Monday, March 19, 2012

Pope Shenouda, religious peacemaker and Mubarak ally

CAIRO (Reuters) - Pope Shenouda, who died on Saturday at the age of 88, was Egypt's highest Christian authority, working for more than 40 years to keep the peace between the Muslim majority and the Christian minority.

On the occasions when Christian protesters took to the streets to complain about discrimination against them, the late Coptic Pope chose to stay silent so as not to inflame tensions.

When Egypt's Islamists won the majority of seats in parliament earlier this year in a move that privately alarmed many Christians, he chose to keep his counsel for the same reason.

"The church decided to take a silent stance and wait to see what would happen," a church official said.

Pope Shenouda was appointed the 117th Pope of Alexandria, the state's highest Christian rank, in November 1971, and was respected by Egypt's Christians and Muslims alike.

Christians constitute the largest minority group in Egypt, the Arab world's most populous nation of over 80 million people. Most Egyptians are Sunni Muslims, but it is estimated that there are around 12 million Christians too.

In the last three years, Egypt has been convulsed by an average of two serious outbreaks of sectarian violence a year. Hundreds were killed and thousands injured.

On most occasions, the Egyptian church under the leadership of Shenouda refrained from making any public criticism of the Egyptian authorities even when his its followers protested, complaining of discrimination and lax security around churches.

Shenouda and the Coptic church endorsed ousted Egyptian President Hosni Mubarak when he ran for his fifth term in 2005, reflecting the views of many Copts, who saw Mubarak as a bulwark against Islamists such as the powerful Muslim Brotherhood.

Shenouda's detractors sometimes accused him of authoritarian tendencies. In the mid-1990s, he faced a backlash within his own church over allegations he was marginalizing or ex-communicating priests who did not agree with his policies.

His decision to reject Egypt's 1979 peace treaty with Israel and to speak out against a small Islamist insurgency in the 1970s that targeted some Christians temporarily saw him lose his freedom.

President Anwar el-Sadat banished him to the Wadi el Natrun monastery northwest of Cairo, accusing him of fomenting sectarian strife and meddling in politics. He was also stripped of his temporal powers.

He was released and given back his authority by Mubarak in 1984, three and a half years after Sadat's assassination.

EARLY CONTACT WITH THE CHURCH

Born on August 3, 1923, Shenouda started to take religious classes in Egypt's Coptic Orthodox Church at the age of 16, continuing his studies at Cairo University until his graduation in 1947 with a Bachelor of Arts in History.

He then joined the Coptic Orthodox Seminary, and later entered the seminary's faculty after graduating from college.

In 1962, the late Pope Cyril VI asked him to become the Bishop of Christian Education and President of the Coptic Orthodox Theological Seminary.

In November 1971, Shenouda became the 117th Pope of Alexandria, the state's highest Christian rank. He appears to have been widely respected by both Muslims and Christians.

"He is a very wise man. He always placed the interest of the nation above any other thing," said Mustafa el-Fiki, a political analyst and a former member of Mubarak's ruling party in a televised interview in January.

"I remember that President Mubarak has suggested to him to make the death of Christ a national holiday like Christmas but he refused, saying that Muslims agree that Christ was born but don't agree on his death," Fiki added.

Shenouda travelled to Europe and the United Sates many times in recent years for medical check ups and minor surgery. Most recently, on March 14, he had visited the United States for medical tests.

(Editing by Andrew Osborn)

Source: http://news.yahoo.com/pope-shenouda-religious-peacemaker-mubarak-ally-221348262.html

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Sunday, March 18, 2012

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Weaver v. Houchin ? Inventorship Lessons

Case No. 2011-1327 (Lourie, Bryson, Moore) (nonprecedential)

Keeping with the topic of inventorship after the previous post on Bard, the dispute in the recent nonprecedential case Weaver v. Houchin offers some supplementary lessons for inventors left out of an application. There have also been some intriguing issues lately involving third-parties and inventors trying to interfere with issued patents, addressed in the lessons below.

