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In Santiago-Sepúlveda v. Esso Standard Oil Co. (Puerto Rico), Inc., (CCH Business Franchise Guide ¶14,604) the U.S. Court of Appeals in Boston held that a gasoline station franchisor did not violate the PMPA in connection with its withdrawal from the Puerto Rico market because its successor did comply with the PMPA’s requirement, for the most part, to offer franchises to the franchisees of the withdrawing franchisor in "good faith."
The argument by the franchisees that any term violating a state law in any respect comprised a violation of the PMPA’s good faith requirement was rejected. Such a per se rule would put at risk a vast number of market withdrawals. The court noted that the offered franchise agreements, comprising interrelated contracts spanning about 100 pages, included hundreds of clauses, of which the lower court invalidated only five in part.
In Ralph Gentile, Inc. v. Division of Hearings and Appeals, (CCH Business Franchise Guide ¶14,626), a Wisconsin state appellate court held that a motor vehicle dealer materially breached its dealership agreement with a franchisor by failing to achieve satisfactory sales performance.
(4) The dealer failed to cure the breach within a reasonable time after receiving written notice of the breach.
The sales-effectiveness rating used by the franchisor for determining the performance of the dealer was ruled proper, and the facts clearly showed that the dealer’s sales performance was well below the sales-effectiveness ratings earned by its predecessor.
In Love of Food I, LLC v. Maoz Vegetarian USA, Inc., (D. Md., CCH Business Franchise Guide ¶14,633) allegations of common law fraud based on the franchisor’s understatements of start-up costs in a UFOC survived a motion to dismiss. The initial costs were allegedly understated by 85% or more. The franchisor argued that cost projections were statements of opinion and could not constitute fraud because they were not susceptible to exact knowledge at the time they were made. However, the court held that erroneous projections could supply a basis for fraud under Maryland law.
Practitioners should be aware that an alert was issued by the Philadelphia Department of Revenue to notify taxpayers that the department's audit unit is currently working to find businesses having tax nexus with Philadelphia but located outside of the city. Nexus questionnaires are being sent out explaining business nexus and asking those businesses to report any activity they have in Philadelphia.
If a taxpayer's business has nexus with Philadelphia and is not filing and paying Philadelphia business taxes, taxpayers are advised to contact the department to bring the company into tax compliance by entering into the Voluntary Disclosure Program. Taxpayers who meet the conditions of the program may be eligible for a waiver of all penalties owed (Amnesty Support Group and Nexus Project, Philadelphia Department of Revenue, May 13, 2011).
The Federal Trade Commission announced yesterday that Reebok International Ltd. agreed to resolve charges that the company deceptively advertised its “toning shoes,” including EasyTone walking shoes, RunTone running shoes, and EasyTone flip flops.
According to the FTC, ads for the shoes claimed that sole technology featuring pockets of moving air created “micro instability” that toned and strengthened muscles as you walked or ran.
In one television commercial, Reebok represented that the EasyTone toning shoes were proven to strengthen hamstrings and calves by up to 11 percent, and that they toned the buttocks “up to 28 percent more than regular sneakers, just by walking,” the FTC alleged.
As part of a settlement, Reebok has agreed to pay a $25 million judgment to be used for consumer redress distributed either through the FTC or through a class action lawsuit. Reebok also will be required to change its marketing for the relevant products, as it continues to sell the footwear.
Reebok has agreed to refrain from making the challenged claims. A proposed consent decree would prohibit the company from representing that toning shoes and other toning apparel are effective in strengthening muscles, or that using the footwear will result in a specific percentage or amount of muscle strengthening or toning, unless the claims are true and backed by scientific evidence.
Future health or fitness-related efficacy claims for toning shoes and other toning apparel would have to be true and backed by scientific evidence. The proposed consent decree also would require Reebok to refrain from misrepresenting any tests, studies, or research results regarding toning shoes and other toning apparel.
Reebok has agreed to notify retailers and instruct them to remove marketing materials and cover portions of boxes making the challenged claims.
Although Reebok agreed to settle the FTC’s allegations, it issued a statement defending its advertising practices.
The FTC filed the complaint and proposed consent decree on September 28 in the U.S. District Court for the Northern District of Ohio. A news release, complaint, and stipulated final judgment and order appear here on the FTC website.
Further details regarding Federal Trade Commission v. Reebok International Ltd., will appear in the CCH Trade Regulation Reporter.
Investors could proceed with civil RICO claims against defendants that allegedly engaged in a fraudulent investment scheme that involved the leasing of thoroughbred mares for a single breeding season, the federal district court in Lexington, Kentucky, has ruled.
The defendants unsuccessfully argued that the plaintiffs were required to allege that each defendant had personally made misrepresentations or had used the mails or wires in order state a claim. They were unsuccessful, as well, in their argument that the plaintiffs did not allege a valid “investment” claim under RICO §1962(a).
Although the U.S. Court of Appeals for the Sixth Circuit required plaintiffs to identify with specificity the actions that each defendant had taken in furtherance of an alleged fraud, the mail and wire fraud statutes did not require a showing that each defendant had personally made a misrepresentation, the court explained.
The defendants unsuccessfully argued that the plaintiffs failed to plead a valid “investment” claim under RICO §1962(a).
According to the defendants, the plaintiffs failed to allege that specified defendants had used or invested income from a pattern of racketeering activity to acquire an interest in, or to operate an enterprise engaged in, interstate commerce.
The plaintiffs, however, “clearly alleged” that the specified defendants had invested income from their racketeering activity (the proceeds they received from the mare leases) into a business that was used to facilitate the cover up of the alleged fraud, according to the court.
The decision in ClassicStar Mare Lease Litigation will appear at CCH RICO Business Disputes Guide ¶12,106.
Further information regarding CCH RICO Business Disputes Guide is available here.
Lawmakers expressed concern about Google’s decision to expand into secondary Internet businesses and addressed charges that the Google search engine channels customers to its own businesses, during a September 21 hearing by the Senate Judiciary’s Subcommittee on Antitrust, Competition Policy and Consumer Rights.
The hearing was held to consider the competitive impact of the conduct of Google, which has been criticized for allegedly manipulating search results for its own benefit. The Federal Trade Commission is currently investigating Google’s business practices.
“[A]s the dominant firm in Internet search, Google has special obligations under antitrust law to not deploy its market power to squelch competition,” Senator Kohl added.
Eric Schmidt, Executive Chairman of Google Inc., defended the company from suggestions that it was hindering competition. Schmidt said that Google was “fully cooperating with the FTC’s investigation” and noted that “every decided antitrust suit that has been brought against Google regarding our search results has been dismissed.
In a statement issued following the hearing, Senator Mike Lee (R, Utah) said that he was “disappointed” by Schmidt’s testimony.
The Massachusetts Supreme Judicial Court has answered four questions that were certified to it by a federal district court for the District of Massachusetts in a dispute between Coverall, a franchisor of janitorial service businesses, and individuals who entered into janitorial franchise agreements with Coverall.
The federal court had determined in earlier rulings that those individuals who were Massachusetts residents were employees who had been improperly classified as independent contractors by the franchisor. The certified questions related to the calculation of damages for one of the individual plaintiffs in the action.
(2) Whether an employer could lawfully withhold wages to an employee if the employer and employee agree that such wages are not earned until a customer remits payment.
The answer to both questions was "no," according to the Massachusetts high court.
(4) Provide replacement supplies and equipment.
The contract further provided for accounts receivable financing whereby Coverall would pay the individual interest-free advances for amounts billed to, but not yet collected from customers. If a customer failed to pay within 90 days, the individual was required to repay Coverall the advance in the form of a chargeback.
The Massachusetts Wage Act required an employer to pay the wages earned to an employee within a fixed period of days after the end of a pay period, according to the court. Where an employee has completed the labor, service, or performance required of him, by common understanding he has "earned" his wage.
That a Coverall customer did not pay its bill within a week after the pay period did not affect the plaintiff individual’s right to wages he had earned. Since the individual was an employee, the obligation to pay him earned wages rested with Coverall, not with third parties, the court held.
The accounts receivable financing system incorporated into the individual’s contract with Coverall, in which wages were classified by Coverall as advances that could be recouped, violated the special contracts provision of the Wage Act, the court ruled. That provision prohibited a person from exempting himself from the Wage Act’s provisions by a special contract or other means. Coverall was not free to withhold, much less recapture, the employee’s earned wages.
In answering the remaining questions, the Massachusetts court determined that the employees could recover as damages incurred any insurance premiums that they were obliged to pay to Coverall under the terms of their contract. In light of the federal district court judge’s statement that he welcomed other advice about Massachusetts law that was relevant to the case, the court addressed the franchise fees that the individual agreed to pay Coverall in order to enter into what the district court determined to be a direct employment relationship. The Massachusetts court’s view was that such fees constituted "special contracts," not usual between employers and employees.
In substance they operated to require employees to buy their jobs from employers. In that respect, they violated public policy. Examined in the context of the Wage Act, the franchise fees paid by the plaintiff individual did not represent a clear and established debt. To the extent that such fees were paid back to Coverall out of wages earned from Coverall, they represented a prohibited assignment of an employee’s future wages to his employer, the court opined.
The court emphasized that its concerns over franchise fees related to the potentially exploitative nature of payments by an employee to an employer for the purpose of securing employment and noted that it expressly did not conclude that franchise fees violated public policy when they were agreed to by parties who were not in an employer-employee relationship.
The opinion is Awuah v. Coverall N.A., Inc., CCH Business Franchise Guide ¶14,671.
The federal district court in Santa Ana, California, has refused to decertify a class of YoPlus yogurt purchasers who asserted that General Mills and Yoplait USA falsely represented that YoPlus yogurt products promoted digestive health, in violation of California’s Unfair Competition Law (UCL) and Consumers Legal Remedies Act (CLRA). The court ealier held that class certification was warranted under both the U.S. Supreme Court’s decision in Wal-Mart v. Dukes, 131 S.Ct. 2541 (2011) and the Ninth Circuit’s recent decision in Stearns v. Ticketmaster, ADVERTISING LAW GUIDE ¶64,386, which directly addressed the issue of class certification of claims brought pursuant to the UCL and the CLRA.
The claims met the commonality and predominance requirements for class certification because they presented core issues of law and fact, and those issues predominated over the issues in the case that would have to be determined on an individual basis, according to the court. These common issues included (1) whether General Mills communicated a representation—through YoPlus packaging and other marketing, including television and print advertisements—that YoPlus promoted digestive health; (2) if so, whether that representation was material to individuals purchasing YoPlus; (3) if the representation was material, whether it was truthful; in other words, whether YoPlus does confer a digestive health benefit that ordinary yogurt does not; and (4) if reasonable California consumers who purchased YoPlus were deceived by a material misrepresentation as to YoPlus’ digestive health benefit, what is the proper method for calculating their damages.
Neither Wal-Mart nor Ticketmaster contradicted the findings of commonality and predominance in this case, the court determined. The claims centered upon a common question: did the defendants state a false claim of a digestive health benefit that a reasonable person would have been deceived by, for purposes of the UCL, or would have attached importance to, for purposes of the CLRA? While individualized determinations may be required to calculate damages, those determinations did not warrant decertification. The common question was sufficiently central to satisfy commonality, and, when compared to individualized aspects of the suit, still predominated.
