entitlements owed to the insurer[10]. Under the terms of the ‘made whole principle’ the insured person must be reimbursed in full prior to any profit being considered liable to the insurer, and the insurer may not implement the doctrine of subrogation until the insured person has been reimbursed in full[11], exc ept where a clause in the policy enables the insurer to apply the principle of subrogation when only partial payment has been made. Nevertheless, insurers are within their statutory rights to offer a voluntary settlement to the insured person and then pursue judgment with the expectation of receiving full compensation through implementing the doctrine of subrogation against the third party’s liability insurance. However, the client may not jeopardise the trust that exists between insurer and insured by claiming more than their loss[12], more recently the basis of a case where a Canadian Court of Appeal reduced the amount of compensation received by the Appellant, while they: â€Å"imposed significant punishment for the bad faith of the respondent without upsetting the proper balance between the compensatory and punitive functions of tort law†. Although in English law claiming more than the actual loss is not specifically illegal, to do so would be in breach of equitable principles and the doctrine of indemnity which assumes that the insured person would not make a profit from their loss. The doctrine of subjugation may be used in certain cases, stipulated by the courts, in order to remedy situations[13] whereby an unjust profit had been made, in accordance with the explanation given by Lord Diplock in Orakpo v Manson Investments Ltd: â€Å"It is a convenient way of describing the transfer of rights from one person to another, without assignment or assent of the person from whom the rights are transferred and which takes place in a whole variety of widely different circumstances†[14]. Should the situation occur whereby the insured profits, it would be expected that they reimburse any excess to their insurer[15]. Meanwhile, if, after both the insured and the insurer has been fully indemnified, there is excess money from the claim, the insurer is within their rights to claim it, as in the case of Yorkshire Insurance Co v Nisbet Shipping Co[16]. Similarly, if a claim is settled in full by a third party and the money paid to the insurer, then that insurer is legally within their rights to deduct any excess from the compensation before paying the residue to the insured in accordance with the terms of their insurance agreement, as revealed in the case of Scottish Union National Insurance Co v Davis[17]. Evidence of Loss The Courts tend to interpret insurance policies in accordance with those rules relating to the laws governing contracts, taking the overall context as being consistent with the actual intended meaning[18] although, in situations where a meaning might be unclear it is usually the insured person who benefits in accordance with the doctrine of contra proferentem in terms of the guidelines of equity, although in the case of Leppard v Excess Insurance Co Ltd the actual sum awarded to the insured was reduced on Appeal as it was ruled the insured had been awarded indemnity in excess of his loss[19]. Accordingly, and in view of the fact that insurance policies are subject to the rules of contract, it is necessary to ascertain whether the client was insured and, if so, under what terms, as revealed in the case of Sprung v Royal Insurance (UK) Ltd[20] where it was decided that, although the plaintiff had clearly suffered a loss through the late payment of his claim, the: â€Å"loss was recoverable in law from the defendants in addition to the interest element of the sum which had already been paid in respect of the loss under the policy†[21]. However, the figure awarded should be in accordance with the market value of the property and, in situations where a property was incomplete, the value of the loss should reflect the market value at the time the loss occurs, illustrated by the case of Richard Aubrey Film Productions Ltd v Graham[22] who, nearing completion of their filming, had their negatives stolen. At completion the film had an estimated market value of around  £20,000 but, as it still required further editing and other attention, thought to be around  £4,700 in value, prior to release the full market value was not considered to be appropriate. It was interpreted that compensation should be in accordance with the value of an ordinary indemnity contract, reflecting the sum a buyer would be prepared to pay for the film at the time of loss. An overriding factor in assessing whether compensation may be payable is the legislation appropriate to each individual case, identified through either its comprehensive cover or through its specific limitations in terms of criteria. Policies need to take account for the devastation fire can cause, taking into account ‘reasonable reinstatement’ as clarified by Reynolds v Phoenix Assurance Co Ltd[23] relating to the proposed refurbishment of an old mill. On the advice of their insurance brokers they greatly increased their indemnity. Subsequently a fire destroyed most of the building. It was established that the policyholder genuinely intended to rebuild the property and should be properly indemnified, although an issue was raised with the doctrine of undue enrichment, which was taken into account. Remedy of Restitution According to case law, and especially clarified by Lord Diplock[24], it is generally an accepted principle that the rule of subrogation cannot be appropriate in every case and should be utilised reservedly for instances where it is especially pertinent and, as clarified in the case of Re TH Knitwear (Wholesale) Ltd[25], only to the satisfaction of the courts, as in the case of Campbell Auto Finance Co v Warren in 1933[26], and similarly in later rulings, e.g. Re Chobaniuk and Canadian Johns Manville Co Ltd[27], although there are always exceptions. Subrogation may occur through the breach of duty or duplicity by the defendant resulting in the plaintiff being owed some form of corrective justice and recognised as a fundamental principle that profit may not be assumed through deceit[28], or the doctrine of unjust enrichment[29], in accordance with Lord Goff’s ruling in Lipkin Gorman[30]: â€Å"A claim to recover money at common law is made as a matter of right; and even though the underlying principle of recovery is the principle of unjust enrichment, nevertheless, where recovery is denied, it is denied on the basis of legal principle†. An insurer may enter into a simple subrogation by metaphorically standing in place of the insured person[31], after the insured person’s claim has been paid[32], and claiming the value of the insured person’s indemnity from this third party. This