text:
Search Warrants for Digital Devices
Jeff Welty, Associate Professor, University of North Carolina at Chapel Hill
A warrant is normally required to search a digital device. Under most circumstances, individuals have a reasonable expectation of privacy in the contents of their digital devices, such as cellphones, tablets, and personal computers. Therefore, the Fourth Amendment requires a law enforcement officer to obtain a search warrant before searching such a device, unless an exception to the warrant requirement applies. The U.S. Supreme Court recently eliminated one important exception when it held that a digital device may not be searched incident to arrest.3 Thus, a search warrant will often be necessary to search a suspect's digital devices.
Establishing Probable Cause
A warrant requires probable cause. In general, probable cause to search a digital device is no different from probable cause to search a physical object or location. But there are several probable cause issues that are unique to digital searches.
Probable cause may be based on an IP address.Investigators sometimes determine that criminal activity has been conducted through a particular Internet Protocol (IP) address and are able to trace the IP address to a residence, only to learn that the residence has an unsecured wireless network. In such a case, investigators may be unable to rule out the possibility that a neighbor or a passerby, rather than a resident, used the network for criminal purposes. Nonetheless, courts have generally ruled that there is probable cause to search the digital devices at the residence, as residents are the most likely users of the network.4
Probable cause in child pornography cases.Courts have addressed a number of recurrent issues that arise in child pornography investigations. In general, the following guidelines apply:
Drafting Warrant Applications and Proposed Warrants
Several practices should be followed when drafting search warrant applications and proposed search warrants for digital devices.
Include digital-specific language.The Fourth Amendment requires that a search warrant describe the place to be searched with particularity. If a warrant identifies a physical location, such as a suspect's home or office, without specifically mentioning digital devices that may be present, there may be some doubt about the sufficiency of the warrant to authorize the search of the devices. Several courts have ruled that such a warrant is adequate, because a warrant authorizing the search of a particular location for a particular item generally authorizes the search of any container at the location that might reasonably contain the evidence sought, and digital devices are containers for information.7 For example, a warrant authorizing the search of a home for records of drug sales, lists of drug customers, and the like would allow the search of any drawer or box within the home in which the records could reasonably be found—and the search of any computer or cellphone that could contain such records.8 However, a few courts have suggested that digital devices are different and normally may be searched only if specifically permitted by the warrant.9 Therefore, a cautious officer who anticipates needing to examine digital devices should note that fact in the application and provide for it in the proposed warrant. Officers should also seek authorization to seize technical manuals, power cables, and passwords associated with digital devices, as not having these items may make a forensic search more difficult.
Describe the items to be seized in as much detail as reasonably possible.The Fourth Amendment requires that a warrant describe the items to be seized with particularity. In most cases involving digital devices, the devices themselves are incidental to the true object of the search, which is the information contained on the devices. Thus, a warrant application should describe the files or information sought, not merely the devices, and should do so as specifically as reasonably possible. At a minimum, it should link the material sought to a specific offense. A court may view as overbroad a warrant that authorizes the seizure of all digital devices that belong to a suspect, but is likely to approve of a warrant that authorizes the seizure of all digital devices that belong to the suspect and that could contain evidence of the specific crime under investigation.10 In an appropriate case, the description of the items to be seized could be further tailored by limiting the files to be examined to files created or accessed by a specific user or files created or accessed on or after a specific date.
Include authorization for off-site forensic analysis.In theory, a suspect's digital devices could be searched at the location where they are seized. In practice, the massive storage capacity of modern digital devices and the need to use specialized forensic tools to examine them makes it more practical to search such devices in a laboratory setting. Therefore, the application should explain that officers plan to seize the digital devices and take them offsite for copying and forensic analysis, and the warrant should authorize this procedure.11 It is a good idea to make clear that this process will be time-consuming. If a defendant later argues that the search was not completed within the jurisdiction's time limit for execution of a warrant, the warrant application will be evidence that the issuing court was aware of and approved the expected time frame for the examination.
Do not include a search protocol.Because digital files can be camouflaged or disguised through misleading file names or extensions, it may be necessary to examine every file on a digital device when searching for incriminating material. Officers often use keyword searches, hash value searches, and other automated searching techniques to facilitate this process. An influential Ninth Circuit opinion has suggested that the search protocol that officers plan to use should be described in the warrant application, so that a judicial official may assess whether the search protocol is likely to retrieve only relevant material.12 However, most courts have held that a search protocol need not be included.13 As one court stated, "[i]t is unrealistic to expect a warrant to prospectively restrict the scope of a search by directory, filename or extension or to attempt to structure search methods—that process must remain dynamic."14 The U.S. Department of Justice advises federal officials not to include any "[l]imitations on search methodologies" in the warrant or application.15 In light of this recommendation and the weight of authority, officers should not include a specific search protocol in a warrant application.
Present the application to an appropriate judicial official.In most jurisdictions, any judicial official empowered to issue search warrants may issue search warrants for digital devices. However, a cautious officer handling a serious case may prefer to submit a search warrant application concerning a digital device to a judge rather than to a magistrate. In particular, if the officer is seeking a warrant for a new type of device or a new type of digitally stored information, a judge may be better suited than a magistrate to identify possible legal problems with the warrant.
Executing the Warrant
Handle digital devices properly.Many state crime laboratories provide guidelines on handling digital devices properly during a search. The guidelines often address issues such as whether to leave devices on or turn them off, and whether to shut devices down normally or simply unplug them. Officers who are unfamiliar with searching digital devices should review these guidelines or consult with officers experienced in digital forensics.