The April 20, 2011, and the September 12, 2011, decisions in Johnson v. General Mills, Inc., SACV 10-00061, will appear at ADVERTISING LAW GUIDE ¶64,412 and ¶64,413.
A janitorial business franchisor did not commit common law fraud or violate the anti-fraud provisions of the Minnesota Franchise Act (MFA) in connection with the sale of a franchise to three franchisees because the franchisor made no untrue statements of material fact or misrepresentations, a federal district court in Minneapolis has decided.
The claims were initially brought as part of a putative class action against the franchisor, but the motion for class certification was denied in an earlier ruling (CCH Business Franchise Guide ¶14,335). After proceeding jointly through discovery, the parties agreed that the franchisor would move for summary judgment on the claims of three representative plaintiffs.
As to the first of the three plaintiffs, the franchisor’s alleged statement to that "[i]f you buy more, you’ll get more" was not untrue, the court held. The franchisor structured its franchising business to correlate the amount of business it promised to offer a franchisee with the amount of initial investment made by the franchisee. In that sense, it was true that the more a franchisee bought (or the larger his initial investment), the more he would receive in gross billings of offered accounts, the court determined.
The statement that owning one of the franchises was a "good business" and that the business could continue for "a long time" were puffery, the court ruled. In general, puffery includes statements of exaggerated boasting or vague, subjective claims of superiority. The franchisee’s counsel contended that the franchisor’s puffery should be evaluated in the context of the lack of sophistication of the franchisee—an immigrant with limited English ability and business acumen. However, immigrants were not a group so gullible that they could not recognize obvious puffery, the court reasoned.
The first plaintiff also asserted that the franchisor falsely represented a guarantee of $1,000 per month in account billings, but the franchisee admitted in his deposition that he was not promised any level of profits or income. Even if such a representation was made by the franchisor, any reliance on representations regarding profitability was unreasonable as a matter of law because it was directly contradicted by the franchise agreement, the court held.
The fraud claimed by the second of the three plaintiffs hinged on the franchisor’s alleged representations that he could earn as much money as a medical doctor or Ph.D., and its failure to inform him that declined accounts would be counted against the amount of business the franchisor was obligated to provide.
The franchisee could not have reasonably relied on the alleged statement because it was made after he signed the franchise agreement, the court held. Further, the statement directly contradicted the franchisor’s Uniform Franchise Offering Circular (UFOC), which disclaimed any representations as to profitability or income level and was incorporated into the franchise agreement. The franchisee could not impose liability under a common law or MFA-based fraud claim merely because he chose not to read the UFOC, according to the court.
The franchisor could not have defrauded the third plaintiff by allegedly failing to disclose that any offers of accounts that the franchisee declined would count against the total amount of accounts that the franchisor was obligated to offer the franchisee, the court ruled. A reasonable jury would find that the franchisee received a version of the franchisor’s UFOC that unambiguously made such a disclosure, the court decided.
Evidence showed that: (1) the franchisee admitted, while a prospective franchisee, to receiving a "black book" from the franchisor; (2) the franchisor’s May 28, 2002 UFOC was bound as a black book; (3) the franchisee signed a written acknowledgment of having received the May 28, 2002, UFOC; and (4) most importantly, the franchisee produced the first two pages of the May 28, 2002 UFOC in the course of the litigation.
The third franchisee’s claim that the franchisor violated the MFA by making misrepresentations regarding profitability, the availability of evening accounts, and the ability to hire employees was time-barred by the Act’s three-year statute of limitations.
Had the franchisor made the alleged statements, and if they were false, the franchisee would have been aware of the facts constituting the claim within months of purchasing his franchise, the court decided. Thus, even if the discovery rule applied to the MFA to toll the statute of limitations, the claim was barred. The franchisee knew all of the facts constituting the claim in early 2003 but did not file the claim until approximately five years later.
The decisions in Moua v. Jani-King of Minnesota, Inc., will appear at CCH Business Franchise Guide ¶14,665 and ¶14,681.
A New York Internet subscriber could not state a New York deceptive business practices law claim against Time Warner Cable for allegedly misrepresenting the speed of its “Road Runner” Internet service, according to the federal district court in New York City.
A California Internet subscriber also failed to state a California Unfair Competition Law (UCL) claim based on violations of the California False Advertising Law (FAL) and Consumer Legal Remedies Act (CLRA).
Time Warner advertised its Road Runner Internet service as having “blazing speed,” being “always on connection,” and the “fastest, easiest way to get online.” These representations allowed Time Warner to charge up to more than 100% of the fees charged by competitors, according to the subscriber.
However, Time Warner failed to disclose that it interfered with and limited subscribers’ access to their Internet connections and their attempts to engage in peer-to-peer communications.
New York and California subscribers sought to represent a class of all Road Runner service customers.
In response, Time Warner argued that the service agreement included express provisions permitting the network management practices at issue. The company further argued that the statements at issue were mere puffery and not actionable under either the New York or California laws.
To state a claim under the New York law (New York General Business Law Sec. 349), the subscriber had to show that the challenged advertising was directed at consumers, the advertising would mislead a reasonable consumer in a material way, and that the subscriber suffered an injury as a result of the advertising. To state a UCL claim under the unlawful prong, the subscriber needed to show that the company violated another law.
While some of the statements were puffery, others could be actionable. However, the claims failed because there was no evidence that the Internet connection was not always available or that the speed of the service was slower than competing services, according to the court.
The decision in Fink v. Time Warner Cable will appear at CCH State Unfair Trade Practices Law ¶32,322.
The First Amendment barred former Rutgers quarterback Ryan Hart’s New Jersey common law right of publicity claim based on misappropriation of his likeness in the Electronic Arts video game NCAA Football, the federal district court in Trenton has ruled.
Hart asserted the right of publicity in a class action complaint on behalf of other players. The court held that the First Amendment trumped the right of publicity because EA’s use of Hart’s likeness was “transformative” and also because the use was clearly related to the game and not simply an advertisement for an unrelated product.
Borrowed from the copyright fair use doctrine, the transformative test balances the competing interests of the right of publicity and the First Amendment by protecting works that add significant elements of expression beyond the mere literal depiction or imitation of a celebrity for commercial gain.
Elements of EA’s own expression found in the game justified the conclusion that its use of Hart’s image was transformative, the court held. NCAA Football contained virtual stadiums, athletes, coaches, fans, sound effects, music, and commentary, all of which were created or compiled by the game's designers. Over 100 virtual teams and thousands of virtual players were included.
Focusing on Hart’s virtual image alone, the court acknowledged that a virtual player bore resemblance to Hart and was designed with Hart’s physical attributes, sports statistics, and biographical information in mind. However, the game permitted users to alter Hart’s virtual player, control the player’s throw distance and accuracy, change the team of which the player is a part by downloading varying team names and rosters, and incorporate players from historical teams into the gameplay.
EA created the mechanism by which the virtual player could be altered, as well as the multiple permutations available for each virtual player image, the court noted.
Because EA’s use of Hart’s likeness was clearly related to the game and not simply an advertisement for an unrelated product, the court determined that the right of publicity claim also was barred under the test developed in Rogers v. Grimaldi, 875 F.2d 994 (2d Cir. 1989). The Rogers test had been applied in cases when the appropriation of a celebrity likeness created a false and misleading impression that the celebrity was endorsing a product.
As explained in Seale v. Gramercy Pictures, 949 F.Supp. 331 (ED Pa. 1996), applying Rogers to a Pennsylvania right of publicity claim, if a name or likeness is used solely to attract attention to a work that is not related to the identified person, the user may be subject to liability for a use of the identity in advertising. On the other hand, the use of a person’s name and likeness to advertise a work concerning that individual does not infringe the right of publicity, according to the court.
The transformative test provided the best analysis, in the court’s view, but EA was entitled to protection under either the transformative test or the Rogers test, the court concluded.
The September 9 opinion in Hart v. Electronic Arts, Inc. will be reported at CCH Advertising Law Guide ¶64,395.
The federal district court in San Francisco has given preliminary approval to a $10 million settlement resolving price fixing claims brought on behalf of indirect purchasers of products contain cathode ray tubes (CRTs) against manufacturer Chunghwa Picture Tubes, Ltd.
A special master will hold a hearing to determine the sufficiency, fairness, reasonableness, and adequacy of the proposed settlement in March 2012.
The indirect purchaser claims were brought on behalf of all persons or entities who or which indirectly purchased in the United States CRT products manufacture red or sold by defending CRT makers or their subsidiaries between March 1995 and November 2007. The net settlement fund will be no less than $5 million. The settlement calls for $2.5 million in attorneys’ fees and sets aside $2.5 million for costs, including costs of notice and administration of the settlement funds.
Last year, the court refused to dismiss the indirect purchasers’ claims based on an alleged failure to adequately plead a conspiracy, the Foreign Trade Antitrust Improvements Act (FTAIA), or an alleged lack of standing.
The complaint met the pleading standards articulated by the U.S. Supreme Court in Bell Atlantic Corp. v. Twombly (550 U.S. 544, 2007-1 Trade Cases ¶75,709) and Ashcroft v. Iqbal (129 S. Ct. 1937, 2009-2 Trade Cases ¶76,785).
The plaintiffs were not required to plead detailed, defendant-by-defendant allegations. It was sufficient that they made allegations that plausibly suggested that each defendant participated in the alleged conspiracy. The complaints contained allegations concerning certain defendants’ participation in alleged unlawful meetings and agreements.
Regarding the FTAIA argument, the indirect purchasers alleged a conspiracy that was carried out both in the United States and abroad, that involved a substantial amount of import and domestic commerce, and that targeted and injured American consumers.
The court also ruled that the indirect purchasers adequately alleged standing to assert state antitrust violations predicated on the Illinois Brick repealer statutes of Arizona, California, Iowa, Kansas, Michigan, Minnesota, Mississippi, Nebraska, Nevada, New Mexico, North Carolina, North Dakota, South Dakota, Tennessee, Vermont, West Virginia, and Wisconsin.
The indirect purchasers alleged that they paid higher prices for CRT products than they would have paid in the absence of the conspiracy and that prices of CRT products were directly correlated to the prices of CRTs.
CRTs purportedly account for approximately 60 percent of the cost of manufacturing computer monitors and a slightly smaller percentage of the cost of manufacturing televisions.
The decisions are Cathode Ray Tube (CRT) Antitrust Litigation, 2011-2 Trade Cases ¶77,592 and 2011-2 Trade Cases ¶77,593.
Bridgestone Corporation has agreed to plead guilty and to pay a $28 million criminal fine for its role in conspiracies to rig bids and to make corrupt payments to foreign government officials in Latin America related to the sale of marine hose and other industrial products, the Department of Justice announced yesterday.
The company has agreed to cooperate with the Justice Department in its ongoing investigations and has committed to extensive remediation and to enhance its compliance program and internal controls.
According to a two-count criminal information filed on September 15 in the federal district court in Houston, the Japan-based Bridgestone conspired to rig bids, fix prices, and allocate market shares of marine hose in the United States and elsewhere in violation of Sec. 1 of the Sherman Act and, separately, conspired to make corrupt payments to government officials in various Latin American countries to obtain and retain business in violation of the Foreign Corrupt Practices Act (FCPA). The challenged conduct took place between 1999 and 2007.
As part of the antitrust conspiracy, Bridgestone and others allegedly agreed to allocate shares of the marine hose market, agreed to establish a price list for marine hose in order to implement and monitor the conspiracy, and agreed not to compete for one another’s customers through bid rigging.