claim through subrogation must, however, be undertaken in the name of the insured person to reflect the fact that liability continues even though the insured person has already been indemnified. In effect, this means that the insurer is forcing the insured person to undertake further action despite the fact that they have already received full payment. The result will reimburse the insurer to the value of that which has already been paid to the insured. In theory, this would enable an insured person who had suffered a loss from the actions of a third person, to receive double compensation through a secondary action against the third party, the tortfeasor, as in the case of Caledonia North Sea Ltd v London Bridge Engineering Co[33] during which the insurers were allowed to â€Å"exercise a right of subrogation and sue in the insured's name under the contracts of indemnity†. The perception of compensation has a dual function: the satisfaction of obtaining justice against a defendant and the plaintiff being compensated to the value of their loss. Nonetheless, debate[34] currently surrounds the issue of deducting collateral damages that might already have been paid to the plaintiff, the intention being that the plaintiff should be left in the position they were in before the liability occurred according to the precepts of common law as ruled in British Transport Commission v Gourley[35]. It was recognised in Parry v Cleaver[36] that common law offers no recognition of prior benefits being deducted or not with it being left to the courts’ discretion to rule in accordance with â€Å"justice, reasonableness and public policy†[37] and, despite the law of tort remaining at variance with any of the more updated methods of compensation, its procedures continue to be an important way of recompensing for loss with the result that collateral compensati on often results in a breach of the doctrine of unjust enrichment, as revealed in British Transport Commission v Gourley: â€Å"it is a universal rule that the plaintiff cannot recover more than he has lost†¦Before Gourley’s case it was well established that there was no universal rule with regard to sums which came to the plaintiff as a result of the accident but which would not have come to him but for the accident†[38]. This ruling was later upheld in Hussain v New Taplow Paper Mills Ltd[39] due, in part, to Lord Bridge’s view that the tortfeasor should not benefit because the plaintiff had paid insurance premiums or received other payments as the result of charity, i.e. an award of damages having a deterrent effect through the defendant having to pay compensation, highlighted in the case of Redpath v Belfast and County Down Railway[40], although this was later superseded by British Transport Commissioners v Gourley[41]. When Browning v War Office[42] was heard in the Court of Appeal it was noted that: â€Å"whether the policy of the common law in these types of actions is to provide restitution for the plaintiff or to visit retribution on the defendant?†[43]. CONCLUSION Insurance law does not necessarily correlate with the principles of common law, with indemnity considered to be non-deductible due to a variety of reasons, part of which appears to be a reflection on the courts’ attitude to social policy. It was ruled in the case of Caledonia North Sea Ltd v London Bridge Engineering Co[44], i.e. Caledonia North Sea Limited (Respondents) v British Telecommunications Plc (Appellants) (Scotland) and Others[45]: â€Å"insurance company recoveries, under their right of subrogation, most often flow from tort actions is quite natural, but without significance. Subrogation is an equitable principle and applies to contract rights as fully as it does to tort actions†¦ The insurer is subrogated to appellant's contract right of indemnity. This sustains the cause of action against appellant for the identical reason that subrogation sustains a tort action where the plaintiff has been paid for his loss† The case of Parry v Cleaver[46], decided in the House of Lords, illustrates the incongruous situation of continuing to recognise the doctrine of subrogation in insurance, recognised by both insurers and the courts as being wasteful and no longer serving any useful purpose, with both the opportunity and the possibility of various unfortunate results emerging from this practice continuing, the concept of insurance having diminished the influence tort alone now has in terms of restitution[47]. Insurance companies now reimburse up to 94% of all damages and 88% of all claims in tort through insurance premiums that have been pre-paid[48]. The law of restitution or quasicontract is recognised at common law rather than contractual remedies or remedies at tort. However, evidence provided by case law suggests that the circumstances in which these remedies are applied is reliant on a specific set of principles[49] and there appears to be considerable doubt as to the criteria for subrogation allowed to be applied, with it being suggested that applying it arbitrarily was unacceptable – it should be a â€Å"matter of principle†[50]. The definitive case that has been acknowledged as introducing the law of restitution into case law was Moses v Macferlan[51]. â€Å"The law of restitution is the law relating to all claims†¦which are founded upon the principle of unjust enrichment†[52]. It has been claimed that ‘federal class actions have tripled over the past 10 years’ represented by a burgeoning escalation of over 1000%[53] and is contributing to an incipient damage to the US economy with ‘litigation costs increased at four times the growth of the overall economy’[54]. Krauss observes that the law of tort is ‘not insurance against unfortunate losses†¦[it]†¦does not exist to protect against risks’. As he clarifies, the competitive nature of the insurance industry enables premiums paid by policy holders to cover the cost of most claims[55]. In the US this may be achieved through social insurance, welfare payments and tax law or by way of private insurance, none of which had evolved to such developments as modern society enjoys when the cases of Castellain v Preston[56] and Darrell v Tibbetts[57] were being heard in the Court of Appeal during the 19th Century. Subrogation was ruled in Darrell v Tibbetts[58] as payment had been made for a loss which, in retrospect, was revealed not to have been a loss and, as such, the plaintiff was entitled to seek redress from the courts in order to be reimbursed for his loss. In Castellain v Preston, however, this was not the case and ultimately resulted in both sellers and purchasers, in effecting conveyance of property, to be required to insure that property against loss, an apparent example of a wasteful exercise. The ruling made by Chitty J was on the premise that â€Å"The contract of sale was not a contract†¦for