Comply with timing requirements.Most jurisdictions require that search warrants be executed within a specific amount of time, such as "within 48 hours from the time of issuance" or "within a specified time no longer than 14 days."16 It likely is sufficient if the initial seizure of the digital devices is completed within this time period, even if the subsequent off-site forensic analysis takes longer.17 Concerns about the timing of the search may be reduced by obtaining explicit authorization in the warrant for a laboratory forensic analysis. Still, some courts have criticized extremely long delays in examining digital evidence, so any forensic analysis should be completed promptly.18
Obtain a second warrant when evidence of another crime is found.When an officer obtains a warrant to search for evidence of one crime, but stumbles on evidence of another, the officer should obtain a second warrant authorizing a search of the device for the second crime. Arguably, this is unnecessary; it is impossible to know what a given file contains without examining it and most courts would allow the officer to search every file on the device for evidence of the first crime, rendering all the evidence of the second crime in plain view. However, one U.S. federal court of appeals has ruled that a warrant is necessary when an officer changes the focus of his or her search of a digital device, and another has called into question the use of the plain view doctrine in searches of digital devices.19 Because the law in this area is unsettled, obtaining a second warrant is prudent.
Dealing with password-protected devices.Digital devices, especially cellphones, may be password protected. In some cases, officers with training in digital forensics may be able to bypass the password. In other cases, the manufacturer of the operating system may be able to extract some information from the device despite the password. This may require obtaining an additional search warrant to be served on the manufacturer. For example, Apple can extract "SMS, photos, videos, contacts, audio recording, and call history" from locked iPhones, but will do so only pursuant to a search warrant containing the specific language contained in Apple's law enforcement guidelines.20 However, because password protection may make it more difficult, or even impossible, to access the information on a digital device, officers should (1) seize any papers near the devices that may contain passwords, and (2) attempt to prevent active devices from shutting down or "sleeping" such that entry of a password is required to activate the devices.
Expect technical limitations.Enormous amounts of information may be extracted from digital devices. For example, cellphones may contain GPS location information, and computers may contain recoverable deleted files. But devices vary, and digital evidence technicians warn that some will bear more fruit than others, depending on storage capacity, operating system, security features, and other factors.
Preparing the Return and Inventory
In most jurisdictions, an officer who executes a search warrant must promptly return the warrant to the court. The officer usually must also provide the court and the person whose property was searched or seized a written inventory of the items seized. Searches of digital devices present several issues regarding returns and inventories.
Make the return after the initial seizure.Should the warrant be returned after the initial seizure of a suspect's digital devices, or should it wait until the subsequent forensic analysis is complete? There is little authority on point, but the prevailing practice is to return the warrant after the initial seizure of the suspect's devices, even if the devices have not yet been subjected to an off-site examination. One justification for this practice is that it provides evidence of compliance with the requirement that a warrant be executed within a particular time period after issuance.
List the devices themselves on the inventory, at least initially.Another question is whether the inventory should list the devices themselves, or the files and data within the devices. Because an officer generally completes an inventory at the same time he or she returns the warrant, the prevailing practice is to list the digital devices as items seized, making no reference to specific data or files, which often have not been extracted at this juncture. This is probably sufficient, though a cautious officer might file a supplemental inventory listing the data or files seized after the off-site search of the devices. In any event, in most jurisdictions, imperfect compliance with the return and inventory requirements is a technical defect that is unlikely to require the suppression of evidence.21
Special Cases
Special problems arise when searching digital devices that belong to third parties not suspected of any crime; when searching digital devices that contain privileged material, such as devices that belong to attorneys or physicians; and when searching digital devices that belong to the news media, broadly defined.
Jeff Welty is an Associate Professor of Public Law and Government at the University of North Carolina at Chapel Hill. He trains judges, prosecutors, and law enforcement officers in criminal law and procedure.
Today, 90 percent of U.S. adults own a cellphone, and digital devices of all kinds are proliferating.22 Although both the technology and the legal landscape are in flux, it is essential that officers become proficient at using search warrants to obtain digital evidence. ♦