With respect to the FCPA count, Bridgestone was charged with authorizing and approving corrupt payments to foreign government officials employed at state-owned entities in order to secure sales of marine hose in Mexico and other Latin America countries. The 11-page criminal information details e-mail exchanges purportedly detailing the company’s efforts to influence foreign officials through local sales agents.
Bridgestone, best known for its tires, is the fifth company to be charged in the Department of Justice Antitrust Division’s investigation into bid rigging in the marine products industry.
Last year, Parker ITR S.R.L. of Italy agreed to plead guilty and to pay a $2.29 million criminal fine for its role in the conspiracy. Two subsidiaries of the Swedish company Trelleborg AB, one based in Virginia and the other in France, agreed to plead guilty and pay a total of $11 million in criminal fines in 2009. British marine hose manufacturer Dunlop Oil & Marine Ltd. agreed to plead guilty and pay $4.54 million fine in 2008. Manuli Rubber Industries SpA of Italy also agreed to plead guilty to similar charges and to pay more than $2 million in criminal fines.
In addition, a number of industry executives have been charged with participating in the marine hose conspiracy, including Bridgestone’s former general manager of international engineered products, Misao Hioki.
While most of the executives have pleaded guilty, two have been acquitted. In 2008, an Italian national and a Florida man who both worked for Manuli were found not guilty of participating in the antitrust conspiracy by a jury in West Palm Beach, Florida. A German national and former executive with Dunlop's former parent company—Phoenix AG—who was indicted in 2007 is awaiting trial.
Bridgestone issued in statement today, saying that the $28 million fine is a significant reduction from the applicable sentencing guidelines due to the company’s “extraordinary” cooperation in the investigation and remediation efforts. As part of the remediation efforts, Bridgestone has dismantled its International Engineered Products Department, closed its Houston office of Bridgestone Industrial Products of America, Inc., terminated many of its third party agents, and taken remedial actions with respect to its employees.
The Justice Department has been investigating Bridgestone’s involvement in international cartel activities relating to the sale of marine hose since May 2007, according to the statement.
The case is U.S. v. Bridgestone Corp., Criminal No. H-11-651.
A Department of Justice press release on the development appears here. Bridgestone’s statement appears here.
Labels: allocation of markets, bid rigging, conpiracy, horizontal price fixing, U.S. v. Bridgestone Corp.
The Federal Trade Commission has proposed amendments to the Children’s Online Privacy Protection Rule in order to ensure that the rule continues to protect children’s privacy, as online technologies evolve. The agency is seeking public comment on the proposal through November 28, 2011.
According to a September 15 press release, the proposed amendments would give parents control over what personal information websites may collect from children under 13 years of age.
The Children’s Online Privacy Protection Act (COPPA) (CCH Trade Regulation Reporter ¶27,590) requires operators of websites or online services directed to children under 13—or those having actual knowledge that they are collecting personal information from children under 13—to obtain verifiable consent from parents before collecting, using, or disclosing such information.
The FTC rule implementing COPPA—the Children’s Online Privacy Protection Rule (CCH Trade Regulation Reporter ¶38,059)—became effective in 2000.
In April 2010, the Commission sought public comment on the COPPA Rule, posing numerous questions for public consideration, holding a public roundtable, and reviewing 70 comments from industry representatives, advocacy groups, academics, technologists, and members of the public.
Definitions. The FTC proposes updating the definition of “personal information” that may not be collected from children under 13 without parental consent to include geolocation information and certain “persistent identifiers” such as tracking cookies used for behavioral advertising. The agency further proposed a change to the definition of “collection” to allow children to participate in interactive communities, without parental consent, as long as the operators take reasonable measures to delete children’s personal information before it is made public.
Parental consent mechanisms. New proposed methods of obtaining verifiable parental consent would include electronic scans of signed parental consent forms, video-conferencing, and use of government-issued identification checked against a database. These new methods would supplement the existing methods of obtaining parental consent, which include signed parental consent forms, parents’ use of a credit card in connection with a transaction, and parents' calls to a toll-free telephone number. The FTC proposes eliminating parental consent through “e-mail plus,” an e-mail to a parent coupled with another step such as sending an e-mail confirmation.
Confidentiality and security. Proposed rules would strengthen confidentiality and security by requiring that operators ensure that any third party to whom they disclose personal information has reasonable procedures to protect that information, retain the information for only as long as reasonably necessary, and properly delete that information.
Safe harbor. The FTC proposes to strengthen its oversight of self regulatory “safe harbor programs” by requiring groups to audit their members at least annually and to report the results of audits to the Commission.
The 122-page notice of proposed rule and request for comments appears here on the FTC website.
Interested persons may submit comments online here or may send a hard copy of comments to: Federal Trade Commission, Office of the Secretary, Room H-113 (Annex E), 600 Pennsylvania Avenue, N.W., Washington, D.C. 20580.
Write “COPPA Rule Review, 16 CFR Part 312, Project No. P-104503” on the submissions.
The federal district court in Washington, D.C. has approved a consent decree resolving Department of Justice Antitrust Division concerns over a joint venture between Comcast Corp. and General Electric Co.’s subsidiary NBC Universal Inc.
The joint venture combined Comcast—the nation’s largest cable operator and Internet service provider—and NBC Universal's cable networks, filmed entertainment, and television programming, including the NBC broadcast network. It is managed and 51 percent owned by Comcast, with GE holding 49 percent ownership.
The consent decree resolved allegations that the transaction, as originally proposed, would lessen competition substantially in the market for video programming distribution by allowing Comcast to disadvantage its traditional competitors—direct broadcast satellite and telephone companies that provide video services—as well as emerging online video distributors (OVDs).
The consent decree was found to be in the public interest. However, the court imposed additional steps to monitor implementation of the final judgment.
The parties were required to report to the court for two years regarding the consent decree’s non-appealable arbitration mechanism for OVDs seeking to obtain the joint venture’s video programming content. An annual hearing was also required.
The case is U.S. v. Comcast Corp. A memorandum order, finding the consent decree in the public interest, appears at 2011-2 Trade Cases ¶77,584. The final judgment appears at 2011-2 Trade Cases ¶77,585.
Sharis Arnold Pozen, Acting Assistant Attorney General in charge of the Department of Justice Antitrust Division, discussed civil antitrust enforcement efforts at the 38th annual Fordham Competition Law Institute’s international antitrust law and policy conference on September 7.
In what panel moderator A. Paul Victor called her “maiden speech” as newly appointed acting antitrust chief, Pozen talked about how civil non-merger enforcement was "alive and well" at the Antitrust Division.
Pozen had intended to focus her comments on non-merger enforcement, saying that she had said a lot about mergers recently. A week earlier, Pozen had delivered remarks at a press conference on the filing of the U.S. suit challenging AT&T Corporation’s proposed acquisition of T-Mobile USA Inc. Moreover, a trial had just begun in the Justice Department’s action to halt H&R Block Inc.’s proposed acquisition of 2SS Holdings, Inc., the maker of TaxACT do-it-yourself tax preparation software.
The official took issue with the suggestion that the Justice Department’s complaint in the AT&T/T-Mobile case did not reflect recent changes to the joint FTC/Justice Department Horizontal Merger Guidelines. Commentators have suggested that the Justice Department’s complaint in the case relies too heavily on market share analysis and structural presumptions.
In her remarks at Fordham, Pozen said that the complaint in the AT&T/T-Mobile case does in fact represent the approach taken in the Horizontal Merger Guidelines and current Antitrust Division practice. She reiterated that the combination is a four-to-three merger that takes out an innovator.
The Horizontal Merger Guidelines (CCH Trade Regulation Reporter ¶13,100), which were revised in August 2010, recognize the continuing need for market definition in merger analysis; however, the focus is on the competitive effects of a transaction. The analysis need not start with market definition, according to the revised guidelines.
There has also been speculation that Sprint Nextel’s private suit challenging the AT&T/T-Mobile transaction could represent an effort by Sprint to bolster a weak Justice Department case. Pozen refused to comment on the Sprint suit other than to say that Sprint’s case was also before Judge Ellen Huvelle. Pozen did not know whether the suits would be combined.
Further information about the Justice Department’s lawsuit to block the AT&T/T-Moble deal appears here in an August 31 posting on Trade Regulation Talk.
With respect to civil, non-merger enforcement, Pozen discussed a number of recently-filed cases in sectors that “affect consumers’ pocketbooks.” In the health care industry, she explained that the Antitrust Division filed its first lawsuit since 1999 challenging a monopolist with engaging in traditional anticompetitive unilateral conduct. United Regional Health Care System of Wichita Falls—the largest hospital in Wichita Falls—agreed to settle allegations that it unlawfully used contracts with commercial health insurers to maintain its monopoly for hospital services in violation of Section 2 of the Sherman Act.
Another action noted in the health care area was the Antitrust Division’s ongoing lawsuit against Blue Cross Blue Shield of Michigan, challenging the health insurer’s use of most favored nation (MFN) clauses in its provider agreements with various hospitals. The insurer has appealed a federal district court’s denial of its motion to dismiss (2011-2 Trade Cases ¶77,568), and the Justice Department has asked for dismissal of the appeal.
In another “key industry for consumers,” the Justice Department is pursuing claims against American Express, challenging payment card rules that allegedly restrict price competition at the point of sale. MasterCard and Visa have agreed to settle similar civil charges (2011-1 Trade Cases ¶77,529).
Pozen noted that the Antitrust Division is “vigilantly watching for signs of anticompetitive conduct across the economy.” She also pointed out that the Antitrust Division was willing to litigate to judgment if necessary. This point is reflected in the ongoing litigation against Blue Cross Blue Shield of Michigan and American Express.
The acting antitrust chief said that she worked closely with her predecessor, Christine Varney, setting antitrust priorities. Among these priorities is a commitment to international cooperation, which she intends to carry forward.
The recent Memorandum of Understanding between the Antitrust Division and FTC and China’s three antitrust agencies (CCH Trade Regulation Reporter ¶13,512) is a first step towards an enduring relationship, said Pozen. She noted that the federal antitrust agencies were pursuing a similar agreement with India, as that country develops its competition regime.
Pozen reminded practitioners that antitrust agencies around the globe are talking to each other. She noted that many parties recognize the benefits of international coordination in investigations and suggested that permitting the agencies to share information can be beneficial to all who are involved.
Labels: Fordham Competition Law Institute, Horizontal Merger Guidelines, mergers and acquisitions, Sharis Pozen, T-Mobile USA, U.S. v. AT and T Corp.
An individual could not go forward with purported class-action claims that an advertising network violated the Computer Fraud and Abuse Act (CFAA) by monitoring her web browsing habits, but she could pursue claims under New York’s deceptive business practices statute and New York common law, the federal district court in New York City has determined.
The network purchased advertisement display space from websites and displayed ads of interest to a computer user. The network’s clients were advertising companies and agencies.
The network allegedly used “browser cookies”—text files that gather information about a computer user’s Internet habits—to create “behavioral profiles.” The network also allegedly used “flash cookies” to “respawn” the browser cookies when they were deleted by users, without users’ consent.
The individual also accused the network of using “history sniffing” code that was invisible to computer users. This code contained a list of hyperlinks, examined the user’s computer’s browser information to determine whether the computer had previously visited those hyperlinks, and transmitted the results to the network’s servers for the purpose of selecting ads to display on the user’s computer.
The individual could not satisfy the $5,000 minimum damages threshold for civil actions under the CFAA, the court said. She failed to quantify any damage that the network caused to her computers, systems, or data that could require economic remedy. Although she alleged that the network impaired the functioning of her computer, diminishing its value, she did not make specific allegations as to the cost of repairing or investigating this alleged damage.