the preservation of the buildings insured†[59]. However, it was also recorded that Chitty, J correlated ‘subrogation’ with â€Å"the insurers are entitled to enforce all the remedies whether in contract or in tort†, thereby paving the way to future confusion between when subrogation was an appropriate action and blurring the distinction between the law of contract, that of tort and that of quasicontract administered through common law. The case went to Appeal where Brett, LJ[60] interpreted simple subrogation as a doctrine of subrogation interchangeable with the doctrine of indemnity. The Law Reform Commission state that Brett, LJ ‘distorted the definition of subrogation so as to cover the case’[61] with the effect that it has subsequently been misapplied in many other cases[62], with its true application, equity, continuing to be incorrectly interpreted over the years as subrogation. The Commission states: â€Å"†¦its long-term effect has been to introduce a confusion into the heart of the law in this area which has rendered its workings obscure and which must be stripped away before the remedies made available†¦to enforce the principle of indemnity can properly be understood†[63]. This reinforces their view of sufficient welfare provision and private insurance cover to preclude the need to subrogate a claim against a tortfeasor. In accordance with this view, the doctrine of subrogation can no longer serve any useful purpose and, in view of the amount of waste in terms of litigation costs and courts’ time that results from this doctrine far outweighs its continued value or rationale. Total Word Count (excluding bibliography and footnotes): 3,000 words BIBLIOGRAPHY BOOKS: Beatson, J (2002): Anson’s Law of Contract, Oxford: Oxford University Press, Page 20. Bird and Hird (2001): Modern Insurance Law, London: Sweet and Maxwell, Page 256 Black's Law Dictionary, 6th Edition (1990). Burrows, (1993): The Law of Restitution, London: Butterworths, Page 1 Goff and Jones (1998): The Law of Restitution, [5th ed]. London: Sweet and Maxwell, Page 3 Krauss, Michael I (1992): Tort Law and Private Ordering, USA: St Louis University Press Mitchell, Charles (1994): The Law of Subrogation. Oxford: Oxford University Press, Page 4 Oxford English Dictionary, The Compact Edition ( Oxford, 1987), ii. 3126 Virgo, Graham (1999): Principles of the Law of Restitution. Oxford: Oxford University Press ARTICLES: Barker, (1995): Unjust Enrichment: containing the beast. In OJLS, 15, 457,473 Barker, (1998): Rescuing Remedialism in Unjust Enrichment Law: why remedies are right. In CLJ, 57, 301. Birds, John: Contractual subrogation in insurance. [1979] JBL 124, Pages 132 133 Connor, Martin F (2000, October): Taming the Mass Tort Monster, In the National Legal Centre for the Public Interest, Page 4 Hasson, Reuben: Subrogation in insurance law a critical evaluation. [1985] 5 Oxford J Legal Stud 416, Page 425 428 HMSO: Report of the Royal Commission on Civil Liability and Compensation for Personal Injury [UK Pearson Commission (1978, Vol. 2, para. 509) [Cmnd 7054] Law Reform Commission CONSULTATION PAPER ON COLLATERAL BENEFITS (LRC CP 15 1999) Dublin: IPC House ONLINE RESOURCES (Site visited 25/05/05. Hyperlinks functioning) Krauss, Michael I (2004): Medical Malpractice: is it time for Tort Reform in Maryland, USA?: The Maryland Public Policy Institute http://www.mdpolicy.org/research/health/MDMedMal.pdf Parsons, Chris (2002): Moral Hazard and Behavioural Aspects of Liability Insurance. http://64.233.183.104/search?q=cache:VR1wzB7SfwEJ:www.nottingham.ac.uk/business/cris/ukec/2002paper5.doc+Pearson+Commission%2Binsurance%2Bclaims%2B88%25%2Btort+hl=en TABLE OF CASES: British Transport Commission v Gourley [1956] AC 185, [1955] 3 All ER 796, [1956] 2 WLR 41, 2 Lloyd's Rep 475, 34 ATC 305, [1955] TR 303, 49 RIT 11 Browning v War Office and Another [1960 B. No. 3080] [COURT OF APPEAL] [1963] 1 QB 750 Caledonia North Sea Ltd v London Bridge Engineering Co [2000] Lloyd's Rep IR 249 Campbell Auto Finance Co v. Warren [ 1933] 4 DLR 509 at 515 Canadian Johns Manville Co Ltd [1969] 39 WWR 680 at 681 Castellain v Preston Others [1881-1885] All ER Rep 493 Castellain v Preston and Others [1882] 8 QB D 613 (April 4) Castellain v Preston and Others [1883]11 QB D 380 (March, 12) Commercial Union Ass Co v Lister (1874)LR 9 Ch 483 Darrell v Tibbetts (Court of Appeal) 5 QB D 560 Hussain v New Taplow Paper Mills Ltd [1988] 1 AC 514, [1988] 1 All ER 541, [1988] 2 WLR 266, [1988] ICR 259, [1988] IRLR 167 Leppard v Excess Insurance Co Ltd [1979] 2 All ER 668, [1979] 1 WLR 512, [1979] 2 Lloyd's Rep 91, 2 ILR 107, 250 EG 751, [1979] EGD 246 Lipkin Gorman (A Firm) v Karpnale Ltd [1991] 2 AC 548, 578 Livingstone v Rawyards Coal Co (1880) 5 App Cas 25, 39 Morrison and Morrison v. Canadian Surety Co, n. 4 above, at 86 per Coyne, JA Moses v Macferlan [1776] 2 Burr. 1005, 1012; 97 ER 976, 981 Napier v Hunter [1993] 2 WLR 42: Lord Napier and Ettrick and Another v Hunter and Others and Lord Napier and Ettrick v RF Kershaw Ltd and Others [Consolidated Appeals] HL [1993] AC 713 Orakpo v Manson Investments Ltd and Others [ 1978] AC 95, [1977] 3 All ER 1, [1977] 3 WLR 229, 36 P CR 1 Page v Scottish Insurance Corporation Ltd; Forster v Page (Court of Appeal) [1929] 33 Ll.L Rep. 134 Parry v Cleaver (House of Lords) [1970] AC 1, [1969] 1 All ER 555, [1969] 2 WLR 821, [1969] 1 Lloyd's Rep 183, 6 KIR 265, (48 MLR 20) Phoenix Assurance Co v Spooner [1905] 2 KB 753 Rayner v Preston (1881) 18 Ch D 1 Regal Films [1946 OCA] Reynolds and Anderson v Phoenix Assurance Co Ltd and Others (Queen’s Bench Division) [1978] 2 Lloyd's Rep 440 2 ILR 75, 3 ILR 51, 247 EG 995, [1978] EGD 172 Re TH Knitwear (Wholesale) Ltd [ 1988] Ch 275 at 286 Richard Aubrey Film Productions Ltd v Graham [1960] QB 2 Lloyd's Rep 101 Scottish Union National Insurance Co v Davis [1970] 1 Lloyd’s Rep 1 Sprung v Royal Insurance (UK) Ltd [1999] Lloyd's Rep IR 111, (Transcript: Smith Bernal) West of England Fire Insurance Co v Isaacs (Court of Appeal) [1895 1899] All ER Rep 683 Whiten v. Pilot Insurance Co., [2002] 1 S.C.R. 595, 2002 SCC 18 Yorkshire Insurance Co Ltd v Nisbet Shipping Co Ltd (Queen’s Bench) [1962] 2 QB 330, [1961] 2 All ER 487, [1961] 2 WLR 1043, [1961] 1 Lloyd’s Rep 479 1 Footnotes [1] Livingstone v Rawyards Coal Co (1880) 5 App Cas 25, 39 [2] Concept introduced in by Court of Appeal in the cases of Darrell v Tibbetts [1880] (Court of Appeal) 5 QB D 560 and Castellain v. Preston, ( 1883) 11 QBD 380 [3] The Compact Edition of the Oxford English Dictionary ( Oxford, 1987), ii. 3126 [4] Black's Law Dictionary, 6th Edition (1990). [5] Orakpo v. Manson Investments Ltd [ 1978] AC 95 at 112, per Lord Edmund-Davies [6] Orakpo v Manson Investments Ltd [ 1978] AC 95 per Lord Diplock [7] Beatson, J (2002): Anson’s Law of Contract, Oxford: Oxford