Notes:1Riley v. California, 573 U.S. __, 134 S.Ct. 2473, 2493 (2014).2For more details, see Jeffrey B. Welty, Digital Search and Seizure (UNC School of Government, forthcoming 2015).3Riley, 573 U.S. at __, 134 S. Ct. at 2485. By its terms, Riley applies only to cellular phones, but its reasoning plainly applies to digital devices more broadly.4See, e.g., United States v. Vosburgh, 602 F.3d 512, 526 (3d Cir. 2010); United States v. Perez, 484 F.3d 735, 740 (5th Cir. 2007); see also United States v. Thomas, 2012 WL 4892850, *4 (D. Vt. Oct. 15, 2012) (unpublished).5In the alternative, the officer might attach the material under seal, if the officer has access to the material. 6For case citations on these issues, see Welty, Digital Search and Seizure.7Wayne R. LaFave, Search and Seizure: A Treatise on the Fourth Amendment, § 4.10(b), 5th ed. (St. Paul, MN: West, 2012); cf. United States v. Ross, 456 U.S. 798 (1982) (expressing a similar rule as to warrantless vehicle searches).8See, e.g., State v. Gurule, 303 P.3d 838 (N.M. 2013); United States v. Giberson, 527 F.3d 882 (9th Cir. 2008).9United States v. Payton, 573 F.3d 859 (9th Cir. 2009) (suggesting that computer-specific language normally is required before digital devices may be searched pursuant to a warrant).10Compare United States v. Galpin, 720 F.3d 436, 446 (2d Cir. 2013) (the court stated that the "particularity requirement assumes even greater importance" with digital searches as "advances in technology… have rendered the computer hard drive akin to a residence in terms of the scope and quantity of private information it may contain"), and Mink v. Knox, 613 F.3d 995, 1011 (10th Cir. 2010), with United States v. Christie, 717 F.3d 1156, 1164-65 (10th Cir. 2013) (noting that application of the "Fourth Amendment's particularity requirement to computer searches [was still relatively new" but identifying as a "recognizable line" the notion that warrants lacking a "limiting principle" tend to be invalid, while warrants which are limited in their scope to either evidence of a specific crime or evidence of a particular type of material tend to be valid).11See United States v. Evers, 669 F.3d 645, 652 (6th Cir. 2012); United States v. Mutschelknaus, 592 F.3d 826 (8th Cir. 2010) (warrant allowing officers 60 days to conduct off-site examination of seized computer was reasonable given the complexity of computer searches); United States v. Grimmett, 439 F.3d 1263, 1269 (10th Cir. 2006); In some jurisdictions, further off-site examination of digital devices is presumptively authorized by rule or statute. See, e.g., Fed. R. Crim. P. 41(e)(2)(B) (stating that "[u]nless otherwise specified, [a] warrant [for digital devices] authorizes a later review of the media or information consistent with the warrant").12United States v. Comprehensive Drug Testing, Inc., 621 F.3d 1162, 1179 (9th Cir. 2010) (en banc) (per curiam) (Kozinski, C.J., concurring).13Evers, 669 F.3d at 653-54; United States v. Cartier, 543 F.3d 442, 447 (8th Cir. 2008); United States v. Khanani, 502 F.3d 1281 (11th Cir. 2007); United States v. Brooks, 427 F.3d 1246, 1251 (10th Cir. 2005).14United States v. Burgess, 576 F.3d 1078, 1093 (10th Cir. 2009).15United States Department of Justice, Criminal Division, Computer Crime and Intellectual Property Section, Searching and Seizing Computers and Obtaining Electronic Evidence in Criminal Investigations, 3rd ed. (2009), 79, http://www.justice.gov/criminal/cybercrime/docs/ssmanual2009.pdf (accessedSeptember 10, 2014).16N.C. Gen. Stat. § 15A-248; Fed. R. Crim. P. 41(e)(2)(A)(i).17Some jurisdictions expressly so provide. See, e.g., Fed. R. Crim. P. 41(e)(2)(B). Even where there is no express provision, a court is likely to allow continued forensic analysis outside the designated time period. See, e.g., United States v. Cameron, 652 F.Supp.2d 74 (D. Me. 2009).18See, e.g., United States v. Ganias, 755 F.3d 125, 137 (2d Cir. 2014); United States v. Cote, 72 M.J. 41 (C.A.A.F. 2013) ("the Government's violation of the warrant's time limits for conducting an off-site search of the seized electronic device constituted more than a 'de minimis' violation of the warrant and resulted in an unreasonable search"; court suggests in a footnote that even absent the explicit time limit in the warrant, the Fourth Amendment's reasonableness requirement may be implicated by such a long delay).19United States v. Carey, 172 F.3d 1268, 1273 (10th Cir. 1999). But see United States v. Brooks, 427 F.3d 1246, 1251 (10th Cir. 2005); Comprehensive Drug Testing, Inc., 621 F.3d, 1178.20Apple, Inc., "Legal Process Guidelines: U.S. Law Enforcement," Apple.com (May 7, 2014), https://www.apple.com/legal/more-resources/law-enforcement (accessed September 8, 2014).21State v. Nadeau, 1 A.3d 445, 463-64 (Me. 2010); State v. Fruitt, 35 N.C. App. 177 (1978).22Pew Research Internet Project, "Mobile Technology Fact Sheet," www.pewinternet.org/fact-sheets/mobile-technology-fact-sheet (accessed September 10, 2014).
Please cite as:
Jeff Welty, "Search Warrants for Digital Devices," The Police Chief 81 (October 2014): 98–100.
From The Police Chief, vol. LXXXI, no. 10, October 2014. Copyright held by the International Association of Chiefs of Police, 515 North Washington Street, Alexandria, VA 22314 USA.


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Bread Ice Cream
There isn't anything unusual about using bread in dessert recipes, and I've certainly eaten my fill of bread pudding, fruit charlotte and pain perdu, but one dessert I've yet to try, is ice cream made with bread. It sounds a bit weird right?
You know that phenomenon that occurs when you learn a new word and suddenly you see and hear it everywhere? Well that phenomenon apparently works for me as well with unusual ice cream flavors.
A couple of weeks ago, I was leafing through the new cookbook Dessert, by David Everitt-Matthias, and in between pausing to wipe the spittle from my chin, I came across a most unusual sounding recipe for croissant ice cream. My immediate reaction was one of confusion, and perhaps even mild disgust, but the more I thought about it, the more the idea grew on me. Then I got to a part in the recipe where the author suggests substituting rye bread for the croissants, and that sent my creative juices into overdrive.
For days after reading about it, I couldn't get my mind off of the rye bread ice cream and kept toying around with ideas of what might go well with it. A pastrami and spicy brown mustard tart was obviously out of the question, but a dense apple or moist carrot cake both seemed to have potential.
Then, a few days ago, I went to read the latest edition of David Lebovitz's blog, and what do you think he had written about? You've got it, bread ice cream! Only his was yet another rendition, this one made with brown bread.
While each of these ice cream recipes features bread, the techniques are very different. In the croissant or rye bread recipe, the bread is steeped in the warm cream before it's added to the eggs. This method allows the bread's unique flavor to permeate the base of the ice cream, but doesn't add much in the way of texture to the end product. The brown bread recipe, on the other hand, calls for caramelizing brown bread crumbs in sugar until they're crisp, and then adding them to the churned ice cream, for little subtle bursts of flavor and crunch. Both techniques sound intriguing to me and using them interchangeably sounds like it could also be fun.
