Sunday, March 15, 2020
Nike Case Essays
Nike Case Essays Nike Case Paper Nike Case Paper What is the WACC and why is it important to estimate a firmââ¬â¢s cost of capital? Do you agree with Joanna Cohenââ¬â¢s WACC calculation? Why or why not? WACC is the weighted average cost of capital. It can be calculated as: WACC = (Weight of funding source 1) x (Cost of funding source 1) + â⬠¦ + (Weight of funding source n) x (Cost of funding source n) Usually this will be simply: WACC = (Percentage of debt) x (Cost of debt) + (Percentage of equity) x (Cost of equity) It is important to estimate a firmââ¬â¢s cost of capital for the appraisal of new projects; a project should only be undertaken if the return from it is greater than that of the capital required to fund it unless there are other compelling (strategic) reasons. A firm should also be aware of itââ¬â¢s own cost of capital and try to minimise this. We do not agree with Joannââ¬â¢s WACC calculation: ? Her funding source weightings are wrong ? There is an argument that all debt (including accounts payable etc) or net debt and a blended return on this should be used The debt figure will only ever be an estimate as the balance sheet is one day in the year ? Her analysis assumes Nike debt is trading at par ââ¬â it is not ? Equity should be based on market value, not book value ? Hence total will be based on market cap. , not balance sheet ? Her debt cost is wrong ? She should use the current or projected cost rather than a historic one ? i. e. use a Bloomberg terminal (other term inals are available) to research yields on debt of the same credit rating as Nike ? It is unlikely Nike has a cost of debt lower than T bills Raising debt in a foreign currency (Jap Yen) either carries an associated hedging cost or exposes the borrower to FX risk, hence the coupon rate on the notes is not the actual cost of the debt ? Her assumed tax rate is probably wrong, if a firm is paying anywhere near the statutory tax rate they are not doing their job properly. We would expect their actual tax rate to be much lower, even though the case does not show this ? Her equity cost is only an estimate and she has not used all of the tools available to her ? The CAPM only provides an estimate. Her inputs are based on assumptions: We do not know whether 20 year T bills are the most appropriate measure of the risk free rate. If NorthPoint is planning a 20 year investment they might be but we need more information. Any proxy for the RFR will only ever be an estimate ? The market risk prem ium is even harder to estimate. Although the geometric mean is the better measure she has used numbers based very old data. Markets may well have changed since 1926 and hence a more recent or even anticipated premium should be used ? Nikeââ¬â¢s Beta appears to be on a downward trend so an average might not be the best estimate. A forward looking Beta based on the outlook and expectations for the business would be better ? Because equity markets are forward looking (12 to 18 months) the current Beta is probably the best estimate ? Nike has been very volatile compared to the SP 500 so the historic Betas smooth reality ? By only considering the CAPM she ignores other methods for calculating the cost of equity and potentially makes a mistake ? A better approach would be to calculate the cost of equity using all available methods then make an estimate based on a larger range of data If you do not agree with Cohenââ¬â¢s analysis, calculate your own WACC for Nike and justify your assumptions [pic] Assumptions: ? Market value of debt ? Better reflection of actual value of source of funds ? We want to be forward looking, par is a historic number ? Running yield on bonds rather than YTM ? Quicker and easier to use ? Not much difference between them (7. 2 vs. 7. 0) o Capital gain on bond is small over life ? Any new debt would have an issue cost so YTM is not a true measure of funding cost ? Effective tax rate from 2001 The best proxy we have ? Still donââ¬â¢t like this number, feels too close to statutory rate. Interest is low so not much tax shield but what about capital allowances and general mitigation schemes? ? Most current equity market price ? Best information we have ? CAPM cost of equity ? See question 3 below for fuller description of methods ? CAPM is not perfect but: o Dividend Discount Model is too heavily dependent on a ââ¬Ëblack boxââ¬â¢ nu mber for dividend growth ââ¬â we have no understanding of this number o Capitalisation Ratio is quite a crude approach Calculate the costs of equity using CAPM, the dividend discount model, and the earnings capitalisation ratio. What are the advantages and disadvantages of each method? CAPM: [pic] Risk Free Rate is an average of 1, 5 and 10 year T bills. We assume this as a proxy for Nikeââ¬â¢s actual debt profile. We use the current Beta because equity markets are forward looking. If we assume efficiency then all known information is in the current Beta. Betas will change over time so historic data is less relevant; we need to predict the future. Using regression our forecast Beta is 0. 