Robert Houchin is the sole named inventor on US Patent 7,316,614, directed to sweepstakes methods and apparatuses. During prosecution, four interlopers unsuccessfully attempted to be unilaterally added as inventors in the application. Following issuance of the ?614 patent, the same interlopers brought an action under ? 256 to be added as inventors. Three of the four dropped the suit, leaving just one interloper plaintiff, Johnney Weaver. The district court granted summary judgment for Houchin, finding that Weaver had not shown inventorship. Weaver appealed . . .


The four interlopers all testified to each other?s co-inventorship; essentially each plaintiff corroborated the claims of involvement in the ?614 patent?s methods and apparatuses. The omitted inventors also proffered related sweepstakes manuals and photographs showing various related games invented by some of them. Third-party testimony from a witness not involved in the invention of the ?614 patent also corroborated the co-inventor allegations.

The Federal Circuit agreed that none of this evidence gave rise to a question of fact that would defeat summary judgment; indeed, the opinion suggests the evidence was nearly worthless. As for the plaintiffs? self-corroboration, this is generally insufficient in inventorship disputes:

without corroboration, the oral testimony cited by Mr. Weaver is simply insufficient as a matter of law to meet the clear and convincing standard of proof required to establish co-inventorship. ?Throughout the history of the determination of patent rights, oral testimony by an alleged inventor . . . is regarded with skepticism, and as a result, such inventor testimony must be supported by some type of corroborating evidence.? Price v. Symsek, 988 F.2d 1187, 1194 (Fed. Cir. 1993).
. . . Mr. Weaver, along with his co-plaintiffs, submitted his evidence of co-inventorship to the court in the ?Plaintiffs? Description of Each Plaintiff?s Contribution to the Patent and Supporting Evidence? (Inventorship Description). Most of the evidence, however, is testimony from Mr. Weaver and his alleged co-inventors, which is legally insufficient proof of corroboration. Medichem, 437 F.3d at 1171.

The court also dismissed the third-party testimony as irrelevant, requiring that corroborating testimony include personal knowledge of a purported co-inventor?s contribution, like direct presence or participation in the inventive process.

The manuals and photographs of related gaming systems were also insufficient; the sweepstakes disclosed in these pieces of evidence were either invented by other plaintiffs (not Weaver) or had no proven tie to the subject matter of the ?614 patent. Particularly, Weaver had testified that ?[t]here may be one thing . . . that I kind of really contributed to? ? ?a credit card style card, and that was kind of my suggestion,? but the undated photograph of Weaver?s system did not show anything about a credit card style card as used in the ?614 patent. Because of the legal insufficiency of Weaver?s evidence of co-inventorship in the ?614 patent, the Federal Circuit upheld summary judgment dismissing Weaver?s claim.

Lessons: To avoid losing out on inventorship, the take-away here is as simple as making sure to document contributions to an invention, particularly when working with independent or separately-employed collaborators to whom you don?t otherwise owe a duty of assignment. Post-hoc testimony, even if corroborated by third parties and other non-joined inventors, will not suffice. Indeed, the Weaver panel seemed to very much be looking for corroboration from a named inventor or someone intimately involved in the conception and patenting process. Several other self-authenticating (or even merely sufficiently credible) documenting means could also work ? a timely email sent through a third-party server to a co-inventor describing contributions, dated and complete manuals or documentation of conception or possession of the invented subject matter, a routine and secure inventor?s journal describing contribution on relevant dates, etc.
On the flip-side, as discussed in the Bard and Falana posts, applicants and assignees should vigilantly identify anyone who could be considered an inventor (or to whom inventive subject matter has been disclosed) and either ensure those individuals have an assignment obligation (preferred) or have good evidence that those individuals are not inventors.

Also, in this vein, Brian Schar at American IPA brings up an interesting point from the recent Yahoo-Facebook patent dust-up, where a former Yahoo inventor is suggesting that his asserted patents are ?nonsensical.? Perhaps assignees should further consider binding all identified potential inventors not only to duties of assignment, but also duties of cooperation, or at least non-disparagement, in procuring ?sensical? patents. I?m no First Amendment or criminal lawyer, but I wonder how such non-disparagement agreements and 18 USC 1001 requirements would play out for an inventor who believes (or comes to believe) that his or her patent is invalid.