Of course, these recipes got me considering other types of bread that might also work well in ice cream and I think that something interesting could come from playing around with sourdough, panettone, soft pretzels, walnut bread or Portuguese sweet bread. I'll keep you posted.
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subset: commoncrawl


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Focal North America Introduces Utopia, Elear, and Listen Headphones|Alberta, CANADA | June 17, 2016 - Focal, a leading French speaker and headphone manufacturer, today unveils the company's newest line of three premium headphones; Utopia, Elear and Listen. Focal's high-end headphones are the result ...read more
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I recently ran across an interesting article in WIRED that describes
the vision of former Google software engineer Patri Friedman to build
private floating islands that would function as sovereign utopias:
Turns out there's actually a short history of similar but unsuccessful ventures, including:
- Operation Atlantis, an attempt at an independent laissez-faire capitalist society created by millionaire Werner Stiefel in the late 1960s. He got as far as a cement barge that was run off by the Haitian government, then destroyed by a storm near Cuba.
- The Republic of Minerva, an island in the South Pacific created in 1971 by real estate magnate Michael Oliver, who poured a bunch of sand onto some reefs and stuck his flag in it. It suffered the indignity of being invaded by Tonga, then dissolved into the sea.
- The Oceana city project, conceived in 1993 as a floating settlement near Panama, never made it off the page.
Unlike some previous attempts at oceanic utopias, Friedman has some solid engineering and science backing up his proposed venture. But while the Bay Area venture capitalists that support him definitely share the libertarian ideals of their predecessors, they seem less interested in visions of Ayn-Randian social utopias and more interested in the idea of kickass tax shelters where they can gamble, do drugs and shoot grenade launchers at the horizon. Not really fodder for an epic sci-fi/horror video game, I guess.


text:
The Fix (Hardback)Damian Thompson
Hardback Published: 24/05/2012
- Not available
Addictions to iphones, painkillers, cupcakes, alcohol and sex are taking over our lives. Our most casual daily habits can quickly become obsessions that move beyond our control. Damian Thompson, who has himself struggled with a range of addictions, argues that human desire is in the process of being reshaped. Shunning the concept of addiction as disease, he shows how manufacturers are producing substances like ipads, muffins and computer games that we learn to like too much and supplement tradition addictions to alcohol, drugs and gambling. He argues that addictive behaviour is becoming a substitute for family and work bonds that are being swept away by globalisation and urbanisation. This battle to control addiction will soon overshadow familiar ideological debates about how to run the economy, and as whole societies set about "fixing" themselves, the architecture of human relations will come under strain as never before. The Fix offers a truly frightening glimpse of the future and is essential reading for fans of Naomi Klein's 'No Logo', Oliver James's 'Affluenza' and Francis Wheen's 'How Mumbo-jumbo Conquered the World'.
Publisher: HarperCollins Publishers
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Reblogged Aug 8, 2016 at QViews
I recently volunteered to help a sales manager develop a customer journey map for her company. When she left I began sharing it with the CEO, but the CEO was turned off by it. The process seemed completely unnecessary to her (the CEO). The CEO and founder does want to... Continue reading
Posted Aug 5, 2016 at Steady CRM
Imagine using your loyalty rewards to order a nice cooler. Maybe it will be cheaper because it comes with the logo of your favorite water brand. Now imagine carrying your cooler past a convenience store and that cooler reminding you to buy the branded water. Now imagine it sending a... Continue reading
Reblogged Aug 4, 2016 at Steady CRM
We can enjoy a terrific interview with Chris Voss published by Talks at Google. Chris is the reigning educator on negotiating skills, and his book is Never Split the Difference. Yes is a commitment, no is protection (not a problem, just a good beginning) Make your counterpart (not adversary!) feel safe, and they grow more creative Hesitate and let your counterpart think Don't ask for a 'few minutes to talk,' instead say... 'is now a bad time to talk'? Summarize the other person's point of view, even if it's not in your favor. Get them to say 'That's right' because... Continue reading
Posted Aug 3, 2016 at QViews
The same communication tools which support our health can be used to encourage overspending and dependency. We have to be careful with our loyalty. Luxury brands won't solve our status challenges, and expensive drugs can't solve our health problems by themselves. We have to integrate a healthy, skeptical search for... Continue reading
Reblogged Aug 1, 2016 at Steady CRM
Seth Godin is very good at reminding people to keep going even though they are not yet seeing results. (I highly recommend The Dip: A Little Book That Teaches You When to Quit (and When to Stick). Recently he reminded us that we can't reason our way into cultural change. No matter how good the reasoning, we have to expect slow change based on our commitment. If we trust our reasons we have to trust that time is on our side. We have to be role models and cheerleaders and analysts, and we have to figure out how to sustain... Continue reading
Reblogged Jul 29, 2016 at QViews
Not many of us think about hanging out in a hotel in our hometown. Often the food is just okay, and the decor very corporate. Hyatt, Westin and Marriott have recently instituted programs and rewards to attract local residents. Travelers are reassured by seeing locals, and their experience becomes more... Continue reading
Reblogged Jul 28, 2016 at Steady CRM
What I love about Daniel Kahneman is that he's opened our eyes to the fact that just because behavior is irrational, doesn't mean we can't understand it. We CAN understand and control irrational behavior, and we don't have to control all of it... Just the part that's doing us harm. I recently discovered the writings of Chris Dillow, who's applying the principles to politics. What a relief. Stumbling and Mumbling: Cognitive biases, ideology & control, 2016-July-3 by Chris Dillow If people are subject to cognitive biases when they have big incentives to be right – when they are investing their... Continue reading