0 so the results are very close. We use 9. 2% as a risk premium. It comes from Brealey Myers (2000) and is for the SP 500. It is the number that would have been available and appropriate for Kimi at the time. We may use a different number today based on our expectations of market returns although Brealey Myers argue that the best approach is to use as much data as possible to remove the effects of market fluctua tions. We have to ask ourselves whether market behaviour from 2008 onwards is the new paradigm. Advantages: ? Recognises return for risk Only considers risks that cannot be eliminated by diversification ? Is the most simple way of doing both of these ? Widely used so widely understood ? Does not rely on company financial projections Disadvantages: ? More of an art than a science. Includes estimates and assumptions for ? Risk free rate. Govt. bonds are not always the best proxy, i. e. some European debt. Also, RFR is probably not a real return due to inflation ? Expected market return. If we knew this number we would not be working for a living ? Beta. Decisions a company makes will change Beta. Depending on what the company is doing historic data may be worthless and hence we need to make our own estimate ? Assumes that Beta is the only reason equity prices move ? Assumes equity indices as proxies for movements in all asset values. This is a simplification of reality as many companies are privately owned ? The perceived required risk premium will change over time ? Investors will have different required rates of return for Nike depending on whether or not they hold it in a portfolio Dividend Discount Model: Problem:Dividends have been constant for the last 3 years. We are being asked to believe a growth story and perhaps an increase in dividend from that. We have no guidance on future dividend levels so the best we can do is use the Value Line Forecast of 5. 50%. Assuming constant growth and using the Gordon Model: Expected Return = Expected Dividend Yield + Expected Growth = 6. 6% Advantages: ? Very simple (in the constant growth form) ? Based on actual cashflows to shareholders Disadvantages: ? The simplified version of the equation we have used assumes the stock is in equilibrium ? Assumes a constant dividend growth rate, this is highly unlikely We do not have sufficient information to predict non-constant growth dividends to put into the full DDM ? Highly dependent on the expected growth rate which we actually have very little idea about ? Assumes we hold the stock in perpetuity. This is not likely for NorthPoint; as a value based fund they will sell at some point to realise a gain (hopefully! ) and re-invest in something they perceive to b e undervalued ? Assumes dividends grow with earnings. We could negate this by assuming dividend irrelevance and basing the analysis on earnings per share Earnings Capitalisation Ratio: Capitalisation Rate = Projected Earnings / Price Method used:Divide forecast free cashflows by current EV Take average Capitalisation Rate = 8. 6% Advantages: ? Quick and simple ? Can be used when no dividends are paid, hence payout ratio is irrelevant Disadvantages ? Relies on projections which are subjective and uncertain ? Compares future earnings to current EV ? Ignores the time value of money ? Solving the Corporation Valuation Model for WACC would be a better approach What should Kimi Ford recommend regarding an investment in Nike? Based on our WACC of 10. % Nike appears to be undervalued (using Joannaââ¬â¢s model, which we have not checked) so Kimi should recommend a buy. However, Kimi should consider the following: ? Do you really want to buy into a promised growth story? Earnings have been flat for a while; do you believe the growth projections? ? How does market price compare to intrinsic value? ? Is the market efficient? Have we really picked up something that no other analyst has or is everything in the price? ? Does the market even recognise fundamental value or is it driven by other things (fear and greed)? Competitors ââ¬â we have only analysed one company. It is not possible to invest on this basis alone. The price of Nike must be compared to a suitable peer group ? Other investment appraisal methods should be used for comparison ââ¬â P/E ratios etc ? Charting (investing technique) could also be considered ? Use her experience (of competitors etc) to estimate a Beta Final recommendation: Growth is uncertain and hence the value of the equity may fall further. This business has low levels of debt (low risk) paying 7% while the required equity return is 11%. Do not buy the equity. Set up an SPV, leverage this as highly as you can and buy the debt. Even if you can only achieve 50% leverage and 5% cost of borrowing (which should not be too ambitious) then you will achieve an 18% return on your equity in the SPV, all whilst invested in a far safer part of the Nike capital structure. Bibliography BREALEY, R. A. and MYERS, S. C. (2000) Principles of Corporate Finance. Sixth Edition. London: McGraw Hill BRIGHAM, E. F. and HOUSTON, J. F. (2009) Fundamentals of Financial Management. Twelfth Edition. Mason: Cengage