University Press, Page 20. [8] Bird and Hird (2001): Modern Insurance Law, London: Sweet and Maxwell, Page 256 believe that â€Å"It may be that there is no general continuing duty of utmost faith†¦Ã¢â‚¬  [9] West of England Fire Insurance Co v Isaacs [1897] 1 QB 226 [10] Phoenix Assurance Co v Spooner [1905] 2 KB 753 [11] Page v Scottish Insurance Corporation [1929] 98 LJKB 308 [12] Rayner v Preston (1881) 18 Ch D 1 [13] Mitchell, Charles (1994): The Law of Subrogation. Contributors. Oxford: Oxford University Press, Page 4 [14] [ 1978] AC 95 per Lord Diplock [15] Darrell v Tibbetts [1880] (Court of Appeal) 5 QB D 560 [16] [1962] 2 QB 330 [17] [1970] 1 Lloyd’s Rep 1 [18] Leppard v Excess Insurance Co Ltd [1979] 2 All ER 668, [1979] 1 WLR 512, [1979] 2 Lloyd's Rep 91, 2 ILR 107, 250 EG 751, [1979] EGD 246 [19] ibid [20] [1999] Lloyd's Rep IR 111 [21] Sprung v Royal Insurance (UK) Ltd [1999] Lloyd's Rep IR 111, per Hedley, J [22] [1960] QB 2 Lloyd's Rep 101 [23] [1978] QB 2 Lloyd's Rep 440 [24] Orakpo v Manson Investments Ltd [ 1978] AC 95 per Lord Diplock [25] [ 1988] Ch 275 at 286, per Slade LJ [26] Campbell Auto Finance Co v. Warren [ 1933] 4 DLR 509 at 515, per Masten JA [27] [1969] 39 WWR 680 at 681, per Friesen DCJ [28] Barker, (1995): Unjust Enrichment: containing the beast. In OJLS, 15, 457,473 [29] Burrows, (1993): The Law of Restitutio

Tristan Gonzales

Gonzales#l Integrity is â€Å"the quality of being honest and having strong moral principles; moral uprightness† (Google Definitions). The first person that comes to mind when I hear the word integrity is Nick Carraway from the movie and the novel â€Å"the Great Gatsby'. Nick Carraway is Gatsbys Lovers brother and Gatsbys best friend, he is also the narrator. Nick shows honesty, moral principles, and moral uprightness throughout the ntire book.Nick Carraway as a narrator is honest and reliable because he explains all the Judgments from characters in general and is unbiased in doing so, he presents original plots or conversations does not scrutinize them and leaves them to the readers to decide, and these good qualities of Nick can be described by comparing others corruption in the book, such as Tom Buchanan, Gatsbys lover's wife. Nick accepted the good parenting in his younger age, which helps him to be a decent person afterwards.It can be proved in the book where Nick's fat her told him: â€Å"Whenever you feel like criticizing someone, Just remember that all the people in this world haven't had all of the advantages you've had. â€Å"( Fitzgerald,l) this advice, which he has been turning over in his head ever since tells us that he is honest for the fact thathe does not Judge people without getting to know them first. Gonzales #2 Nick has high morality and decency while others do not. For example, â€Å"l was one of few guests who had actually been invited.People were not invited-they went there. † (F. Scott Fitzgerald, 43) Majority went there without an invitation. It shows those people have low morality and are dishonest. In the book Gatsby asks nick to go and tell daisy to meet him for lunch after he tells the story of him and daisy and what occurred with their relationship. He agrees to this gesture because he feels that tom Buchanan is an unfaithful husband and he has witnessed first hand of his affairs. He knows what he is doing is for the best and is looking out for daisy in more ways than ne.These reasons for Nicks integrity that I have stated are only the ones that truly stuck out to me on the contrary though if I re read the book I'm confident that I could conjure up 100 more reasons why he has integrity. In every chapter of the book he is in a circumstance where he must make the right choice, and he never fails to make that choice. In the third chapter atter meeting a lot ot the main characters Nick states â€Å"l am one of the few honest people that I have ever known†( Fitzgerald,54). And I agree with this quote completely.

Hunger Games Book Review

Everyone has heard the saying that winning is not everything. In Suzanne Collin’s bestseller, The Hunger Games, it redefines that saying. In the novel, North America has been through some apocalyptic disasters and is known as Panam with twelve districts that are ruled by the Capitol. Each year the Hunger Games are held as a reminder of the bleak past and that the Capitol is still in control of the citizens of Panam. One girl and one boy between the ages twelve and eighteen from each district are drafted to fight to death in the Hunger Games.The last one standing is the winner and will bring home the fame and fortune for their district. Each kid must attend â€Å"The Reaping†, which is the ceremony where the names are drawn for the person to be in the Hunger Games. Primrose Everdeen is only twelve years old and this is her first year attending â€Å"The Reaping†. Her sister, Katniss Everdeen, assures her that she’s not going to be picked because her name is only in the drawing once. Surprisingly, the odds were not in Primrose’s favor.Katniss cannot stand to see her little sister go and fend for herself in the Hunger Games, so she does the unthinkable and volunteers to take Primrose’s place as tribute, a person who competes in the Hunger Games. Peeta Mellark is the male tribute chosen to represent District 12 in the Hunger Games. Peeta has had an everlasting crush on Katniss since the day they met. Will Katniss have mutual feelings with Peeta during this crucial time of life or death or will the love be a distraction while it boils in the heart? Also, will the beloved characters perish or will they prevail in the Hunger Games?The Hunger Games is a compelling young adult novel that will surely appeal to many readers that admire action and adventure with a hint of romance. In my opinion, The Hunger Games is an exceptional novel that is dramatic and really fun to read. The author, Suzanne Collins, does a really good job with developing the plot. The plot is very unique and unpredictable. I really liked the little plot twists she throws in the story; it keeps the story interesting. I also like how the story has just the right amount of action and romance. The action keeps the whole book from being consumed from all of the romance.The main characters were all developed really well, but I think the minor characters could have been developed a little better. Other than that, the whole book was excellent. I believe this book will appeal to people who like stories about action and adventure with slight romance to freshen things up. This book will also most likely appeal to both genders of teenagers and adults. In summary, The Hunger Games by Suzanne Collins is a remarkable novel that will make you yearn to find out what’s going to happen next in the trilogy. The book has a great plot that will definitely leave a lasting impression on the reader.