The collection of her personal information, and any associated invasion of her privacy, would not be compensable under the CFAA, which redressed only economic damages or loss. The collection of demographic information did not constitute damage to consumers or unjust enrichment to the collectors.
The individual’s inability to delete or control the network’s cookies might constitute a de minimis injury, but not an injury sufficient to meet the $5,000 CFAA threshold, according to the court. Even if losses could be aggregated for purposes of the CFAA before a class was certified, damages resulting from the placement of cookies on multiple computers of prospective class members could not be aggregated because these losses would not result from the “same act” by the network.
In addition, even if the individual represented a class of consumers, she would have to show that she had been personally injured.
The advertising network’s behavioral profiling conduct could constitute a deceptive business act or practice under New York law, in the court’s view. The network’s use of flash cookies and history sniffing code could constitute deceptive conduct that misled consumers into believing their digital information was private, when in reality it was being tracked by the network.
The individual and similarly-situated consumers allegedly were harmed in that they suffered the loss of privacy through the exposure of their personal and private information. The individual was not required to allege reliance to plead a claim under the New York statute.
Although collection of personal information did not cause an economic injury, such nonpecuniary harm to privacy had been recognized as an actionable injury for purposes of the New York statute, the court said. The network’s conduct also could constitute a trespass to chattels under New York common law.
The individual failed to allege facts demonstrating that any of the companies whose products were advertised by the network (the “advertisers”) had engaged in any deceptive conduct or trespass. Claims against the advertisers were dismissed with prejudice.
The decision is Bose v. Interclick, Inc., CCH Privacy Law in Marketing ¶60,665.
The Illinois Personal Information Protection Act has been amended to provide additional safeguards and penalties surrounding the protection of personal information, including prevention of and response to a security breach.
A new provision added to the Act requires the disposal of “materials containing personal information in a manner that renders the information unreadable, unusable and undecipherable.” The law containing the amendments (H. 3025, Public Act No. 483) was approved on August 22, 2011 and will be effective on January 1, 2012.
The amended Act provides additional details as to what security breach notifications must contain. Previously, the Act required entities to notify affected individuals that a breach had occurred, but it did not specify what the notification should include.
• A statement that the individual can obtain information from these sources about fraud alerts and security freezes.
The amended Act will apply security breach notification requirements to any data collector that maintains or stores computerized data. The current version of the Act does not apply to data collectors that merely stored data for others. Moreover, service providers will be required to cooperate with data owners or licensees in regard to the breach.
• Electronic media or other non-paper media containing personal information may be destroyed or erased so that personal information cannot practicably be read or reconstructed.
Any person, entity, or third-party is subject to a civil penalty of $100 (capped at $50,000) per individual whose personal information was not disposed of properly, and the attorney general may bring a civil suit to impose a penalty.
Text of Public Act No. 483 appears here. The current version of the Illinois Personal Information Protection Act is reported at CCH Privacy Law in Marketing ¶31,300.
A claim by table grape producers in California that the state's table grape commission violated federal antitrust law through a scheme involving the bad faith licensing and enforcement of alleged patent rights on grape varieties was properly dismissed for failure to identify a valid relevant product market, the U.S. Court of Appeals for the Federal Circuit in Washington, D.C. has ruled.
Dismissal of the producers’ Sherman Act, Sec. 2 claims (2009-1 Trade Cases ¶76,522) was affirmed.
The producers claimed that the relevant product market consisted of several distinct patented varieties of table grapes and that the existence of the plant patents limited the myriad other varieties of table grapes from being substitutes for the patented varieties in the worldwide markets.
The complaining producers could not rely on the naked assertion that non-infringing grape varieties were not an adequate substitute for a patented product, especially when it was undisputed that other vines possessed at least some of the relevant characteristics that defined that product, the court reasoned.
The grape producers needed—but failed—to make some allegation that, if proved, would define the market or submarket with reference to consumer demand for the product and consumer demand for its reasonable substitutes.
The aspects of an invention that may have led the Patent and Trademark Office to issue a patent were not per se coterminous with the features of the patented product that may lead consumers to select that product over other similar ones, the court concluded.
The decision is Delano Farms Co. v. The California Table Grape Commission, 2011-2 Trade Cases ¶77,578.
Under new legislation that will take effect next year, persons and entities doing business in California will be required to make additional disclosures in the event that the security of their computerized data systems are breached.
Existing law requires companies doing business in California to disclose data breaches involving the personal information of California residents.
The recent legislation (Senate Bill 24, Chapter 197) amended California Civil Code Sec. 1798.82, adding several specific requirements as to the form and substance of breach notifications. As amended, the statute requires breach notifications to be in plain language.
• The name and contact information of the notifying person or business.
• The types of personal information that were the subject of the breach.
• The date or estimated date of the breach.
• Whether notification was delayed as a result of a law enforcement investigation.
• A general description of the breach incident.
• The toll-free telephone numbers and addresses of the major credit reporting agencies, if the breach exposed California residents’ Social Security, driver's license, or identification card numbers.
• Information about what the notifying company has done to protect individuals whose information has been breached.
• Advice on steps that persons whose information has been breached may take to protect themselves.
In addition, if notification is made to more than 500 California residents as a result of a single breach of the security system, the notifying company must electronically submit a single sample copy of the notification, excluding any personally identifiable information, to the California Attorney General.
The legislation was signed by Governor Jerry Brown on August 31, 2011, and will take effect on January 1, 2012. Similar bills were vetoed by former Governor Arnold Schwarzenegger in 2009 and 2010.
The current version of the law appears at CCH Privacy Law in Marketing ¶30,500.
In the wake of the Department of Justice’s filing of an antitrust lawsuit to block AT&T Corp.’s proposed acquisition of T-Mobile USA Inc. on August 31, mobile wireless carrier Sprint Nextel brought its own antitrust action today, seeking to prohibit the acquisition as a violation of Section 7 of the Clayton Act.
Sprint filed the lawsuit against AT&T Corp., AT&T Mobility, T-Mobile USA Inc., and Deutsche Telekom (T-Mobile’s parent) in the federal district court in the District of Columbia as a related case to the Department of Justice’s lawsuit.
• Harm retail consumers and corporate customers by causing higher prices and less innovation.
• Entrench “duopoly control” by “Ma Bell” descendants AT&T and Verizon of the almost quarter of a trillion dollar wireless market.
• Injure Sprint and other independent wireless carriers.
According to Sprint, a combined AT&T and T-Mobile would control more than three-quarters of the wireless market and 90 percent of the profits. The combined companies would be able to use its control over backhaul, roaming, and spectrum and its increased market position to exclude competitors, raise their costs, restrict their access to handsets, damage their businesses, and ultimately less competition, Sprint charged.
According to last week’s Department of Justice complaint, the four nationwide providers of mobile wireless service—Verizon, AT&T, Sprint, and T-Mobile—account for more than 90 percent of the national market. T-Mobile, the smallest of the four, has historically challenged the top three competitors by providing value, innovation, and aggressive pricing.
The elimination of T-Mobile as an independent, low-priced alternative rival would therefore “remove a significant competitive force from the market” and “substantially reduce competition,” the Justice Department claimed.
On August 31, Sprint issued a statement supporting the Department of Justice lawsuit, but did not hint that it was considering filing an action of its own.
A news release on Sprint’s filing of today’s action appears here.
Further information about the Justice Department’s lawsuit appears here in an August 31 posting on Trade Regulation Talk.
Labels: mergers and acquisitions, mobile wireless service, Sprint Nextel v. AT and T Corp., T-Mobile USA Inc., U.S. v. AT and T Corp.
the U.S. Court of Appeals in San Francisco has ruled.
A complaining hospital contended that the regulations prevented it from providing the procedures, known as elective percutaneous coronary interventions (PCI), on a nonemergency basis.
Judgment in favor of the Washington State Department of Health on the hospital’s antitrust claim (2010-2 Trade Cases ¶77,294) was upheld.
The PCI regulations were a unilateral restraint of trade not subject to preemption, the court held. The regulations were complete upon enactment, and did not delegate any regulatory power to incumbent licensees.
The court rejected the hospital’s argument that the PCI regulations granted regulatory power to incumbent licensees by calculating the need for a new certificate based in part on the number of PCI procedures they perform, thereby allowing the incumbent licensees to manipulate the number of PCIs they perform so as to exclude competing hospitals from the elective PCI market.
conduct. Absent a hybrid restraint or other per se violation of the antitrust laws, there was no preemption.
The decision in Yakima Valley Memorial Hosp. v. Washington State Dept. of Health will appear in CCH Trade Regulation Reporter.
A permanent injunction and nearly $2 million monetary judgment entered against the marketers of two purported weight loss products—a "Chinese Diet Tea" and the "Bio-Slim Patch"—for engaging in deceptive advertising prohibited by the FTC Act were proper, the U.S. Court of Appeals in New York City has ruled.
The federal district court in Bridgeport, Connecticut, did not exceed its authority in awarding monetary relief, and it committed no error in calculating the award or ordering the marketers to disgorge the full proceeds from their sale of the products, the appellate court said. The judgment of the lower court (2009-2 Trade Cases ¶76,840) was affirmed.
The statute on which the district court’s jurisdiction was based—Sec. 13(b) of the FTC Act—empowered the court to award ancillary equitable remedies, including equitable monetary relief such as disgorgement of wrongfully obtained funds, in the appellate court’s view.
That the marketers’ funds were wrongfully obtained was not in question, as the marketers had conceded liability with respect to the marketing of both products. There was no evidence that any of the marketers’ gains were "just" gains because the products in no instance worked as advertised, the court noted.
By authorizing courts to issue injunctive relief, Sec. 13(b) invoked the equitable jurisdiction of the court. A money judgment was thus permitted as a form of ancillary relief because, once its equitable jurisdiction had been invoked, the court had "the power to decide all relevant matters in dispute and to award complete relief."
An argument that the express provision of FTC Act Sec. 19 for monetary damage limited Sec. 13(b) to its explicit terms was rejected. The statute made clear that nothing within Sec. 19 affected the authority of the FTC under any other provision of law, the court observed.
The marketers were not entitled to a reduction of the monetary award on account of bounced checks, credit card chargebacks, or other expenses. Their incomplete records did not allow them to calculate the losses from bounced checks and chargebacks that could be attributed to the two products at issue, only the losses across their entire line of products, which numbered more than 60.
The district court’s refusal to apply a loss estimate equal to the two products’ share of the marketers overall share was within its discretion, in the appellate court’s view.
The district court’s monetary award was not an impermissible legal—rather than equitable—award, the appellate court also held. The lower court’s failure to identify particular funds in the defendants’ hands that were specifically traceable to the fraudulently marketed products did not force the court "to conform its award to the ancient remedy of constructive trust" or limit its judgment to the profits generated by the two products at issue.
Where the basis of a claim was a violation of the FTC Act, the court had to determine only that the nature of the underlying remedies sought was historically equitable.
The substance of the monetary judgment comported with the equitable remedy of disgorgement, the appellate court concluded. Disgorgement did not require a district court to apply equitable tracing rules to identify specific funds subject to return.
The decision is Federal Trade Commission v. Bronson Partners, LLC, 2011-2 Trade Cases ¶77,574.