Reblogged Jul 27, 2016 at QViews
We want to provide the very best solutions for our customers. So we study the competition carefully, committed to staying on top of the latest trends. We study the research, hoping to be the first to unearth an important new insight. Unfortunately, those honorable activities often cause us to disconnect... Continue reading
Posted Jul 26, 2016 at Steady CRM
I read many articles from mass email service providers about how to write more productive emails. Now I'm getting a fresh perspective from the GMail app called Boomerang. The application reminds its users if an email has not yet received a response, among other features, and is now available for Outlook as well. Boomerang decided to analyze the 40 million emails that used their application last year, and recommend... Keep the writing complexity down to 3rd grade level (use the Flesch Kincaid analyzer to measure) Include a couple of questions Write with gentle emotion (see below) 75 to 100 word-long... Continue reading
Reblogged Jul 20, 2016 at QViews
When we build an image for our brands, we have to consider so much more than "marketing communications." Our actions and our interests convey so much more than tweets and advertisements could ever communicate. On of our role models in 'acting out the brand' is KIND Snacks. Prophet: The Not-Only-for... Continue reading
Posted Jul 18, 2016 at Steady CRM
People tell us that good planning will lead to project success but that's a lie. Good planning can keep your friends on your side when the project is completely messed up. Good planning can help you track where things went off the rails. Good planning can lessen your guilt, but wait, maybe we have nothing to feel bad about... Psychology Today: Big Projects, Big Mood Swings, 2016-Jun-30 by Jim Stone In general people feel far too much shame when one of their projects fails due to unforeseen complications. It happens to nearly everyone who bothers to take on large projects... Continue reading
Posted Jul 15, 2016 at QViews
As we try to drive loyal customer behavior, we often make mistakes because we over-simplify. We don't just have one kind of customer who is more loyal. Our loyal customers have diverse motivations, and their behavior can be triggered by various events. And they experience different emotions, yet all still... Continue reading
Reblogged Jul 14, 2016 at Steady CRM
In the U.K., Virgin has released a new mobile app, Virgin Red, which is designed to attract current and new customers. Games, quizzes, content and unusual offers convey the entertaining brand image of Virgin. Current customers can log their loyalty and be recognized for their loyalty, but non-customers can still... Continue reading
Reblogged Jul 8, 2016 at Steady CRM
What I love about this story is that it offers a method for schools and other institutions to shift perceptions and behavior in their community. Lots of big city school districts have public relations departments, but few of them "work smarter" to make change the way this team does. It's very inspiring, and I recommend reading the whole story at David Meerman Scott's blog on www.WebInkNow.com. WebInkNow: Brand Journalism at Cleveland Metropolitan School District, 2016-Jun-29 by David Meerman Scott The Cleveland Metropolitan School District serves some 40,000 students. [Chief Communications Officer] Roseann [Canfora]'s team not only focuses on reaching the... Continue reading
Reblogged Jul 7, 2016 at QViews
Just try telling people they can't join... we're pretty sure that's not what actually happened, but... "Invitation only" worked its magic and churned up lots of interest in the A-List at Chick-Fil-A. The program has been rolled out slowly with individual location operators offering the best customers a membership card,... Continue reading
Reblogged Jul 6, 2016 at Steady CRM
Many companies think that 'customer marketing' equals 'buy more.' Actually, customers want to be contacted for a variety of reasons--their reasons. Inc.: Why Winning Millennials' Loyalty Is Easier Than You Think, 2016-Jun-22 by Molly Reynolds "[Crowdtwist] research indicates that Millennials are very brand loyal, so we wanted to get to... Continue reading
Reblogged Jun 28, 2016 at Steady CRM
Some things are unmeasurable, at least in a practical, affordable way. David Ogilvy used to say, "We sell. Or else." It's not that all those intermediate steps aren't necessary... they're just not measurable. That's why mapping customer journeys help so much. Figure out the path from attention to engagement to interaction to sale... but don't stop working until you have a measurable sale. Canalside View: The Trouble with Engagement, 2010-Jun-21 by Martin Weigel Engagement is one of the most unhelpful pieces of language we bandy around. At best it is entirely meaningless. At worst, it encourages all manner of dangerous... Continue reading
Posted Jun 27, 2016 at QViews
At most companies, the customer journeys through knowledge toward a purchase. But loyalty leaders like Sephora recognize that they have to keep creating new experiences to keep the customer on the right path. In our customer marketing we should always be asking ourselves, what can I do for the customer... Continue reading
Posted Jun 24, 2016 at Steady CRM


text:
10 Seeds per pack
Indoor as well as Outdoor
400 - 500 g/m² in SOG
8 - 10 weeks
Potent F1 hybrid of Skunk #1 and Skunk Special.
Strong flavor, powerful buzz.
Commercially interesting yields.
Super Skunk is our successful attempt at beefing up the famous Skunk #1 strain by crossing it with our Skunk Special. One of the first to match the potency of powerful import hashish available in coffeeshops, this F1 hybrid is well-known for its strong flavor and powerful buzz. Super Skunk is much easier to grow and manicure than "white" strains. Yields have great financial potential. This strain also works well in greenhouse or shed operations.
|Skunk#1 x Skunk Special
|Plant Type
|Indoor as well as Outdoor
|Plant Height
|Average Yield
|400 - 500 g/m² in SOG
|Flowering Period
|8 - 10 weeks
|Seeds per pack
|Happy, Relaxed, Euphoric
|Skunk, Pungent, Earthy
|Depression, Stress, Pain
I'm like a kid in a candy store when I got my package. At first I almost throw it away than I remember what I was waiting for. Cant wait to get started. I'm so happy now.