Standard Business Questions in English

There are a number of standard business questions used when making generally inquires into the nature of a company. The following dialogue covers a number of standard business questions. The reference section then provides variations and related business questions for a number of the standard business questions used in the dialogue. Business Reporter Thank you for taking the time to meet with me today. Manager: Its my pleasure Business Reporter: Who do you work for? Manager: I work for Springco. Business Reporter: What does Springco do? Manager: Springoco distributes health products throughout the United States. Business Reporter: Where is the company based? Manager: Springco is located in Vermont. Business Reporter: How many people do you employ? Manager: Currently, we have 450 people on staff. Business Reporter: Whats your annual revenue? Manager: Our gross revenue is about $5.5. million this year. Business Reporter: What type of distribution services do you provide? Manager: We distribute to both wholesale and retail outlets. Business Reporter: What sort of internet presence do you have? Manager: We have a storefront, as well as an online forum. Business Reporter: Is your company public? Manager: No, we are a privately held company. Business Reporter: What type of logistical structure do you have? Manager: We ship from four regional warehouses. Business Reporter: Where are your products manufactured? Manager: Most of our products are manufactured abroad, but a number are also produced here in the United States. Standard Business Questions Who do you work for? Variations: Which company do you work for? Where do you work? Related Questions: What kind of job do you have? What do you do? What are your responsibilities? What does X do? Variations: What kind of business does X do? Which business is X in? Related Questions: What type of products does X sell/manufacture/produce? What type of services does X provide/offer? Where is the company based? Variations: Where is your company located? Where are your headquarters? Related Questions: Where do you have branches? Do you have any offices abroad? How many people do you employ? Variations: How many people does X employ? How many people does X have on staff? How many employees are there at X? Related Questions: How many divisions are there? How many people are on staff in that branch? How many people do you employ in (City)? Whats your annual revenue? Variations: Whats your turnover? What type of revenue do you do? Related Questions: Whats your net profit? What are (were) your quarterly earnings? What type of a margin do you have? Is your company public? Variations: Are you a publicly traded company? Are you on the stock market? Is your company privately held? Related Questions: Whats your companys stock symbol? Which market are you traded on? Where are your products manufactured? Variations: Where are your goods produced? Where do you manufacture/produce your merchandise?

The End of Toeic Essay Samples Questions

The End of Toeic Essay Samples Questions The Secret to Toeic Essay Samples Questions You're able to write a paper by yourself and even now. There are a few other suggestions for donations on the Chicago Pet Workshop site. Benefits of Online essay Writing Services Essay writing is an ambitious undertaking for the majority of the students today. Anyway you need to decide to earn a Teacher Cover Letter Example. Whatever sample you select, make sure your CV is readable and gets attention from the recruiters at first. Your responses could possibly be different. The sample is there to offer you an impression on the characteristic of the paper. Most samples are at no cost. You might still manage to obtain a point or two. The way the topic affected you'll play a huge part in the way you will write your essay. The main portion of a quick essay is known as the body. Examine the matter from the standpoint of the reader. When selecting high school essay format, step one is to recognize the kind of essay you want to write. Bear in mind that the sample answers are only ideas. Thus, you've got to consider from the view of an artist to come up with a superior body paragraph of A level essay. There are typically 3 body paragraphs in a persuasive essay, and each one it used to talk about a particular point about this issue. Your closing statement should be quite so emphatic that the reader is completely convinced about your position. To state your primary point, your final sentence in the very first paragraph is essential. High school essay examples incorporate a selection of short essays like narrative, persuasive and analytical. Writing a high school essay if you've got the tips about how to do essay effectively. High school essays are structured very similarly irrespective of the topic and very good essay structure will let you write a very clear essay that flows from 1 paragraph to the next. Cause and effect essays are a few of the most usual pieces, students will be asked to write. In Questions 1 and 2 you are going to be requested to read a bit of text out loud. You may then choose a topic from this list to produce your creative writing ideas. The topic doesn't require any specialized understanding. Writing of scholarship graduate essay is an incredibly tough academic task simply because students have to demonstrate they are capable of accomplishing the task that they're applying for. For instance, a student will be asked to answer a prompt requiring them explain just what happens to a kid's health that starts smoking cigarettes. You must find the proper resources for your essay together with patience when finding the correct inspiration to write. Many people think that high school entrance essays are comparatively less difficult to write than college entrance essays, that is the reason there are fewer places where you are able to get assistance with higher school entrance essays. For instance, you won't see questions which are about a particular calendar year, name, or location. Once you opted to find a service that has the ability to write essay for money, you should upload the essential information and fill in the purchase form. If you want to include more detail, that's perfectly fine and solely your choice, the parent. You have to provide as many facts about the picture as possible in the time allowed. So so as to receive a small relief from this additional burden, it is very important that students receive their essays written by online professionals. When you're taking reference from the samples, you must search for the sample that supplies you with best presented details of former jobs, education and present skills. There are a few topics which are absolutely unseen and students find difficulty in locating the perfect direction and method of information collection. As a parent, you're able to fully anticipate the teachers and faculty to at least keep your eye on the kid and permit you to know whether they see any problems.