Thursday, February 27, 2020
Peasant Life in Elizabethan England Research Paper
Peasant Life in Elizabethan England - Research Paper Example The neediness hit individuals made due with constrained assets and were drained by the rich in each and every condition receptive. Religion was a key part of life in the lives of the individuals in the Elizabethan period with Roman Catholic as the prevailing religion. This paper focuses on the lives of the peasants inside the Elizabethan time of time. Religion was a key part of the Elizabethan life. The Church was the wellspring of both assistance and treachery for poor people. The Justice of Peace (Jps) were assessment authorities profited in every ward that gathered a duty from the individuals who claimed land in the area. It was known as the Poor Rate and was utilized to help poor people (Mcginnis 203). The Poor Rate had two functions in the social order. First and foremost, it made the poor feel that something was being ruined them and made them feel less furious about the neediness. Besides, some great work could be carried out by the poor inside the area to help that ward. Along these lines, the Justice of Peace went about as administrators of the poor throughout the Elizabethan period. The poor were sorted into three aggregations by the administration. To start with, there were the defenseless poor (Mortimer 26). This assembly incorporated the old, the debilitated, the disabled and the stranded youngsters. Seniors and the crippled had been given a differing measure of cash and sustenance proportions on week after week foundation. At whatever point they were unable to gather their endowments, they could be transported to their living arrangement. Poor youngsters got an extraordinary apprenticeship secured due to the ward. In this way, the ward profited from the free work until the youngster became a mature person and deduce new dexterity. The powerless poor were not viewed as a trouble to the legislature. Ordinarily, the wards offered them the permit to ask (Claments). The second classes were distinguished as the capable poor. These people were
Tuesday, February 11, 2020
Diabetes Assignment Example | Topics and Well Written Essays - 1250 words
Diabetes - Assignment Example Metabolism is the functionality of the body cells to convert the food and its constituents to attain energy. It helps the cells to grow and divide. The food that our body digests is converted to most simple type of sugar that is glucose. Glucose is entered into our blood stream by our digestive system. Blood transports the glucose to the cells. Insulin is the hormone that helps the glucose to enter the cells. Without insulin our cells are unable to absorb the glucose. Pancreas produces insulin and maintains the level of insulin in the blood. The hormonal system distinguishes how much insulin should be produced to absorb the glucose. It also stabilizes the amount of glucose that is present in the body by producing different amount of insulin according to the diet we intake. Diabetes is a condition in which either body is unable to produce set level of insulin or produce no insulin or the cells of the body do not respond to wards the insulin. The condition may also occur if the pancreas fails due to imbalance hormonal system or any other condition. Without the insulin, the body is unable to convert the glucose into energy. The blood has increased level of glucose. Some glucose is expelled out of the body through urine. The cells are unable to gain the glucose. Besides polyphagia (frequent urination), polydipsia (increased thrust) and polyuria (increased hunger) are the common symptoms of the diabetes, diabetes may cause immense damage to other systems of the body. Following complication may occur as the result of untreated diabetes. Eye complications (eyesight got affected due to diabetes),Ã Foot complications (foot muscles are unable to heal and foot wounds are unable to heal and take more time to heal),Ã Skin complications (skin lacks the sensitivity),Ã Heart problems,Ã Hypertension (lack of energy and glucose to the cells may bring the condition of hypertension), Mental health (The
Friday, January 31, 2020
Educator Resume Essay Example for Free