Boom! Customer service was top notch, package was very discrete, can't wait to try out these seeds. Thank you very much nirvana! I WILL be ordering more seeds in the future! :D
I absolutely love this plant. Super Skunk is the best of all worlds. You get a great plant that mine grew 6 feet tall and once pruned right then it turned into a tree of buds. You cannot hide this smell so do not carry it in your car on yourself. I took a small amount in a baggie that was also wrapped up inside a ziplock bag and folks I worked with said that I smelled like I had ran over a skunk on the way to work. LOL. Very strong high and my first order turned out 4 females out of 5 seeds which I used the male to pollinate one branch on one of my female plants which gave me enough seeds to share with others and to keep my growing from fresh seeds whenever I wanted. Great seeds and discreet shipping. I will order several more times and experiment with different strains. Thanks, Mike.


text:
book your appointment
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Phone: (905) 456-8196
Call Us to Book Your Appointment:905 456 8196
At the BodyMend Health and Wellness Clinic, physiotherapy clinics and sports injury clinic, our physiotherapist, massage therapist and chiropractor are pleased to offer you customized health and wellness physiotherapy, massage therapy, sports therapy, back pain, shoulder pain, sports injury, rehab and a variety of other healing services in a refreshing and re-energizing environment. A visit to our Brampton health and wellness clinic can be a welcome break in your busy day!
Our personable and professional best physiotherapist, massage therapist and chiropractor in Brampton are happy to work collaboratively with you as you embark on your journey of healing. Your care is carefully customized to meet your unique health and wellness goals.
We believe we have done our job well when you leave our Brampton health and wellness clinic, physiotherapy clinics and sports injury clinic feeling refreshed, re-energized, and motivated to continue on your journey to better health. Try our Bramalea physiotherapy walk-in and physio rehab health Clinic in Brampton.
Our goal is to be "mending you back to better health."
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text:
Research Article
A minimal set of bacterial cellulases for consolidated bioprocessing of lignocellulose
Version of Record online: 3 AUG 2011
DOI: 10.1002/biot.201100157
Copyright © 2011 WILEY-VCH Verlag GmbH & Co. KGaA, Weinheim
Biotechnology Journal
Special Issue: Biotechnology in Asia
Volume 6, Issue 11, pages 1409–1418, November 2011
Additional Information
How to Cite
Liao, H., Zhang, X.-Z., Rollin, J. A. and Zhang, Y.-H. P. (2011), A minimal set of bacterial cellulases for consolidated bioprocessing of lignocellulose. Biotechnology Journal, 6: 1409–1418. doi: 10.1002/biot.201100157
Publication History
- Issue online: 9 NOV 2011
- Version of Record online: 3 AUG 2011
- Accepted manuscript online: 14 JUN 2011 06:40AM EST
- Manuscript Accepted: 6 JUN 2011
- Manuscript Revised: 4 MAY 2011
- Manuscript Received: 9 MAR 2011
Funded by
- DOE BioEnergy Science Center
- DOE Office of Science
- College of Agriculture and Life Sciences Biodesign and Bioprocessing Research Center at Virginia Tech
- Chinese Scholarship Council
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We found 1 that has recently dropped in price.
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2000 BMW 7 Series 740i 4dr Sedan
Good car love it.
This is my 5th BMW, and also my favorite. Ive owned several 3 series and 5 series. All great cars but the 7 series of this E38 generation is truly special.The powertrain is strong by the standard of the 00, for 99% of your driving the power is more than adequate. The lines are classic, I still think the best of all BMW and the car continues to turn heads like no other. Clean, taught, uncluttered, and purposeful. The true sport package on the 740i is tighter than most would like, would recommend the non-sport for most people.If you are not mechanically included, or do not have a mechanic you trust and dependent on the BMW dealership, you may want to step with caution.
Comfort is great, seating position is about as good as it gets. Driving dynamics are wonderfully classic BMW.
Car has been free of major issues and after 4 years months of ownership, lower repairs than average ($200-400/yr) but some of this is DIY. It is easy to maintain if you have technical skills, online sites like E38.org are well organized and helpful.
The latent load on the battery is high, if you dont drive everyday suggest you plug into a battery tender.
I think the stereo is good, but not great nor as pure as I would have hoped.
This car is awesome no other way of saying it. it is better than any 7 series for sale today. the styling is classic. the interior is perfect and doesnt have any bmw i drive nonsensejust a good sized navigation system that matches perfectly in the center, the driving feel is awesome too. the leather quality is excellent and the rear seat leg room is something the be seen. the engine may be short of 300 hpbut you wouldnt be able to know once you floor it. the engine is perfect, the transmission is one of the smoothest out there. the car may be long and heavy but bmw has managed to make it feel only slightly short of an M3's handling capabilites. this car is a joy to drive.
handling, engine, rear seats they are more comfortable than some couches. front lay out, styling, transmission,engine noise, stereo, brakes the brakes feel like they are racing brakes they work flawlessly, traction control system is exellent.
have the Vanos not need replacing and 180k miles. find a way to improve city gas mileage, im averaging about 14 when driving city streets and 20-22 highway on long trips.
i have owned more than 10 cars and for some reason they all get played out and sold. i got offered a reasonable price but could not sell it. i owned it for 5 years now. performance love it, still looks better then the 745il models. drives fast with out realizing (bad in some cases). maintenance is not bad at you local mechanic (water pump & fan with belts tune up and other few thing ran about 1200, same price as my 2001 Honda prelude) and no time seeing my self getting rid of it.
steering wheel,surround sound system, love the gear shifter in sport mode
cup holder
Bought the car almost three years ago. My first Bimmer will likely be my last. As much as I love driving the car, it is waaaaay too costly to fix. The plastic (!!) tank on the radiator split 5 days after I purchased the car. I've had to replace the water pump, thermostat, and power steering pump. Right now I could drop $8k on the car just to fix the many problems that I live with, including: - ABS computer dead (no traction control), - Thrust bearings in front suspension, - Tranny needs to be replaced (but car still drives, - engine failsafe program kicks in about once a month). Now my car won't pass a smog check because the check engine light STAYS ON.