The Lottery, By Shirley Jackson - 1772 Words

Conformity is not based mainly on containing and supporting a society, but also to dominate and control what is within. The control of repressed individuality benefits those at the top of a power structure. From early on, men were considered the breadwinners and women were to maintain households; whether due to a difference in physical, emotional, or mental state; this was an unquestioned hierarchy. Therefore, any women who pushed back were ultimately punished for threatening the system. In â€Å"The Lottery†, Shirley Jackson uses literary devices of symbolism, irony, and characterization to reveal the danger of blind obedience, and implanting the thought of resistance for women. To an extent, conformity is necessary in reality; time has shown that laws, rules, and regulations that are innately bad can serve as the catalyst for rebellion, as recorded for the French Revolution, Vietnam War, and Czarist Russia. Conformity lays the groundwork for good laws to be constructed, and until that time, men are able to abuse and utilized the current laws for their own superior gain. One of the biggest â€Å"rebellions† is backed purely by feminism, where women are repressed by men. Unfortunately, in the past not many women knew their true value, and were prematurely silenced; however, Jackson is revealing the reality of the restraints. The author utilizes symbolism throughout her storyline to great effect. The physical properties, the black box, the slips of paper, the placing of the box on theShow MoreRelatedThe Lottery, By Shirley Jackson1195 Words   |  5 PagesOn the surface, Shirley Jackson’s short story, â€Å"The Lottery,† reads as a work of horror. There is a village that holds an annual lottery where the winner is stoned to death so the village and its people could prosper. Some underlying themes include: the idea that faith and tradition are often followed blindly, and those who veer away from tradition are met with punishment, as well as the idea of a herd mentality and bystander apathy. What the author manages to do successfully is that she actuallyRead MoreThe Lottery by Shirley Jackson757 Words   |  4 Pagessucceed but many fail just like the main character Tessie Hutchinson in Shirley Jackson’s short story â€Å"The Lottery†. When someone hears the word â€Å"lottery †, he or she may think that someone will be rewarded with prize. But â€Å"The Lottery† By Shirley Jackson is different than what one thinks. In the story, a lottery is going to be conducted not like Mega Million or Powerball one play here. In the story, the person who wins the lottery is stoned to death instead of being rewarded with the prize. TessieRead MoreThe Lottery By Shirley Jackson931 Words   |  4 PagesIn 1948 Shirley Jackson composed the controversial short story â€Å"The Lottery.† Generally speaking, a title such as â€Å"The Lottery† is usually affiliated with an optimistic outlook. However, Jackson’s approach is quite unorthodox and will surely leave readers contemplating the intent of her content. The story exposes a crude, senseless lottery system in which random villagers are murdered amongst their peers. Essentially, the lottery system counteracts as a form of population control, but negatives easilyRead MoreThe Lottery By Shi rley Jackson1504 Words   |  7 Pagesâ€Å"The Lottery† by Shirley Jackson In The Lottery Shirley Jackson fills her story with many literary elements to mask the evil. The story demonstrates how it is in human nature to blindly follow traditions. Even though some people have no idea why they follow these traditions. The title of the story plays a role in how Shirley Jackson used some literary elements to help mask the evils and develop the story. The title â€Å"The Lottery† serves as an allegory. When people think of the lottery majorityRead More`` The Lottery `` By Shirley Jackson894 Words   |  4 Pagesshort story â€Å"The Lottery†, author Shirley Jackson demonstrates Zimbardo’s concepts in three different areas: Authority figures, Tradition and Superstition, and Loyalty. The first concept Jackson portrays in â€Å"The Lottery† is the authority figures. Jackson indicates that the lottery is being held in the town center by one authority figure, Mr. Summers, annually on June 27th. Every June 27th, without fail, townspeople gather in the town square to participate in the annually lottery even though mostRead MoreThe Lottery, By Shirley Jackson1510 Words   |  7 PagesShirley Jackson’s â€Å"The Lottery† illustrates several aspects of the darker side of human nature. The townspeople in Jackson’s â€Å"The Lottery† unquestioningly adhere to a tradition which seems to have lost its relevance in their lives. The ritual that is the lottery shows how easily and willingly people will give up their free will and suspend their consciences to conform to tradition and people in authority. The same mindless complacency and obedience shown by the villagers in Jackson’s story are seenRead MoreThe Lottery By Shirley Jackson8 11 Words   |  4 Pagesâ€Å"The Lottery† was published by Shirley Jackson. The story was true expression of Jackson’s genuine thoughts about human beings and their heinous competence in an annual village event for corn harvest . First, her used to word symbolized main point of the story. Second, Jackson was inspired by few historical events happened in the past and a life incident in her life. Lastly, She was able to accomplish the connection between historical and biographical with the story. Therefore, Shirley Jackson’sRead MoreThe Lottery By Shirley Jackson934 Words   |  4 Pagesâ€Å"The Lottery† by Shirley Jackson signifies the physical connection between the villagers and their unwillingness to give up their tradition. â€Å"The Lottery† is very unpredictable and quite misleading. The black box has no functionality, except every June 27th. Shirley Jackson depicts the black box as an important and traditional tool. Although the villagers in â€Å"The Lottery† are terrified of the goal of the lottery and the black box, they are unwilling to let go of the tradition. Shirley Jackson portraysRead MoreThe Lottery by Shirley Jackson799 Words   |  4 Pagesthe mood and to foreshadow of things to come. The Lottery by Shirley Jackson is a story in which the setting sets up the reader to think of positive outcomes. However, this description of the setting foreshadows exactly the opposite of what is to come. In addition, the theme that we learn of at the end leads us to think of where the sanity of some human beings lies. The story begins with the establishment of the setting. To begin, Shirley Jackson tells the reader what time of day and what time ofRead MoreThe Lottery by Shirley Jackson1764 Words   |  7 Pagesfilled with excitement and eeriness, leaving the reader speechless. The Lottery , a short story written by famous writer Shirley Jackson, created an uproar on June 26, 1948, when it was published in the magazine The New Yorker (Ball). The gothic thriller, set in an unknown time and place, shares the tradition of a small town, a little larger than three hundred people, in which a drawing is held once a year. In this â€Å"Lottery,† each family’s husband draws a slip of paper from a black box. The husband

The Relationships of Fashion Leadership Marketing and Management

Questions: Part 1: Outline the FCP process triangle in relation to jobs within Fashion Communication and Promotion, identifying the area of the industry you are interested in (e.g. where would the role of a Buyer sit within the triangle or a Visual Merchandiser? What job do you hope to graduate into?) Reflect on your feedback from the previous 1.5 years; highlighting your strengths and areas to improve Produce two cartograms (each relating to a different idea) which should identify new and exciting trends within the industry. You should follow the format as per The Trend Forecasters Handbook using the same headings Outline if appropriate how these two areas might translate into project ideas for your third year e.g. is there a gap in the market, a problem that needs solving? Produce a consumer profile in relation to each of the two areas of research Outline how you intend to work on your ideas over the summer i.e. a plan of action for research Part 2: You are also required to produce a 3000 (roughly 1500 per idea) word visual report expanding on your presentation. This must be produced on InDesign. This should also contain: Marketing models and theory where appropriate when outlining the context of your ideas A primary research methodology A list of illustrations A page of references plus a bibliography The slides from your presentation which should be in the Appendix of your report Consent forms in relation to your primary research. Answers: Part1 FCP process triangle Fashion and communication promotion is the most important aspect that may be, related to the FCP triangle. In the first stage of the interaction it has been found that innovations the top of the stage and then comes the business collaborating in the communication process. Service delivery is the last aspect that is analyzed in the triangle of the FCP. In the fashion and communication promotion, this triangle can be useful and this plays a key role in the innovation of the technology (Saltz, 2010). Even in case of the aspects like that of the promotional techniques innovation is the aspect that attraction of the customers. The industry that has been, used in the present case includes tattoos and