Educator Resume Essay EDUCATOR Sociology / Psychology / Human Services Goal-oriented Professional with an education in Social Services pursuing a teaching career at a local junior college in the areas of sociology, psychology, and human services.à Currently completing a Masters Degree in Social Work and an Internship as a Group Facilitator at Brighton Rock. Prior professional experience includes 10 years with DePaul Medical Center and a part-time position at Sentara in the Healthcare Administration field.à Dynamic Leader known for being caring and compassionate, who enjoys helping the community through case management, referrals, needs assessment, and goal setting. à Excellent communication skills with an ability to provide superior social services to individuals, families, and community organizations in a faith-based setting.à In-depth knowledge of Medicare, Medicaid, and third-party payment plans.à Technically proficient in Microsoft Office Suite and Windowââ¬â¢s Operating Systems. Functional Areas of Expertiseà à à à à à à à à à à à à à à à à à à à à à à à à à à à Personal Assets à Fundraising Grant Writing Skills Psychosocial Assessments Program Development Support Group Facilitator Case Management Medicare / Medicaid Knowledge Community Outreach Programs Event Planning Office Management Customer Service Excellence Highly Organized Detail-Oriented Analytical Skills Hard Working / Reliable Self-Motivated Team Player / Positive Attitude Caring Compassionate Excellent Time Management Skills Oral / Written Communication Crisis/Problem Resolution Skills Excellent Interpersonal Skills EDUCATION Norfolk State University Masters Degree in Social Work, Graduating in May 2008 Bachelor Degree in Social Work, 2005 Tidewater Community College Associates in Applied Science in Liberal Arts, 2002 COLLEGE COURSEWORK Human Behavior in the Social Environment Social Work with Individuals Social Work with Groups+ Social Work with Families Fundraising and Grantsmanship Differential Assessment for Social Work Practice Community Mental Health Policy and Services Case Management in Social Work Advocacy and Social Planning Research Method Continueâ⬠¦page 1 of 2 INTERNSHIP EXPERIENCE Brighton Rock, Inc., Portsmouth, VAà à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à 2007-2008 Social Work Internship Serves as Facilitator for Grandparents as Parents Support Group. Assists with fundraising and grant writing projects. Effectively plans conferences and workshops for grandparents. Sentara Norfolk General, Norfolk, VAà à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à 2006-2007 Social Work Internship Assisted in providing Psychosocial Assessments and Counseling for individuals with chronic illnesses and providing them with community resources. Evaluated, monitored, and assessed client outcomes and maximized the ability of families to move through the assessment process. Determined psychosocial stresses, coping mechanism and long term adaptation to chronic illness. PROFESSIONAL EXPERIENCE à Gethsemane Baptist Church, Norfolk, VAà à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à 2006-Present Director of Ministry Provides leadership development and oversight for ministry staff and volunteer services. Oversees the ministry programming and consults with ministry leaders in the implementation of a comprehensive ministry strategy. Recruits ministry staff and trains servant leaders in their specific area of ministry expertise. Develops community outreach programs. Transplant Sentara Norfolk General, Norfolk, VAà à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à 2002-2006 Financial Coordinator Conducted the initial financial interview with patients. Screened and educated them on transplant process, policies, and procedures. Utilized established procedures for pre-certification, preauthorization, and letters of medical necessity. Coordinated the process for all transplant services. Maintained a comprehensive library of resource materials for patients, families and medical staff. Identified patients who qualified for indigent programs such as medications and charity care. Assisted patients with billing questions and collection notification. à DePaul Medical Center Rehabilitation, Norfolk, VAà à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à 1998-2002 Office Manager Managed all daily office activities, provided administrative support for the site Director, and prepared monthly budget reports. Created and implemented office administrative procedures. Effectively mediated and resolved patient complaints and problems. DePaul Medical Centers Clinic, Norfolk, VAà à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à à 1990-1998 Office Administrator Conducted interviews with patients to establish eligibility at Clinic. Provided educational materials for uninsured and underinsured patients. Significantly increased patient experience and provided administrative support to medical staff. COMMUNITY VOLUNTEER SERVICE Norfolk Drug Court Foundation Norfolk Detention Center Advisory Board Member Second Chances Ex-Offenders Fundraising Campaign Norfolk State University Community and Outreach Program National Association of Social Worker Association of Black Social Worker, Norfolk, VA Gethsemane Baptist Church, Norfolk, VA Kinship Connection Inc.