When the car acts right, I love the power and smoothness of the ride. LA to Vegas in exactly 3 hours, cruising easy all the way. What a great drive! Car takes twisty mountain roads with ease, I've never felt like I'm at the limit.
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text:
Return to SwingLifeStyle.com The Swingers Home Page
There are a total of 8431 Jonesville swingers, within 100 miles.
The list below is a subset of the swingers in the Jonesville area.
Create a free swingers account so you can see and write to them all.
Queen unicorn... before you message please read the full profile!!
Looking for a silver-haired fox!
Hot Hot Hot!
Interested in bi curious couples and singles as well as friends.
interested in a little fun tonight, send us a birdie
Simple man with a hot woman
Cum out to play
Couple seeking like minded couple or singles
Couples For Fun
Looking for fun times
Looking for fun
We are looking for friends that like to do fun things
Making new friends....one BBQ at a time
checking out the site for options
Fun, laid back couple w/ British female looking for MF couple or single/multiple women
Looking for FWB's
Took summer off now we have to keep warm for winter :)
looking for small clean fun care to join me
mixed up couple for new adventures ;-)
Active Swingers as of 29-Sep-16.
This site does not contain sexually explicit images as defined in 18 U.S.C. 2256.
Accordingly, neither this site nor the contents contained herein are covered by the record-keeping provisions of 18 USC 2257(a)-(c).
Disclaimer: This website contains adult material. You must be over 18 to enter or 21 were applicable by law.
All Members are over 18 years of age.
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text:
The Daily Squeeze: Equality In Bras, Smoking's Side Effects, And An Online Dating Scam
A big store in England is no longer charging extra for its larger-sized bras. This is only fair because we're pretty sure well-endowed men never had to pay more for jock straps requiring loads of fabric. [Reuters]
If your boyfriend smokes and it annoys you, just tell him that continuing to puff might make him… More »


text:
Luol Deng
Basketball Player
Luol Deng is a British professional basketball player for the National Basketball Association's Chicago Bulls and the Great Britain national basketball team. He plays the small forward position. He was selected to his first All Star game during the 2011… Read More
News + Updates
Browse recent news and stories about Luol Deng.
Lakers Agree To Sign Luol Deng To Four Year, $72 Million DealLATimes - Jul 03, 2016
Ap Source: Lakers Get Luol Deng For 4 Years, $72 MillionNYTimes - Jul 02, 2016
Deng Questionable For Heat With Bruised Left WristYahoo News - May 12, 2016
Deng, Heat Overpower Hornets In OpenerReuters.com - Apr 18, 2016
Learn about the memorable moments in the evolution of Luol Deng.
1985 Birth Born on April 16, 1985.
2003 18 Years Old 1 More Event
Considered a five-star recruit by Rivals.com, Deng was listed as the No. 1 small forward and the No. 2 player in the nation in 2003.
2004 19 Years Old 2 More Events
… A member of the Chicago Bulls from 2004 until 2014, Deng was selected for his first NBA All-Star game during the 2011–12 season. … Read More
2006 21 Years Old 2 More Events
2007 22 Years Old 2 More Events
On 26 March 2007 Deng posted a new career-high 38 points to lead the Bulls to a home victory against the Portland Trail Blazers. … Read More
2011 26 Years Old 1 More Event
On 24 February 2011, Deng scored 20 points, 10 rebounds, and hit the game winning 3-point shot with 16 seconds left on the clock in a game against the Miami Heat. … Read More
2012 27 Years Old 4 More Events
Deng injured his wrist during the fourth quarter against the Charlotte Bobcats on 21 January 2012. … Read More
2013 28 Years Old 2 More Events
Deng was selected as a reserve for the 2013 NBA All-Star Game, along with Joakim Noah.
2014 29 Years Old 1 More Event
On 7 January 2014, the Chicago Bulls traded Deng to the Cleveland Cavaliers for Andrew Bynum, two future second round draft picks in 2015 and 2016 (initially traded from the Portland Trail Blazers to the Cavaliers), a protected future pick the Cavaliers received from the Sacramento Kings, and the right to swap first round picks with the Cavaliers in the 2015 draft. … Read More
Original Authors of this text are noted on http://en.wikipedia.org/wiki/Luol_Deng.
Text is made available under the Creative Commons Attribution-ShareAlike License.
Text is made available under the Creative Commons Attribution-ShareAlike License.


text:
Google Gears
For the past few months I've been using Google Reader instead of Bloglines. While this has nearly completed Google's hegemony in my life, I made the switch because with the Greasemonkey script Better Gmail I can integrate Reader right into Gmail. Now there's another reason I'm glad I made the transition. Google Gears is a new browser add-on from Google, enabling offline use of their online products. So far it only works with Reader but I'm sure that integration with Documents and Gmail isn't far behind.
What can this do for you? If you're with your laptop someplace and have a connection but won't have a connection for much longer (e.g. boarding a plane), you can download the content of your RSS feeds (and soon Documents and Gmail!) by clicking on a little green arrow (upper right corner in this screen grab).
When you're again connected, you click the arrow to sync what you've done with your online account. Nice! One could argue that a tool like this will continue to be less important as wireless connectivity becomes increasingly pervasive. This might be true, but until we're all connected 100% of the time we want to be, being able to work offline might come in handy.