industry_corpus2: Law & Justice


text:
Treasured Dolls are moving to the United States of America.
The Irish company Treasured Dolls is delighted to announce the sale of the company to An American Doll Company based in Missiouri.
We would like to wish Melissa Stoltzfus of Treasured Dolls USA every success in the future with her new Treasured Dolls. We have no doubt that TD USA will take our beautiful dolls to greater heights and a fabulously wide audience.
Treasured Dolls is an online Boutique doll company, selling age appropriate beautiful 18”/46 cm premium quality vinyl dolls. At Treasured Dolls we strive to encourage girls to be the best they can be and to enjoy and celebrate childhood in a meaningful way. Our promise is to encourage girls to believe in their ability and unlimited potential. Our aim is to create dolls and inspire girls to know and believe in themselves.
CHARLOTTE : with shoulder length brown layered hair and gorgeous brown eyes, wearing her beautiful brown riding outfit. Charlotte loves horse riding, her dream is to work as a horse trainer. She spends her evenings at the stables cleaning out for her horse Fable. Together they love to spend time trotting through the fields and exploring. Fable loves when Emily plaits his mane and tail. Their friendship is so important to them both.
SOPHIE : her stunning long curly auburn hair and beautiful brown eyes give her a unique look. Wearing her pale pink ballet outfit, Sophie is always practicing for her recital with her ballet bar, being a ballerina is all Sophie thinks about. Her dream is to star in the Swan Lake and to dance for the Royal ballet academy.
EMILY : her beautiful short caramel curly locks and chocolate brown eyes really make her stand out from the crowd. Wearing her stunning cream pink roses dress with silver and pink rose bud shoes. Emily loves fashion and one day hopes to work as a fashion designer. Her love for fashion gives her a confidence when choosing her outfit. She doesn’t always get it right but knows that all you have to do is keep trying to succeed.
NIAMH : with long curly red hair and emerald green eyes, wearing her trendy hoodie and jeans. Niamh loves history after all she was named after Niamh from the old Irish fable Tír Na nÓg. A story that Niamh loves to share with her friends all about the land of eternal youth. Niamh is a great storyteller and one day hopes to write her own book. Knowledge is our greatest tool and Niamh wants to learn as much as she can.
TREASURED DOLLS : original range of dolls is for the girl who wants a LOOK LIKE ME, doll with a fabulous choice of skin tone, eye colour, hair colour, hair style, with over 15 dolls to choose from.
Our extensive range of doll and girl outfits, accessories, furniture and playsets will keep your girl and doll busy for hours of endless meaningful playtime. All Treasured Dolls outfits and accessories fit American Girl, Our Generation and other 18”/46cm dolls.
We hope that you love your Treasured Doll as much as we loved creating her. Please join our Treasured Doll club and become a premium VIP customer and be the first to receive all our special offers and new stock.
AND WE WILL BE DELIGHTED TO GET BACK TO YOU.
Treasured Dolls has a choice of 15 dolls with different eye, hair and skin tone.
Each doll is packed in Treasured Doll signature box with see through pocket.
The beautifully stylish Treasured Dolls® have been designed with love in Ireland to the highest quality.