Thursday, January 23, 2020
Snakes And Ladders :: essays research papers
à à à à à Snakes and Ladders by Gita Mehta is a book that celebrates India and its history. The author provides many short stories that try to show how India is trying to develop as a nation. She tells about the complex religious system, as well as cultural diversity, and the corruption of Indiaââ¬â¢s government. She shows the reader many aspects of the experience of living in India, which Mehta clearly shows that she loves, but she attempts to remain neutral about the issues that she discusses. à à à à à When the Indian nationalists were revolting against the British Empire, it changed the way of life in India. It let women have a more active role in everyday activities. Mehtaââ¬â¢s father played a very active role in the revolutions; he used his house as a place for Indian nationalists to hide out for this he was placed in jail for several years. Her uncle was sentenced to seventeen years in a torture camp for different charges. Yet when asked what their worst memory of being under British rule was, they simply provided a simple story with not much significance. Now instead of being under British rule, the India people are under the rule of leaders that view themselves as being the person who drove the British out of India. One thing remains the same though, the people of India view their land as being their own, and that is what is important to them. à à à à à One of the major problems facing India is poverty among its people. India is one of the ten most industrialized countries in the world, they graduate around five million people from college each year, and they even have a space program more advanced than most European countries. Yet the people of India are still starving, they do not produce enough jobs for all of the college graduates, and despite the fact that they can travel into space, India has underdeveloped irrigation, and electrical grids. à à à à à On the outskirts of Delhi, the author found people rummaging through garbage dumps. At first she thought that they were just homeless bums, but when she went into the dumps herself she found out that the people had been of a higher class, but tragedy landed them here. The people in the dumps were women and children searching though the dumps for scraps of iron, glass, or cloth. They would then sell these items to a contractor for money.
Wednesday, January 15, 2020
 Cybercrim in Society Essay
Cybercrime With everything in society advancing rapidly, it should be of no surprise that technology is now used to commit crimes against other people. Those crimes include identity theft, stealing money, illegal gambling, and cyberstalking. This paper will review cybercrime and the differences there are from traditional crime and it will review the purpose of hackers. There will also be three cases reviewed to help bring light to what kind of cybercrimes are being committed around the world. Differences between Cybercrime and Traditional Crime For an individual to fully understand the difference between cybercrime and traditional crime, the individual needs to understand what cybercrime is. The definition of cybercrime is according to ââ¬Å"Oxford Dictionariesâ⬠(2014), ââ¬Å"crime conducted via the internet or some other computer networkâ⬠(cybercrime). Cybercrime is committed by hackers with the goal of financial gain in min by stealing personal information(bank information, credit card information, etc) from individuals. Traditional Crime is a considered crimes against the public. There are many different categories for cybercrime but the main four include identity theft, illegal gambling, cyber terrorism, and cyber stalking. Both cybercrime and traditional crime are charged on a state law level; however, there are plenty of federal laws that can be violated through committing cybercrime. The main difference that needs to be known is that when cybercrimes are committed, the crimes are done so from the luxury of a hackerââ¬â¢s house or place of business while traditionally crimes are not. Another difference worth noting is that cybercrime criminals have the ability to commit these crimes from different states, even internationally at some levels. When cybercrimes are committed liken that, it makes it hard to prosecute as the laws may vary from place to place. That is usually when federal laws are reviewed for a prosecution to happen. Purposes of Hacking Hacking dates back to the 1950ââ¬â¢s. This is long before the birth of the internet. Hacking began as a method or searching for shortcuts when encountering a computer issue. According to ââ¬Å"Marriam Websterâ⬠(2014), A hacker is ââ¬Å"a person who secretly gets access to a computer system in order to get information, cause damageâ⬠(para. Hacker). Today hacking of oftenà referred to a person wanting to cause havoc in a computer or many computer systems for a reason. Hacking has evolved over the years. In the beginning, hacking was often used to prank, cause mischief and curiosity. Hacking today has grown very large and has been categorized into the types of hacking. Although hackers use different methods of accessing unauthorized information, the most