Comment: No surprises here for me ? the ?614 patent had been the subject of a petition to make special based on ongoing infringement. I?d speculate that the interlopers were somehow loosely involved with the inventor Houchin, saw a gravy train, and tried to hop aboard. Summary judgment was a good conductor for that train.

When the interlopers tried to get added before the USPTO, the Office denied them on the ground that it does not ever arbitrate third-party inventorship disputes. Could Weaver have filed an identical application, naming himself and all others as inventors, to provoke an interference? Would inventorship be decided or corrected in such a proceeding under 37 C.F.R. ? 1.48(j)? I really have no idea if this is possible, but if it is, then it appears the USPTO does arbitrate third-party inventorship disputes. Further, under the new derivation proceedings, it seems all the USPTO will do is referee inventorship.

Source: http://alleylegal.com/2012/03/weaver-v-houchin-inventorship-lessons/

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Friday, March 16, 2012

Increase business productivity in poor economic times | training ...

This is according to Tjaart Minnaar, MD of OIM International, one of South Africa?s leading business consultancy firms. ?In poor economic climates, employers must understand that the destiny of the company, to a large extent, is in the hands of its employees. The only way to manage costs, quality, service levels and commitment, is with the buy in and determination from employees,? he says.

Clear understanding of business direction

?In order for employees to identify areas where they could improve, they must have a clear understanding of the overall business direction and critical success factors, as well as exactly what is expected of them. Only then can they visualise their role in the organisation and how their daily output affects overall results,? says Minnaar.

Even if employees do know exactly what they should focus their energy on each day, they cannot deliver on this unless they have access to all the necessary resources and skills. Often people are willing to do a good job, but are restricted due to ineffective processes, inferior equipment and a lack of appropriate skills. Training can be an expensive exercise ? but not nearly as costly as the ultimate cost of incompetence.

Leaders must set the example

A crucial requirement in challenging times is credible leadership. Difficult economic realities will always create insecurity and dependable leadership will go a long way towards creating stability and trust among employees. It is essential that employees observe that leaders are serious about living the values and driving the strategic goals within the realities of the external business environment. Set an example and be positive, yet realistic and communicate honestly and directly ? both about positive and negative aspects.

Create communication forums

Coupled with credible leadership, line managers must create an environment that inspires employees to actively participate in business performance. According to Minnaar managers should create operational communication forums where they effectively and sufficiently engage employees so that they own their jobs and have a willingness and incentive to continuously improve on cost, quality and service.

Employers must ensure that performance discussions are conducted as an integral part of the company?s daily operations. Managers should provide regular feedback on business, team and individual performance and hold people accountable. Give recognition and reward for good performance and decisively improve substandard performance with support and/or consequence management.

Article source: http://www.bizcommunity.com/Article/196/534/72347.html

Source: http://trainingsouthafrica.co.za/?p=1975

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Tendulkar scores cricket's first 100th century

ALTERNATE CR0P OF DEL150 - Indian cricketer Sachin Tendulkar kisses his helmet after scoring his 100th century during the Asia Cup cricket match against Bangladesh in Dhaka, Bangladesh, Friday, March 16, 2012. Tendulkar, who had been stuck on 99 centuries for a year, became the first cricketer to score 100 international centuries on Friday when he hit to square leg and ran a single against Bangladesh in the Asia Cup. (AP Photo/Aijaz Rahi)

ALTERNATE CR0P OF DEL150 - Indian cricketer Sachin Tendulkar kisses his helmet after scoring his 100th century during the Asia Cup cricket match against Bangladesh in Dhaka, Bangladesh, Friday, March 16, 2012. Tendulkar, who had been stuck on 99 centuries for a year, became the first cricketer to score 100 international centuries on Friday when he hit to square leg and ran a single against Bangladesh in the Asia Cup. (AP Photo/Aijaz Rahi)

Indian cricketer Sachin Tendulkar celebrates scoring his 100th century during the Asia Cup cricket match against Bangladesh in Dhaka, Bangladesh, Friday, March 16, 2012. Tendulkar, who had been stuck on 99 centuries for a year, became the first cricketer to score 100 international centuries on Friday when he hit to square leg and ran a single against Bangladesh in the Asia Cup. (AP Photo/Aijaz Rahi)