industry_corpus2: Others


text:
Phew................I can finally say it was my last day at work for the year! Get in! Joe and I have both been working hard recently so we've taken a proper amount of time off over Christmas, and neither of us are back at work until the 3rd of January!
Joe is celebrating properly, out with work in Manchester. He is staying over and has said he will not be drinking very much - I quite simply do not believe him and am expecting to be proved right when he crawls home off the train tomorrow! I, on the other hand, will be feeling virtuous after my yummy bacon, chorizo and pepper salad (oh yes, bacon AND chorizo!) and stubby beer - what could be better?!


text:
First of all, I want to remind everyone that we have open knitting at the Bridgewater Library from 6:30 to 8:30 on Thursday night. Please come! We have a lot of fun, and I’ll have some books about making hats, scarves and cowls to inspire you.
Finished the heather-colored hat, but now I want it. I had a similar one in a darker berry color,but I can’t find it.
On Sunday afternoon, I finally finished the hat I started a couple of weeks ago to be my first charity hat of the winter season. It was an Alex’s Favorite Beanie with a fishermen’s net cable all around it, and I made some mistakes in the directions of the cables which required me to rip out about 8 rounds yesterday. I’m glad in a way, though, because I ended up finishing it in a new way, not the way I usually decrease stitches in a beanie, and I love the way it came out so much that I want to keep it. I had another hat like this in a color that perfectly matches my winter jacket, but I can’t find it, and this new hat harmonizes with that jacket pretty well.
Maybe I’ll make myself another one.
I have to say that we have plenty of hats coming in, and I’m so grateful to all you knitters and crocheters. I talked with someone from the Franklin Township Food Bank last week, and they’d love to have some hats from us. We have so many hats coming in now, that I will be able to take some over this week.
But what we don’t have a lot of are scarves and mittens. Some of you, though, are making scarves with thick yarns like Lion Brand Homespun and Lion Brand Hometown. And that got me to thinking. I have a LOT of Lion Brand Homespun in my stash, most of which I bought years ago to make prayer shawls, except I’m not making prayer shawls these days. So the yarn is not getting used, and yet it knits up fairly quickly because you use big needles with it. So I’m going to do a lot of Homespun scarves this winter, not only to use up some of this yarn, but also to increase the number of scarves we can give out.
This is the scarf after knitting 18 inches. Now I’m up to 24 inches. It’s boring to work on, but it’s going fast.
I started my first Homespun scarve last evening, watching American Pickers on the History Channel. In a couple of hours, I got 18 inches done on a scarf that is a mere 21 stitches wide (about 7 inches). It’s a sort of muddy gray color, which I think is fairly unisex, and I’m happy about the idea of making a bunch of these. I’m just doing garter stitch because it goes fast and that stitch won’t curl. I think I’m using a size 13 needle, but it’s circular and it’s not marked. Maybe it’s a size 15.
If you want to join the fun of making hats and scarves for those in need, you might want to make them with thick yarn (bulky, #5 yarn) on big needles and see how it goes. You can just do garter stitch like me and come up with something that anyone would be happy to wear to keep warm.
Posted in Uncategorized on October 31, 2017 by Pam MacKenzie.


text:
Elioe E Burgos is similar to the following 4 Doctors near Port Orange, FL.
Have you had a recent visit with Elioe E Burgos? Select a star to let us know how it was.

industry_corpus2: Health & Medicine


text:
How do I use your system? How to I create fangate?
Are all of your features available for free?
Yes, absolutely. There are no PRO plans and no extra costs, just use our system and create as many fangates as you want.
How can I make money from my tracks?
There is a section called "My rewards" in the top right corner. Go there and see how many downloads must any of your track achieve to receive the reward.
I just received a reward. Why do I must send you my email adress?
We need to know where can we send you the reward, you've recieved. In case of Paypal transfer, we will ask you for your Paypal email.
Why is the number of downloads in the rewards section lower than the real number, that my tracks have from the very beginning.
That is because, we reset all statistics and numbers for the rewards section during the launch of the rewards system. All numbers are starting from scratch.
What "EXCLUSIVE release" in the Promotion section means?
We will release your track on a channel of your choice and keep promoting it for a month. The better song you deliver, the better result will be possible!
What does "Subscribe this channel" feature mean?
In case you want to stay in touch with a producer / artist that you like, you can subscribe the channel, thanks to which, you will be receiving email notification each time there will be a new fangate created under this channel.
Why is there a limit in SC Scheduler for number of reposts per hour?

industry_corpus2: Film & Entertainment


text:
September 31, I'll be six months post-chemo. My hair is almost three inches long. The color is gray, but it's a pretty, silvery gray. I'm not used to it yet - I still don't know who that woman is when catching a glimpse of myself in a store window. I'm not certain I'll keep it this color or not, but for now the color wasn't my main concern.
Unfortunately, I have hit the point where the famous and dreaded chemo curl reared its ugly head, pun intended. The curl first started around the bottom, and then like a fungus, began creeping up. It got to the point where it was very wavy on the top and super curly below the ears. Had I kept my original red dye-job, I would have been mistaken for Bozo the Clown's sister. As it was, I was on my way to looking like a sheep. Or, Betty White.
Each morning I woke up to a head full of dandelion frizz, so I'd mist it and use spiking glue to try and tame it.
I'm a woman. It doesn't matter what I've been through. It doesn't matter that estrogen is not allowed in my body anymore. I'm a female, and that means I'm genetically incapable of liking my hair. The fact that I had spent six months this year bald means nothing in the face of that truth.
Photos of women with short, cute, spiky straight pixie cuts kept finding their ways into my magazines, and into my consciousness.
So, I decided to relax it. I know that my African American sisters have had much success with chemical straighteners, and my own sister has done the Brazilian and Japanese straightening treatments - so I figured it was my turn.
I made an appointment for Friday, excited at the thought of smooth, silky hair so straight that it would appear longer. And, that was a big part of my desire to straighten it - I wanted bangs. The longer my hair got, the more it curled and it wasn't ever going to cover my forehead, I felt.
Well, you can guess what happened. I got the exact opposite of what I'd hoped for. I have thin, impossible to style hair now which sadly is still curly on the bottom. My scalp feels scarred and the hair feels like dental floss. I used hair glue before to contain the curls - now have to practically pour it on my head so I don't look 90 years old with puffy sections sticking out everywhere. The straight hair is aging, doesn't fit my face, and weirdly, it looks shorter than when it was curly. If I don't slick it back, it puffs out in strange and straw-like ways.
One of the worst parts is that it smells. Horrible. Like burnt microwave popcorn. No amount of washing seems to get rid of that scent. It fills my tiny office and is giving me a headache.
Ladies, let this be a lesson to you. Chemo curl is better than starting all over with your hair. Chemo curl will go away on its own. Be patient!
Let me tell you this as well. A bad hair day after you have been bald is a much worse feeling that before. It seems so unfair.
See the Bozo curls near the ears? No flatiron was strong enough to flatten it.
Not so bad but this is after a lot of work. The curls were there even under water.
Oh no, still not straight on the bottom.
I liked it much better curly.
Hmmm.....I wonder if I should do a perm?
Hair, are we ever really happy with it? Take it from a total stranger...it looks much better than you think it does!
Hey Judi, what is your email address? Can you contact me? Thanks!
Yes! It DOES look much better than you think! And soooo full!
Hey that's my hair exactly!! I have these curly whatever you want to call them at the end of my hair. The other side of my head the hair just stands up straight won't lay flat just sticks up. Looks like a cow lick lol. Oh well it's just hair.....My hair grew in a little darker and with some reddish tinges compared to my blonde locks I had previously.
You post gave me a good smile!!
I agree with Alli about your post bringing a smile. I could not help but feel that, at last, I find I am not alone. Women and hair - we always seem to want what we haven't got.
As I have only seen you with your short silver style, my thoughts were that it suited you perfectly!
Wow, you have a shitload of hair already! It looks great!
I'm 9+ months post-chemo and mine isn't as long as that and everyone that's been through this that I know keeps telling me that mine has grown much faster than most but now that I've seen your pics I am certain that mine isn't growing nearly as fast as yours! Mine didn't come back curly or wavy at all either. Mine didn't come back gray though either. It came back a few shades darker than my natural color and brunette instead of strawberry blond.
I am 11+ years post-chemo, and I still have some of the curl. Although it has relaxed considerably, there's just enough to be annoying. I have been seriously thinking about the straightener, and your description of the smell alone cured me of that notion. Work with what you have, I guess. I agree with the others -- yours looks way better than you think. You have nice, soft waves not frizz.
Wow, so much hair so soon, and I think it looks great and I love the natural color. I didn't get curls, but everyone has loved my hair really short - bangs only about 2 inches after 10 months that came in just as straight as before. When my friend husbands tell me how much they like the way I'm "doing" my hair.......Oh well. Have fun with it.
Yeah, I did lose some hair and some strands came out when I washed it yesterday.
Is there anything I can do on my own to fix it? What kind of protein treatment?
Hi Ann, it's hairstylist woman! First of all, get a bottle of Redken Cat. Do not overuse it. Wet your hair, spray the Redken Cat in it, and use a nice natural emollient in your hair on top of it, like coconut oil or olive oil. Massage it into your hair, wrap a crappy towel around it for about 15 minutes, and shampoo out with a gentle shampoo. Condition, rinse. Towel dry. Don't force your hair into anything right now. Do the protein once a week(no more) for a month, but the deep conditioning is great, do it twice a week, You can add real essentail oils to the coconut or olive oil, no more than 8 drops of lavender, or real rose. The oil is probably no more than an eight of a cup.
Thank you hairdresser woman! I'll go look for that redken product this Saturday and use as instructed. Thank you.
Ann, I think you look awesome! You have so much hair and the color is wonderful! Mine is only about an inch long but has come in a beautiful silver. I never thought I'd say this but I love it so short and I don't think I'm going to color it. It looks much better than you think!
Glad that you put the pictures up. Your hair was wavy, not curly. And I hate to break it to you, but that's just the reality of your hair growing back out, you will have awkward phases.
My hairdresser told me to blow dry my hair and use some wax to keep it from flipping up. In the beginning it was gel, but as it grows out you'll need wax because it's heavier. My hair grew back salt and pepper and I felt the same way when I looked in the mirror. Who is that? Finally dyed it back to my former color. Whew! That's better. I look like myself again.
Good Luck to you. Glad to see you're smiling.
A year after chemo and having a baaaddd ! hair day It's frizz and curl galore.
I have been using Surf Hair by Fructis and gel, I wash my hair once a week because it is pouffy for days when I wash it.
Could be worse I guess , no hair !
I love my chemo curls. I cut my hair over the ears a few times to keep my pixi cut nice and neat, then as it grew, the curls showed and I refuse to cut it. See I have always wanted naturally curly hair. The down side is I use a ton of conditioners, moisturizers and oils on my hair. Moroccan hair oil, silicone oil, coconut oil. Sometimes several together to keep it from drying out. No matter how our hair is, we are alive and that is important.
My hair came back curly at first, and an ugly silver color. I colored it back to red. Then the curls went away, and I was back to straight hair, but it was much thicker than originally. Now, for some reason, the curliness/waviness is back. My hair is almost chin length, and after I wash it, I just use something called "Curl Up," which I got at the salon. I let it air dry, finger-comb it a bit, and use another "Curl Up" product here and there. It looks wonderful and carefree. If I want, I can blow it dry and straighten it for a more polished look. I am 2 years post chemo. I have ovarian cancer, not breast.
I could only wish to have your hair!!! I am 5 months out of chemo and my hair is very thick and very tight curls growing straight up instead of down making me look like a Q tip so much my husband has nicknamed me cotton top. So although this post is really old and I pray you are still here to read this you were and are blessed.