selfie. These two methods could be, used to create the promotion. The role of the buyer in the present case may include knowledge and the service that is required. Reflection of the feedback Strengths of tattoos In case of tattoos, the most important thing that is used is the culture and the fashion that it has followed. It may be, said in the present regard that there are certain culture that has been imbibed and inculcated in case of the culture that has been retained. The strength is that the copying of the celebrities and the modern culture was, made the promotion of the tattoos. The thoughts could be, administered in the best process (Walker et al. 2009). Strength of selfie The strength of selfie is that with the advanced techniques that are, used these days there may be a number of promotional techniques that could be used. Selfies can be, seen by a number of people round the world with just a click. It is the promotion of the clothes and the ideas that could be shown. Cartograms The cartogram that could be used is that tattoos mostly used by the people of the western countries. In such cases, it is important to note that the culture and the perception play a key role. The other people based on the thematic differentiation may be the natives of Africa who use the tattoos. In case of the selfie the thematic map is that all the countries in the world are mostly part of it. There is no such vital differentiation that can be drawn. Projected ideas These ideas could be, catered to use the method of promotion is order to get the tattoos and the selfie. These are the products or the processes that could be used in getting the basic desire of the customers. Consumer profile The profile of the consumer is not always someone who comes from an affluent background. This is the case in both the cases. The selfie and the tattoos that are used may be the ones that are related to customers who are interested. These days most of the phones have access of the selfies. There is no major issue with the customers. Plan of research The plan of the research is to try to take the variables and relate them with the research topic. Apart from this the major methods that has been, used is to carry the information and then study the aspects relating to the problem that the customers face. The communication and the fashion statement are pivotal. Part 2 Marketing model and theories of tattoos In the recent scenario round the world, it has been, found that there has been a number of relevance that has been, found in the aspect of tattooing. In the present case, it has been, found that the consumer culture and the behavior attached to the same changed drastically. The postmodern self of individuals in integrally related to the consumer behavior model. The buying behavior is relating to the postmodern ideas that deal with the ideas that may be, derived from the impulsive behavior of the customers (Bailey and Seock, 2010). The identity of any person is related to the behavior or the perception that they have towards a product. In case of the tattoos, the cultural aspect may be, derived in the buying process and the decisions that are, attached to the same. The behaviors are dependent on two types like that of the personal use and that of the one that is for personal use. The fashion communication and the promotion is such ole in a pivotal role. It has been, found that there a re certain aspects in the customer behavior model, which includes the purpose of the product, the free choice that may be, related to the product, the behavior that influences behind the choice of the products and the need of the products in terms of the process of production (Buttle and East, 2010). The major aspects that are, related to the process of the choice of the tattoos include the factors like that of the marketing stimuli that is the product, price, place and the promotion (Boyle, 2010). The other stimulus that may be included in the process includes the economic aspect, technological, political and the cultural. This leads to the characteristics of the buyers and the process of the decision-making. This finally leads to the responses like the choice of the product along with the choice of the store for buying and estimating along with the amount that is to be bore. In the postmodern perspective, it may be, said that the most important attribute is that tattoos have become a style stamen. Bye and Sohn (2010) opine based on the locality and the international fashion statement it may be, said that there are number of aspects that have been faced by the consumers. The buying process has been an integral part of the present want and the fashion demand of the customers. The cultural factors that have been, used include the sub culture methods that are ingrained in the life of a person. However, to gain a social status there might be some methods of consumer that is to be at par with the society. This social perspective is then, related to the reference group and the family tradition. However, Bye (2010) argues roles and the status that is, exhibited by the customers play another key role in the process. In case of the tattoos, the reference group is the most effective method to promote. The other factors that are related to any of the customer behavi or includes the age of the customer the occupation that they are in, the circumstances and the economic that they have. Self-concept is the most important aspect in the present case (Gonzailez, 2010). The psychological aspect that leads to a decision like using tattoos include the motivation, perception, learning beliefs and the attitudes that is projected by the consumers. The promotional techniques that are, used in the preset case are the use of the media. This helps in deriving the necessary drive in the fashion technology. The promotional methods that are used includes the factors like Media- there are different shows that help in making the perspective that tattoos are fashion choice by most of the celebrities. These shows or the media may help in generating the positive view with the inspiration of using tattoos in the real life (Guarino, 2010). Peer groups most of the young people who are part of using or making the tattoos is getting the inspiration from the fellow group. This makes them at par with the group and the ideas that are collectively, generated from the method. Peer groups could be a method that can help in the promotional techniques that is important to create the communication in the young group. Celebrities- there are many celebrities from the television or sports world who make use of tattoos to show different expression. Granger (2010) refer this in another promotional method that is used y the customers without any proper channeling. In all the above methods, the effectiveness of the use of tattoos is, channeled without the proper promotional and intentional methods. The ideas that are, related to the use of the tattoos are that is certain group this is taken to be a part of the culture. Apart from this culture, other methods like the television and the media that play an important role. Heine (2010) opine the major method that has been, used in the concept of culture in the imbibed culture that has been, retained by the customers. The basic determinant of the decision of a customer is the social heritage that has been, carried out. In some cases, there is mix of culture that comes from different decent that may play a pivotal role in the decision of a person. The most important aspect that is related to the sub culture o any person deals with the sub groups that makes use of the common experiences in the life and the situation that lead to the decision. The social classes in the present condition help in creating the values, interest and the behavior of the customers (Gwilt, 2006). The major reasons that has been, accessed is that Memories Art Love or passion These are the major consumer behavior that has been, attached to the making of tattoos to be a part of a persons life. The promotional techniques are that of the ways that has been, mentioned above, but the major aspect that play a control over the decision is not always culture. It may be, said in this regard that the Maslows theory of motivation that makes of the different stages (Burgess and Clark, 2010). Maslows theory of motivation The lowermost stage that has been, mentioned in the theory entails the basic needs. The safety needs are the ones that come just above the basic needs. The social needs come above the safety needs. The esteem needs is above the social needs and the first stage is the self-actualization method (Hodges and Karpova, 2010). In case of the tattoos, it might be, said that the social need is the most important aspect. This is because of the fact that in order to receive the social needs that a person involves in the process of getting a tattoo done. The connection that is, established in the unintended promotion is the inspiration that a person may draw from being a part of the society. The social needs that is responsible for the drive is being part of the new society. The tattoo has moved from being not so important aspect of fashion to the one that has been of the pivotal aspect of the consumer behavior. The scope of the customer in the present plays a key role and there have been a numb er of changes that is, crucial in this regard. The third change in the behavior f the customer includes the loosely connected values due to which consumer may