Indian cricketer Sachin Tendulkar looks at his bat after scoring his 100th century during the Asia Cup cricket match against Bangladesh in Dhaka, Bangladesh, Friday, March 16, 2012. Tendulkar, who had been stuck on 99 centuries for a year, became the first cricketer to score 100 international centuries on Friday when he hit to square leg and ran a single against Bangladesh in the Asia Cup. (AP Photo/Pavel Rahman)

Indian cricketer Suresh Raina, right, and Sachin Tendulkar run between the wickets during the Asia Cup cricket match against Bangladesh in Dhaka, Bangladesh, Friday, March 16, 2012. Tendulkar, who had been stuck on 99 centuries for a year, became the first cricketer to score 100 international centuries on Friday when he hit to square leg and ran a single against Bangladesh in the Asia Cup. (AP Photo/Pavel Rahman)

Indian cricketer Sachin Tendulkar bats on his way to scoring a century during the Asia Cup cricket match against Bangladesh in Dhaka, Bangladesh, Friday, March 16, 2012. Tendulkar, who had been stuck on 99 centuries for a year, became the first cricketer to score 100 international centuries on Friday when he hit to square leg and ran a single against Bangladesh in the Asia Cup. (AP Photo/Aijaz Rahi)

(AP) ? Sachin Tendulkar achieved a milestone unlike any cricketer.

The historic journey to his 100th international century on Friday took longer than expected, being stranded from the unprecedented mark for just more than a year.

But the "Little Master" made the mark in the Asia Cup at Mirpur Sher-e-Bangla National Stadium for the highly anticipated cricket achievement.

"When I got the 99th century, no one spoke about it," he said. "I guess it was the media which started it. Everywhere I went people were talking about my 100th hundred."

Tendulkar got to his 49th one-day international century and first against Bangladesh with a clipped single to square leg off spinner Shakib Al Hassan. He did not celebrate much despite the mounting pressure of expectations from millions of his Indian compatriots.

"I can't think of anything at this stage, it has been a tough phase for me," Tendulkar told Neo Cricket channel after his innings. "I started off the season well, but was luckless. It does not matter how many hundreds you score, you still have to grind it out."

The best batsman of the modern era scored his last century (111) against South Africa at Nagpur during the World Cup on March 12 last year.

The World Cup final at Mumbai and tours of England and Australia all provided him opportunities of getting to the mark at some of the most celebrated venues but Tendulkar came up short each time.

He was twice out in the 90s in tests last year ? for 91 versus England at The Oval and 94 against West Indies at Wankhede Stadium ? while also being dismissed for 85 against Pakistan during the World Cup semifinals at Mohali.

He was finally out for 114, caught behind off Mashrafe bin Mortaza, who then ran over to shake his hand.

Tendulkar has set a benchmark unlikely to be surpassed in his lifetime, with his closest rival, Ricky Ponting, on 68 international centuries and approaching the twilight of his career at the age of 37.

Since his international debut at 16 against archrival Pakistan in 1989, Tendulkar has been compared to not only top batsmen of his era like Brian Lara and Inzamam-ul-Haq, but also to Australian great Donald Bradman as the best batsman ever.

Bradman, who retired in 1948 with an average of 99.94 runs, said Tendulkar reminded him of his own playing style.

"Not even Don Bradman carried expectations like this, and Sachin had been bearing it since 1989," former India coach and Australia captain Greg Chappell wrote in his recent autobiography.

Tendulkar already holds most of the major batting records, including most runs and centuries in both five-day tests and one-day internationals.

He has taken on the best bowlers over the past 23 years including Imran Khan, Wasim Akram and Waqar Younis during his first tour of Pakistan in 1989, and the likes of Allan Donald, Glenn McGrath, Shane Warne, Courtney Walsh and Dale Steyn over the rest of his career.

The 38-year-old limited his participation in one-dayers since 2010 when he became the first to score a double-century in the 50-over format with 200 not out against South Africa at the Indian venue of Gwalior.