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1) Swim/snorkel between docks and in designated swim areas when available.
2) Do not attempt to swim out to the reef.
3) Consider not wearing jewelry when snorkeling or swimming.
4) If any vessel is heading in your direction signal to make yourself visible.
5) Use a life vest or diver down buoy for visibility when snorkeling or swimming.
6) Touching coral, plant life and dock posts may cause extreme allergic reactions.
7) Always have someone watching when snorkeling or swimming at night.
8) Do not dive from docks as there could be shallow water or obstructions under water.
9) Pay attention to the wind speed and direction when kayaking away from shore.
10) A kayak and/or paddle are useful to make yourself visible while in the water.
11) Your belongings should not be left unattended on the beach or dock.
We want your vacation on Ambergris Caye to be a memorable and enjoyable one so please be safe while exploring our natural wonders.
Posted : Marty Casado - Sat, Oct 15, 2011 6:27 PM. This article has been viewed 8828 times.
How far north can golf carts and bicycles go? Can we drive all the way by road to our condo at the Costa Maya Reef?
I have read a couple places that its best to bring your OWN snorkeling gear if you plan on snorkeling because the stuff they rent out doesn't always fit well?
What are the ferry or water taxi options on Caye Caulker?
What sports are played or have facilities in San Pedro?
What is the diving & snorkeling like in San Pedro and Belize?
When is the best time to see whale sharks?
Is it possible to get Scuba Certified in Belize?
What dive instructor would you choose?
Is spear fishing while scuba diving legal?

industry_corpus2: Travel & Geography


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Welcome to Marvel 101, where you can learn all about your favourite characters, places, objects and more from the House of Ideas! Find out the awesome origins and stupendous stories behind the brightest stars in the Marvel Universe.
Track and react with millions of Marvel 101 fans just like you on TV Time.


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singer, songwriter & fashion designer @katyperry Katy Perry is selling blackface shoes but feigning ignorance.
Spring Fashion Favorites + Katy Perry SHOE HAUL | Dulce Candy Hi, queens! I hope you're all enjoying your week! I am so excited to be back doing what I love.
Singer Katy Perry is coming under fire for a shoe design that some say evokes blackface. Perry is the latest designer to be criticized for using such imagery.
For More Information or to Buy: https://qvc.co/2OKOIkP This previously recorded video may not represent current pricing and availability.
For More Information or to Buy: https://qvc.co/2OTqzIw This previously recorded video may not represent current pricing and availability.
For More Information or to Buy: https://qvc.co/2OTdVcC This previously recorded video may not represent current pricing and availability.
For More Information or to Buy: https://qvc.co/2OW4x8o This previously recorded video may not represent current pricing and availability.


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provides not more than three hours of nursing care per week per resident.
There are three sizes of CBRFs based upon the number of residents; small (5-8), medium (9-20), and large (21 or more). They also differ by class, which is determined by the resident’s ability to move about (ambulation), to follow directions (mental capacity), and to act for self-preservation under emergency conditions.
provides not more than seven hours of nursing care per week per resident.
AFHs are characterized in two ways: (1) those AFHs where the owner/licensee lives on the premises and provides resident care; and (2) AFHs that are owned by an entity that provides shift staff.
provides not more than 28 hours of supportive, personal, and nursing services per week per resident.
RCACs must be either registered or certified. Registered RCACs serve only private pay tenants, while certified RCACs may serve tenants who are eligible for public funding.
Family not available to provide care or supervision.
What Groups of People are Served By Assisted Living Facilities?
How Do Residents Pay for Their Care and Services?
Personal resources including savings accounts, pensions, insurance, veterans care benefits, or Social Security and related benefits such as SSI and SSI-E.
State and federal funding for home and community based long term care may be available for eligible participants through state programs, such as Family Care.
Funding for these programs is limited, and not all facilities are eligible.
Assisted living facilities will want to know how you will pay for your care. They will ask you to sign an admission agreement specifying the payment arrangement.
What Services Can You Expect from an Assisted Living Facility?
Personal care services such as help with dressing, eating, bathing, grooming, toileting, and mobility.
Additional services may be provided in an assisted living facility to assist residents with their personal needs and goals, such as transitioning to more independent living, counseling, transportation, money management, etc. Services may vary significantly. It is important to evaluate the facility, not only based upon current needs, but also future needs.


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Twin Lakes is a new 55+ lakefront community in St. Cloud, Florida. Builder Jones Homes plans to offer about 2,000 attached and single-family homes across 1,100 acres of scenic landscape. Homebuyers will have a variety of beautiful floor plans to choose from that will suit their styles and budgets. This active adult neighborhood will also feature a lavish clubhouse that will sit on the shorelines of Live Oak Lake and offer resort-style amenities. Residents will enjoy plenty of social activities that allow neighbors to build lifelong friendships within a vibrant atmosphere.
This active adult community is located close to shopping, dining, beaches, and attractions. It's also just 40 minutes away from Orlando for big-city entertainment and outdoor recreation.
The central hub for physical activity and relaxation will be found in the luxurious 20,000 square-foot lakefront clubhouse. Here, residents will be able to stay healthy by using the exercise equipment in the fitness center. A ballroom will be the perfect spot for dancing or attending a social function. A game room and card tables are great for fun nights with friends. Neighbors will be able to grab a drink or snack at the on-site restaurant and bar.
Outdoors, homeowners will enjoy a refreshing dip in the resort-style pool or lounge on the patio. Multiple sports courts for tennis, bocce ball, basketball, and pickleball will be available for residents who want to challenge neighbors to a friendly game. Beautiful walking and biking trails, perfect for leisurely strolls, will surround the community. The clubhouse is situated along the shores of Live Oak Lake, which will provide a pier for boating and kayaking activities as well as scenic water views.
Jones Homes began construction of Twin Lakes in 2016 and plans to build 2,000 residences. Buyers can choose from a wide variety of floor plans that come in two styles: attached or single-family homes. Active adults will love that these residences have low-maintenance exteriors and scenic views of the lake and lush landscape.
There are four unique floor plans that offer 1,351 to 1,449 square feet of living space. These homes have two or three bedrooms, two or two-and-a-half bathrooms, and an attached one to two-car garage. Homebuyers will love the spacious layouts, luxurious master suites, and covered outdoor living areas.
Active adults who want more space can choose from eight elegant single-family floor plans. These detached homes comes as one-story or two-story designs and offer 1,596 to 3,146 square feet of living space. They have one to three bedrooms, two to three bathrooms, and an attached two to three-car garage. Some features include inviting living rooms, gourmet kitchens, formal dining rooms, luxurious master suites, and covered outdoor living areas.
This vibrant 55+ community will have all of the amenities and activities that active adults could want or need for a social lifestyle. A full-time activities director will also be available onsite to help plan and organize clubs, events, and classes for all residents to enjoy. Homeowners will be able to join card games or participate in holiday events and other social activities. They will also have options for outdoor recreation like swimming, tennis, bocce ball, basketball, and pickleball. With easy access to the lake, residents will also have opportunities to enjoy water sports like kayaking, canoeing, and boating. As the community continues to grow with new residents, more activities will be offered.
Located on Hickory Road and south of Route 192, Twin Lakes will be close to shopping, entertainment, and attractions. Residents will be ten minutes from downtown St. Cloud where they will find numerous restaurants, retail shops, a library, and gas station. Just 15 minutes away homeowners will find the VA Medical Center for their healthcare needs.
Attractions like Disney World, SeaWorld, and Universal Studios Florida are great for when the grandkids come to visit and can all be reached in about 30 minutes. The beautiful beaches along the Atlantic Coast are just 40 minutes away. For big-city entertainment, downtown Orlando is a 45-minute drive and offers sporting events, performance venues, museums, and fine dining. When traveling long distance is necessary, Orlando International Airport is close by. Active adult homebuyers will love Twin Lakes' prime location and nearby attractions in Central Florida.
Clubhouse - 20,000 Sq. Ft. - Coming Soon!
There are plenty of activities available in Twin Lakes. Here is a sample of some of the clubs, activities and classes offered here.
These plans offer 1,351 to 1,449 square feet of living space. These attached homes have two bedrooms, two bathrooms, and an attached one-and-a-half or two-car garage. Homebuyers will love the spacious layouts, luxurious master suites, and covered outdoor living areas. Please Note: Floor plans are not available at this time.
Active adults who want more space can choose from eight elegant single-family floor plans. These detached homes offer 1,596 to 3,146 square feet of living space. They have one to three bedrooms, two to three bathrooms, and an attached two to three-car garage. Some features include inviting living rooms, gourmet kitchens, formal dining rooms, luxurious master suites, and covered outdoor living areas. Please Note: Floor plans are not available at this time.
After a five-year search for the best place to retire, my husband and I chose Twin Lakes after the first visit. The beautiful lakefront pier (from which we watched the SpaceX Falcon 9 rocket launch last night) and perfect temperature of the sparkling lap pool lured us, then the great floor plan and affordable home price reeled us in. It also helped that the weather was typical Florida wonderful on that first visit, in contrast to the snowstorms we gladly left behind in NY. We’ve now lived through one beautiful Central Florida winter, with many enjoyable moments together on our screened-in porch. The icing on the cake is that we’ve met welcoming and likeminded people who believe that bridges are better than walls. As for Jones Builders, they’ve gone above and beyond our expectations---we love our gorgeous new home.
What a wonderful expercience we had purchasing a new home in Twin Lakes. Everyone we worked with so helpful - and patient! I am so excited about this new neighborhood! I love the floor plan of our new house - I call it my dream house!!! We are looking forward to our move-in date in January 2017.
55places.com is not affiliated with the developer(s) or homeowners association of Twin Lakes. The information you submit is distributed to a 55places.com Partner Agent, who is a licensed real estate agent. The information regarding Twin Lakes has not been verified or approved by the developer or homeowners association. Please verify all information prior to purchasing. 55places.com is not responsible for any errors regarding the information displayed on this website.