common reason for doing such things is for financial gain. Kevin Mitnick vs the USA Kevin Mitnick began hacking at an early age of 12. As this age he began making punch cards for the Los Angeles transit authority. Mitnick also joined a phone phreak gang which conducted many pranks. The group discovered a way to take over the telephone directory assistance and prank incoming callers. The group also changed the status of home phones to payphone status. A home telephone user would attempt to use the telephone but a recording would request the user to deposit twenty cents. The group accessed a San Francisco based company and destroyed files. More than a year later, this crime was unsolved. It was not until a memberââ¬â¢s girlfriend went to the police. This led to the arrest of Kevin Mitnick, age 17, and other members of the group. Mitnicks streak of hacks has landed him in jail multiple times throughout his hacking spree. At the age of 16, Mitnick accessed a computer manufacturing company and sold their software. He went on the run for several years by accessing companies via computers to produce identity documents. He was not convicted of these crimes. He was eventually arrested for hacking into Nokia and Motorola and convicted. This arrest landed him in jail for four and-a-half years before being brought to trial. Upon his release in 2000, he was restricted from using any communications technology which was more advanced than a wired home phone. Mitnick contested this ban and won. He now owns Mitnick Security Consulting LLC. The RBS World Pay servers WorldPay is a Payment Card Industry that helps businesses in payments processing. WorldPay headquarters is based in Atlanta, Georgia and have expanded globally in London, Belfast, Edinburgh, Gateshead, Sweden, Singapore, Montreal and a few other countries. WorldPay payment processing service enabled businesses to accept payments from customers from differentà payment types such as, Visa, MasterCard, discover, American Express, debit and gift cards, checks, Electronic benefits Transfer, and direct debit. The WorldPay hacking was considered the most sophisticated attack so far in history. In November 2008, According to Baker, Associated Press (2012) hackers infiltrated the RBS WorldPay servers and accessed prepaid payroll card numbers, cracked their encrypted pin codes, raised the balances on the cards and distributed dozens of them to a team of people around the world. Within a matter of hours, the same group of hackers hit 2,100 ATM terminals in 280 cities around the world from the U.S. to Russia.to Italy to Japan. FBI tracked down the hackers by narrowing down their suspects to one man who worked for the company and his name is Oleg Covelin. After he found a vulnerability in the computer network that RBS WorldPay uses, he passed the information to Sergei Tsurikov of Tallinn, Estoria who then distributed 44 counterfeit cards to a team of cashers around the world. The hackers tried to cover their tracks but the FBI traced the hackers by using Cyber forensics and also with the help of foreign authorities and international banks. Sergei Tsurikov, Viktor Pleshchuk of St. Petersburg, Russia, and Oleg, Covelin of Chisinau, Moldova and three others from Estonia were indicted in the case in 2009. Three of the main suspects were convicted in Estonia and the other suspects are awaiting sentence. In conclusion, although traditional crime is still around, cybercrime is slowly making its way into society and the advancement of technology is helping that happen. The only difference between the two types of crimes is the way they are committed. Hackers will not let anything stop them from achieving the ultimate goal of successfully hacking a system. With the cases listed and reviewed it is clearly stated that hacking and cybercrimes can be committed by anyone for any certain reason. No one can be sure that their information is completely safe but it is better to take precaution by not putting so much personal information on the web than it would be to not worry and end up the victim of cybercrime. Hackers continue to expand their knowledge on the systems to hack so that should push society to expand the security for the web. References Baker, M. (2010). Policeone. Retrieved from http://www.policeone.com/federal-law-enforcement/articles/2187579-FBI-gets-suspect-in-massive-cyber-crime-case/ Busch, A. (n.d.). Why Do People Hack. Retrieved from http://www.ehow.com/about_4673738_why-do-people-hack.html ââ¬Å"Hacker.â⬠Merriam-Webster.com. Merriam-Webster, n.d. Web. 3 May 2014. http://www.merriam-webster.com/dictionary/hacker Meriwether, D. (1995). Takedown. Retrieved from http://www.takedown.com/bio/mitnick.html Orphanides, K. (2011). Top 10 Most Spectacular Hacks. Retrieved from http://www.expertreviews.co.uk/general/1285633/top-10-most-spectacular-hacks/2 Oxford Dictionaries. (2014). Retrieved from http://www.oxforddictionaries.com/us/definition/american_english/cybercrime
Monday, January 6, 2020
New York Passes a Married Womens Property Act, 1848