Google Mashup Editor
Only available to a small number of developers at this point, Google recently released Google Mashup Editor which is like Yahoo! Pipes (mentioned here) but perhaps a bit more text heavy.


text:
You are cordially invited to attend the upcoming performance of Shanti: A Journey of Peace, a spectacular multi-media musical production that fuses western choral and orchestral music with Indian musical and dance elements.
Please join us for this opportunity to meet and greet students, staff, and faculty of color from across the GTU Consortium. Refreshments will be provided.
The event is hosted by the GTU Consortium Student Affairs Officers. For more information contact Kathleen Kook, GTU Dean of Students.
Where: Bade Museum, PSR, 1798 Scenic Avenue, Berkeley
Thursday, September 29th
"And then I killed him: Soviet Jewish Veterans of World War II Speak of Encountering Perpetrators of the Holocaust," with Anna Shternshis
12:45pm: Graduate Theological Union | Dinner Board Room, 2400 Ridge Road, Berkeley CA 94709
In the evening, Anna will be speaking at another event:
Please join friends, colleagues, and former students of the late Rev. Dr. James A. Noel, Ph.D. for an academic symposium discussing the four key issues of the African-American experience that shaped his work.
The Flora Lamson Hewlett Library's annual book sale will be held in Henry Mayo Newhall Plaza in front of the library from 10 am to 3 pm on Friday, September 30.
This year there is a remarkable selection of books for Masters of Divinity students. Hard cover books are $2.00; paperbacks, $1.00. A few books may be priced slightly higher. Arrive early for the best selection.
The GTU's Richard S. Dinner Center for Jewish Studies is hosting an event celebrating the publication of Dr. Naomi Seidman's long-awaited work, The Marriage Plot Or, How Jews Fell in Love with Love, and with Literature (Stanford University Press). Dr. Seidman will be speaking about her latest book in conversation with Stanford University's Dr.
This forum will be a place where doctoral students present their work (dissertation or special COMPS) to fellow GTU students, faculty, and staff. The presentation will be 15 minutes-long for each presenter. Asia Project board envisions having 3 presenters for the forum that day.
Tuesday, November 1st, 2016 "The Past Is a Foreign Country: Poland Confronted with Holocaust History" with Dr. Jolanta Ambrosewicz-Jacobs and Dr. Sven Erik-Rose.
5:00pm: Graduate Theological Union | Dinner Board Room, 2400 Ridge Road, Berkeley CA 94709
Phenomenology of Religious Experience is the topic of a conference in philosophy of religion that will be held on November 4-5, 2016, at the Patriarch Athenagoras Orthodox Institute in Berkeley (a GTU Affiliate). The conference is divided into two main sections: theologies and philosophies of religious experience, and the descriptive psychology and phenomenological method, with examples and case studies (in people and texts).
Graduate Theological Union
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Admissions +1.800.826.4488
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text:
Women's Prois® Competitor Sleeveless Shooting Shirt
Item # WX2-198445SOLD OUT
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- Details & Specs
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Women's Prois® Competitor Sleeveless Shooting Shirt... high - performance for the high - powered huntress!
Prois® is a serious hunt company all about where the boys aren't ... it's the hottest clothing specifically for gals who heat up gun barrels and bow strings! Their Competitor Line is the peak of real bottom-line function that happens to look terrific, too.
This Shooting Shirt is durable 100% polyester wicking fabric with stretch and attractive tapered athletic cut for ease of movement. It has quilted shoulder patches, left and right, for the gunner. It's sleeveless, with ventilation, for the most hot and humid days at the range. Point collar. Machine wash / dry. Imported.
State Size and Color, as available in the Shopping Cart. Great looks, dead-on performance... choose yours ONLINE today!


text: Labatt Brewing Company Ltd. (French: Brasseries Labatt du Canada Ltée) is a Canadian beer company founded by John Kinder Labatt in 1847 in London, Ontario. In 1995, it was purchased by Belgian brewer Interbrew; it is now part of Anheuser-Busch InBev. Labatt is the largest brewer in Canada. In the United States, Labatt brand beers are sold under license by Labatt USA, which since 2009 has been fully independent of the Canadian firm and a subsidiary of the privately-held North American Breweries of Rochester, New York.


text:
Carbon Tariffs: Effects in Settings with Technology Choice and Foreign Production Cost Advantage
David Drake
Harvard Business School - Technology & Operations Management
November 17, 2015
Harvard Business School Technology & Operations Mgt. Unit Working Paper No. 13-021
It is widely believed that carbon leakage — offshoring and foreign entry in response to carbon regulation — increases global emissions. It is also widely believed that a carbon tariff — imposing carbon costs on imports entering the emission-regulated region — would eliminate carbon leakage. However, neither of these assertions necessarily holds. Under a carbon tariff, foreign firms with a production cost advantage adopt clean technology at a lower emissions price than domestic firms, and foreign entry can increase in emissions price when foreign firms hold this edge. Further, domestic firms conditionally offshore production despite a carbon tariff, but doing so implies that they adopt cleaner technology. Therefore, carbon leakage can arise under a carbon tariff but, under mild conditions, it decreases global emissions. Due in part to this clean leakage, imposing a carbon tariff is shown to decrease global emissions. However, domestic firm profits can increase, decrease, or remain unchanged due to a carbon tariff. This suggests a carbon tariff's principal benefit is not to protect domestic firm profits, as some argue. Rather, it is to improve emissions regulation efficacy, enabling emissions price to be used to reduce global emissions in many settings in which it would otherwise fail to do so.
Number of Pages in PDF File: 33
Keywords: Carbon regulation, Carbon leakage, Technology choice, Imperfect competition
Date posted: October 19, 2011 ; Last revised: November 18, 2015
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