be part of a culture (Lunceford, 2010). The best innovative ideas that could be, used are that tattoos have become one of the style statements that are being, used by most of the people these days. The thought that may be, evoked through tattoos is that there may be memories or there may be a sentimental sense that may be related to the idea of making a tattoo. The research that could be, applied in the present perspective is the drive that makes people makes tattoos and the reason for it (Johnson and Hokanson, 2014). Promotion and communication required in tattoo In order to reach the target customers the best method used as a method of marketing is the use of the social media sites. These days most of the people are, linked to Facebook and twitter. These are the best methods used in order to get the best response and to promote tattoos. Other than, this in order to create the business strategies and to make people, get attracted towards tattoo the best thing that could be, used in creating a page on Facebook. This would help in reaching the target customers. A accompany making tattoos can also make use of this method to create the positioning of the company or store in the market. As a method of creating customer loyalty, it is important to create a customer base that could be, made through the market channeling and promotional methods using the social networking sites. Marketing model and theories of Selfie The promotion of the method of selfie has been one of the aspects to draw the attention on the social media. There are different types of selfies that may be, clicked as per the requirement. This is to ensure the fact that the customers receive the due amount of respect and the amount of importance in the soil networking. The fashion statement that has been, used in order to get the due recognition is through the aspect of the clicking of the pictures (Jimei et al. 2010). There may be group selfie and there may be single selfie that may propose different types of moods that like funny or an enjoyable moment. There are different ways in which selfie can help in the marketing process: Information system of the market- The information that is necessary in creating the awareness is, found in the feedback that a selfie might possess. The uses of the products can be, provided or offered to the customers with the help of the feedback (Talmadge and Taylor, 2010). Branding- The position of the brand and the major aspects that the brand is offering to show to the customers is shown. The position of the brand in terms of the competition in the market is, shown with the help of the pyramids of the branding. Product- The potential of a product may be, used to transfer the ideas of the product through a clear selfie. The use of the products could be, clearly shown trough the method of pictures that may uploaded in the selfie. Price- Sheridan (2010) put forward the price helps in dealing with the value of the product and the changes require the help that is necessary to achieve the objectives of pricing. Distribution- The distribution process is, essentially based on the platforms that are, used as a method in the social media to channel the product. The most important method that could be, used these days is the mobile phone and the platform of social media (McClaud, 2010). Promotion- The products could be, used in a number of ways. The buyers usually make use of the selfie to now about the promotion of trust and the version of the customers. These days selfie in used in every aspect of the market starting from the stores to the super market. The image that comes helps in identifying the products and automatically helps in the promotion process. Celebrity in selfie Celebrities make use of the selfies these days in order to show their talent or could even due to skin show. Neil and Sager (2010) refer the range of celebrities may include the ones who are from different areas like that of the musical areas sport, television or motion films. In such case, an important method could be, used in order to make use of the promotional techniques. The controlled version of the celebrities is that of the ones that is, delved in the present case of the selfie. The promotional methods may also includes the selfies that can be, used in the clothes or the bags that they use. In case of the fashion world, this may be a promotional technique that is used in order to know more about the perception of the customers (Meng, 2012). This is to draw the attention of the, celebrities along with the products that they might endorse. It is important to note in the present case that there are different mediums like television and social media sites like Facebook and twitte r that could be, used in order to know about the perception of the customers. The most important aspects that could be, used in the context of selfie include: Selfie and the copyright issues Social media content in relation to the spectrums of alienability Current remedies with the issues of selfie Legal aspect Social identity model of deindividuation effects (SIDE model) This theory essentially deals with the attribute of anonymity that could be, used in order to deal with the social media aspect. In the present case, it has been found that the theories of the technology which deals with the deindividuation. This theory was, proposed in order to get the necessary information that could have helped an individual to make the mark in the public. The early ideas that were, proposed in the initial days of the theory explained the self-awareness and accountability. The SIDE model analysis the anonymity that may be used in the present case. The copyright and the retention of the images could be the method that may be, used to know about the concept of selfie. The SIDE theory however makes use of the concrete ideas that a person may have in posting or clicking a selfie. However, the concept deals that there may be methods that may be responsible to keep the silence of the social identities. A person might like to post despite the stereotype that might be exi sts in society. However, Park and Choi (2010) argues it is to be, noted that the methods has to be overcoming the stereotype. This is the major issue to concealing the aspects that may be regarded with the identity of the person who posts selfie. The major issue that is, found relating to the ides of selfie includes the one there are certain techniques that may be confusing. In such case the ideas may vary like in case of families the ideas of the selfie is the belongingness. Whereas in case of the celebrities the ones that may show the skin show, the ideas may not be very modest. In such case the promotions is the publicity that could be, used by the celebrities is to gain the identity. It is a method of promotion that may be, used in case of fashion and the communication process. This may be regarding a fashion brand that is trying to place itself in the market and to gain the value in the market. This is also to ensure the fact that the issues relating to the, skin show is to channel the brand and to help in gaining the recognition that they deserve. It is necessary for any of the company that is relating to fashion and technology to use the methods of the popularity in order to gain the position of the brand. It is necess ary that the celebrities or the people who are using the selfie make it evident to show and tailor the methods to use the communication methods that are, used in the modern technology to get the desired benefit (Patterson and Schroeder, 2010). The methods that could be as the strong perspective to create the methods of improvement and proper use of the process of selfie that could be, used to gain the amount of interest in the fashion process. The major methods and the areas of research that could be, used entail the fact that there are methods like selfie and the celebrity indulgence that could be accessed (Schulz, 2010). This would help in understanding two variables like the selfie and fashion and the same related to the celebrities. Promotion and communication required in selfie Selfie can be, used as promotional technique through the method of social media marketing. The best method of using the promotion and communication method is through social media marketing. The communication is, established through the sharing of the pictures on the social media sites. These are the best methods that could be, used in order to reach the customers and to help in communicating people round the world through selfie. Celebrities to promote their videos or the endorsements are part of Selfie. Apart from this, the target customers of these people could be, reached through the method of social media. The position of the product or the companies that the people endorse can be, promoted through selfies and the social media sites. Communication through the social media networking is easy and feasible with just few clicks. References Bailey, L. and Seock, Y. (2010). The relationships of fashion leadership, fashion magazine content and loyalty tendency. Journal of Fashion Marketing and Management: An International Journal, 14(1), pp.39-57. Boyle, G. (2010). Tattoos on the heart. New York, NY: Free Press. Buttle, H. and East, J. (2010). Traditional facial tattoos disrupt face recognition processes. Perception, 39(12), pp.1672-1674. Bye, E. (2010). Fashion design. Oxford: Berg. Bye, E. and Sohn, M. (2010). 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