Enacted: April 7, 1848 Before married womens property acts were passed, upon marriage a woman lost any right to control property that was hers prior to the marriage, nor did she have rights to acquire any property during marriage. A married woman could not make contracts, keep or control her own wages or any rents, transfer property, sell property or bring any lawsuit. For many womens rights advocates, womens property law reform was connected to suffrage demands, but there were supporters of womens property rights who did not support women gaining the vote. Married womens property law was related to the legal doctrine of separate use: under marriage, when a wife lost her legal existence, she could not separately use property, and her husband controlled the property. à Although married womens property acts, like that of New York in 1848, did not remove all the legal impediments to a married womans separate existence, these laws did make it possible for a married woman to have separate use of property she brought into marriage and property she acquired or inherited during marriage. The New York effort to reform womens property laws began in 1836 whenà Ernestineà Roseà and Paulina Wright Davis began to gather signatures on petitions. In 1837, Thomas Herttell, a New York city judge, attempted to pass in the New York Assembly a bill to give married women more property rights. Elizabeth Cady Stantonà in 1843 lobbied legislators to pass a bill. A state constitutional convention in 1846 passed a reform of womens property rights, but three days after voting for it, the delegates to the conventions reversed their position. Many men supported the law because it would protect mens property from creditors. The issue of women owning property was linked, for many activists, with the legal status of women where women were treated as the property of their husbands.à When the authors of theà History of Woman Suffrageà summarized the New York battle for the 1848 statue, they described the effect as to emancipate wives from the slavery of the old common law of England, and to secure to them equal property rights. Before 1848, a few laws were passed in some states in the U.S. giving women some limited property rights, but the 1848 law was more comprehensive. It was amended to include even more rights in 1860; later, married womens rights to control property were extended still more. The first section gave a married woman control over real property (real estate, for instance) she brought into the marriage, including the right to rents and other profits from that property. à The husband had, before this act, the ability to dispose of the property or use it or its income to pay for his debts. à Under the new law, he was not able to do that, and she would continue her rights as if she had not married. The secondà section dealt with the personal property of married women, and any real property other than she brought in during marriage. à These too, were under her control, although unlike real property she brought into the marriage, it could be taken to pay debts of her husband. The third section dealt with gifts and inheritances given to a married woman by anyone other than her husband. à Like property she brought into the marriage, this also was to be under her sole control, and like that property but unlike other property acquired during marriage, it could not be required to settle her husbands debts. Note that these acts didnt completely free a married woman from economic control of her husband, but it did remove major blocks to her own economic choices. The text of the 1848 New York Statute known as the Married Womens Property Act, as amended in 1849, reads in full: An act for the more effectual protection of the property of married women:à §1. The real property of any female who may hereafter marry, and which she shall own at the time of marriage, and the rents, issues, and profits thereof, shall not be subject to the sole disposal of her husband, nor be liable for his debts, and shall continue her sole and separate property, as if she were a single female.à §2. The real and personal property, and the rents, issues, and profits thereof, of any female now married, shall not be subject to the disposal of her husband; but shall be her sole and separate property, as if she were a single female, except so far as the same may be liable for the debts of her husband heretofore contracted.à §3. Any married female may take by inheritance, or by gift, grant, devise, or bequest, from any person other than her husband, and hold to her sole and separate use, and convey and devise real and personal property, and any interest or estate therein, and the rent s, issues, and profits thereof, in the same manner and with like effect as if she were unmarried, and the same shall not be subject to the disposal of her husband nor be liable for his debts. After the passage of this (and similar laws elsewhere), traditional law continued to expect a husband to support his wife during the marriage, and to support their children. à Basic necessaries the husband was expected to provide included food, clothing, education, housing, and health care. à The husbands duty to provide necessaries no longer applies, evolving because of an expectation of equality of the sexes.
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