But he remains as energetic as anyone in the field as well as while running between the wickets, and each speculation of an impending retirement is knocked off with a new achievement.

Tendulkar's ability to accumulate runs has not diminished and he has adjusted well to changing times by not only perfecting new strokes like the "upper cut" and "paddle sweep" but also excelling in the slam-bang Indian Premier League.

Asked by commentator Ramiz Raja what message he had for youngsters, Tendulkar advised them to follow their dreams. Like he did when he "had to wait for 22 years to win the World Cup."

Associated Press

Source: http://hosted2.ap.org/APDEFAULT/3d281c11a96b4ad082fe88aa0db04305/Article_2012-03-16-CRI-Tendulkar-100-Centuries/id-d36bef176b4041d397e4e4515d176968

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Video: Cramer: Watch General Electric

CNBC's Jim Cramer says with the shift from coal to natural gas, General Electric is a good company to watch.

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Source: http://video.msnbc.msn.com/cnbc/46759067/

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How to Relieve Your Headache Naturally without Using Prescriptions

With such an extreme pain on your head, it is hard to concentrate on work and school and move on with our daily activities. Many of us would get hand on over-the-counter prescriptions for temporary relief. But don?t you know that OTC drugs for headaches only treat the symptoms, not the causes of pain?

Is there a way to treat headache without using prescription drugs? Yes, there is, and there are lots of ways to relieve all types of headaches without resorting to medicines. These tips to a headache-free life are very simple activities. It involves certain lifestyle changes, so no pain in there.

? Cut down on alcohol ? Don?t you know why you get hangover headache from getting drunk? Alcohol products act as a diuretic which draws fluids out of the body through urination.

With all the fluids out of you body, you get dehydrated. And with dehydration comes headache.

? Drink lots of water ? Water is way better than alcohol, caffeine and wine to hydrate your body.

? Limit red wine, coffee and chocolate ? The amines in red wine can trigger an increase in blood pressure. Caffeine, like alcohol, is a diuretic that can contribute to headache and dehydration. Chocolate, because it has caffeine, cannot even help relieve the pain.

? Eat a well-balanced nutritious diet ? And don?t forget to eat regularly too. Cut down on processed and fried foods, but don?t forget healthy amounts of protein in your breakfast, as the lack of it can cause you headaches later in the day. Also include foods rich in omega 3 fatty acids in your meals.

? Get enough sleep ? The lack of enough sleep is a recipe for pain. The tiredness that results from it can lead you to consume coffee thus worsening your headache.

? Get enough fresh air ? Don?t you know that some people feel pain on their head when they smell strong perfume or any strong smelling chemicals? If you have that enough, you should go out and breathe fresh air. Breathing is a therapy too, don?t you know? SO go out, breathe and relax.

? Exercise and stretch regularly ? Regular exercise and stretching can help loosen up stiff and tight muscles, increase blood flow and distribute oxygen evenly all over your body.

? Take a hot shower at times ? The warmth and steam of a hot shower can relax tight muscles on your head, thus easing your headache.

? Relax your mind ? Keep away from negative thoughts and emotions. They don?t help.

? Go for a massage ? A good massage promotes better blood flow and oxygen circulation, muscle relaxation and freedom from stress. Massage the head can help relax the tight muscles in there.

? Try alternative techniques ? Practicing yoga, acupuncture and various and relaxation techniques can help you drain the tension from your body and deal with all types of headaches.

? De-stress ? Certain everyday stress and pressure can put you down and place you out of life?s focus. You should learn how to manage your stress and get away from things or events that can stress you out. Learn to say ?no? if you think you can?t make it. Manage your time. Delegate certain tasks and responsibilities to other people. Escape the pressure by going on a vacation.?

? Listen to therapy music ? Music can calm your nerves and help you relax. Every individual has their choice of music, so this would depend on your preference.

If you want help on managing your headache and other body pains, you should visit a physiotherapist at a nearby physiotherapy Sydney clinic. Your physiotherapist can provide you tools to relieve your pain and help you make lifestyle choices for a pain-free life.

?

Source: http://health.ezinemark.com/how-to-relieve-your-headache-naturally-without-using-prescriptions-7d34c44bb0a8.html

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