industry_corpus2: Real Estate & Construction


text: I absolutely love it! I would recommend getting a size above what you’d normally get because they run slightly small. Other than that it’s extremely comfortable and the print is gorgeous.


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Solve a very challenging and fun puzzle. Complete the puzzle to become grand champion.
Have fun and challenge yourself. Try to solve this hot air balloon puzzle. Put all the pieces together to see the whole picture.
This is one of the best Air Hockey game ever! And you do not even need an opponent to play with. You can play it alone against the computer and have the best fun ever.
Play the best Alcohol Addiction Treatment puzzle and beat the highscore possible. Enjoy playing the game!
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industry_corpus2: Gaming


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We know well India is full of historical places and natural sights. So million of foreigner people visit India to see the historical places and enjoy the natural sight. Foreigner invests too much money to enjoy their journey and want to make it memorable moment in life. In this condition they search online tours and travel services provider at best package and book their trip for 15 and 30 days. Foreigner booked all things like car hotel services and tour guide along with. I think they invest 5 to 25 lacks easily.
You know better than me because you want to start tour and travel services and you would know each and every thing in detail about this. So you can imagine how much benefit in tour and travel services. It's not only for foreigner clients out Indian people are also found to enjoy their life. So I think all Indian people also visit historical places and natural place to enjoy their live with wife or full family. So Indian people also hire best tour and travel services provider to visit Indian places or other country. They spent lots of money to enjoy their journey.
In such condition you have only one option that you must have your own online Tour & Travel Website so that people search In Google and book online ticket. They can hire taxi, hotels and so on. Therefore, you need to design or develop fully attractive and user friendly website so that people book any things very easily and pay online.
Your website must have full information for each and every service and should be visible on each and every keyword in search result. In such condition you need SEO friendly website.
You know well website is not only enough for online business. Your website should be also appearing in Google, Yahoo and Bing Search result. So you will need to hire SEO services for this. Only professional SEO Services Provider Company can help you in such condition. We know well how much competition in Tour and Travel area.
You can hire me for SEO services for same. Just call me at - 91-9871774014.
You might like to read - SEO Live Project Training in Delhi NCR.


text: This baby is in fantastic condition and priced to sell! The gun is rated a 94/100 cosmetically (Little wear from little play) and a 100/100 mechanically. This gun comes with the case, manual, barrel sock, parts kit, tool kit, and lube.


text: Bordered by the Atlantic Ocean rests the Wave Outdoor Collection. Distinguished by its synthetic wood grain plank boards, powder-coated aluminum frame, inspired design, and rich organic feel, Wave stands out as a versatile series for outdoor dining. These contemporary modern armchairs is perfect for contemporary patios, backyards, poolside, and other outdoor lounge areas.

industry_corpus2: Manufacturing


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So good to see Martine’s beautiful pennant has arrived home in The Netherlands safe and sound! The circle is complete, the spell is cast, all the pennants and talismans are on their way back to their makers around the world. Making the dream was the most beautiful ride on a huge wave of love that has now brought me gently to shore. The circle will keep rippling with love for our beautiful broken world.
I will keep updating this post as everyone sends back photos of where their pennant or talisman has settled to keep the dream alive!
“I’m just sending this pic of the talisman with the lace and tulle, that for now, I’ve draped and pinned to a couple of my small art quilts, otherwise it all disappears into the cream wall behind. (Actually, now that I look at the photos again, I really like the red hearts showing through from behind) I have an idea of making them into something more permanent, stitching them to a backing so the fine lace and tulle can be clearly seen. I have some silk scarves my son brought me from Darjeeling, that he was given when he stayed in a Nepalese homestay, and I feel to give substance and depth to the finery will be a good use of these.
“Yesterday your package arrived safely here in Holland, Thank you so much ! The piece feels like it brought home lots of vibrations and good will of all the other pieces that surrounded it during your wonderful exhibition and of course of YOU ! I’m so happy with the extra pieces you included : they will surely find their way into other pieces I will make ! LOVE the piece of the blue branch and the many stars it surrounded !!! I will find a special place for them too 😉 You did a wonderful “job”, with your idea, the binding of the stitchers in a loving circle all around the world, and the realization of the artwork itself … magic !
makes and tends to the fire needed for ritual sweat-lodges (Indian style) It is a good place for the heart to rest !
“Everything about this from start to finish has been magical. My heart is filled with such joy right now looking at how lovingly you have packaged all this OMGOODNESS .. by far being part of this journey has risen me to new highs in ways I cannot find the words for.
Thank you .. thank you!!
Elizabeth knows how to photograph light!
Thank you Mo, for your vision and great heart … I will treasure the memory and the beautiful pieces you sent.
Liz Ackert’s pennon for the dream traveled all the way from Texas !
here’s the pennon, shell and card happily settling into the studio space, the dream is real, I can hold it in my hands and read it!
this side of the cloth holds words from Old Man Crow, Terry Tempest Williams, Wendell Berry, John Lennon, Clarissa Pinkola Estes, Dee Mallon, Marti in New Mexico, and me!
stirring the pot, magic is afoot!


text: I hear it is mighty cold out your way. Not here. I was wearing my t-shirt outside today while at the park. My spring bulbs are coming up and the daylight is finally getting longer.


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Only $2.94 per cigar... Save 61% + FREE Shipping!
Stockpile the coolerdor with Cuban-legacy smokes your cigar-ransacking pals will sniff out from a mile away thanks to the sub-wholesale discounts you scored on Ramon Allones Heritage Series at the Holt’s checkout. An oily Ecuador Habano wrapper leaf embraces a balanced recipe of all Nicaraguan long-fillers in a pair of cool-burning shapes you can effortlessly puff on all afternoon without making a dent in your cigar savings. Enjoy medium-bodied flavors of baking spices, coffee with cream, and a chewy, sweet finish. Add Ramon Allones to your rotation while another classic brand is caught in the crosshairs of our radar for rock-bottom prices, son!


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Architectural and Interior Design service from concept to completion in Lisson Grove. Planning, Feasibility Assessments, Technical Drawings, Interior Design, Immersive 3D Modelling, On Site Visitation and Contract Administration. Book A Free Consultation.
From our base in Battersea we take on projects within London and have good relationships with Lisson Grove’s local planning authority, Wandsworth Council.
We will diligently guide you through each stage of the process from conceptual design / planning approval through to the completion of your dream project in Lisson Grove.
Armstrong Simmonds Architects will work with you to develop a concept design, sketching layout options to explore the potential of the property. We will also carry out a full measured survey of the property in Lisson Grove and its surroundings, allowing us to produce an accurate set of drawings.
Following on from the briefing we will prepare a set of scale drawings reflecting the range of ideas discussed. We will prepare and submit the planning application, liaising with the Lisson Grove’s local planning authority, Wandsworth Council, as needed throughout the process. Our extensive experience will help facilitate a smooth planning process.


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industry_corpus2: Biopharmaceuticals