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Home Policy Priorities Fund Regulation Disclosure
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- ICI Comment Letters
May 20, 2004
Mr. Jonathan G. Katz
U.S. Securities and Exchange Commission
450 Fifth Street, NW
Washington, D.C. 20549-0609
Re: Disclosure Regarding Portfolio Managers of Registered Management Investment Companies (File No. S7-12-04)
Dear Mr. Katz:
The Investment Company Institute1 appreciates the opportunity to comment on the Securities and Exchange Commission's proposal to require registered management investment companies to provide enhanced disclosure of information regarding their portfolio managers.2 The Commission's proposal would require a fund to disclose information relating to: (1) the members of a portfolio management team; (2) other accounts managed by the fund's portfolio manager; (3) the portfolio manager's ownership of securities in the fund and in such other accounts; and (4) the portfolio manager's compensation structure. The Commission's proposal is intended to provide greater transparency regarding portfolio managers, their incentives in managing a fund, and potential conflicts of interest that may arise when they or the advisers that employ them also manage other investment vehicles.
The Institute generally supports the Commission's objectives. We are concerned, however, that certain of the proposed disclosure requirements would not effectively accomplish their intended goals, inasmuch as they would result in overly voluminous disclosure that might not be very meaningful to shareholders and/or disclosure that could adversely affect portfolio managers' legitimate privacy interests. Our recommendations are intended to address these concerns, while still achieving the Commission's objectives.
In summary, our comments are as follows:
- The Institute supports the Commission's proposal to require prospectus disclosure about portfolio management team members, but notes that the proposed disclosure requirements would not work for larger management teams. Accordingly, we recommend that the Commission modify the proposal to permit funds with portfolio management teams that consist of more than five members to identify the five individuals with the most assets under management; provided, however, that disclosure should only be required of those individuals that manage at least ten percent of the fund's assets.
- The Institute supports the proposal to require funds to provide disclosure in their statements of additional information ("SAIs") regarding conflicts of interest related to the portfolio manager's dual management of the fund's investments and those of other accounts, but recommends that the Commission modify the proposal to require funds to disclose only the material conflicts that exist given the type of fund(s) and account(s) at issue.
- The Institute opposes the requirement to provide SAI disclosure of policies and procedures that address conflict of interest issues, and recommends instead that the Commission require disclosure stating that the fund and/or its adviser have policies and procedures in place designed to address the conflicts of interest identified, and that such policies and procedures have been approved and are periodically reviewed by the fund's board of directors.
- The Institute supports the proposal to require SAI disclosure of the structure and methodology of the portfolio manager's compensation, but recommends that the Commission modify the proposed definition of the term "compensation" in certain respects.
- The Institute supports the proposal to require SAI disclosure of securities that the fund's portfolio manager owns, but recommends limiting the disclosure to securities in the fund that is making the disclosure. At the very least, the proposal should be modified to require disclosure of securities owned in (a) the fund and (b) the fund and other funds and accounts that are managed by the fund's portfolio manager, in the aggregate.
- The Institute supports the proposal to require disclosure of securities ownership within prescribed dollar ranges, but recommends that the maximum dollar range be "over $100,000" instead of "over $1,000,000" as proposed.
- The Institute opposes the Commission's proposal to subject index funds to the proposed disclosure requirements by removing the exclusion currently available to index funds that have as their objective to replicate the performance of an index.
Our comments are discussed in greater detail below.
Table of Contents
A. Identification of Portfolio Management Team Members
B. Disclosure Regarding Other Accounts Managed, Potential Conflicts of Interest, and Policies and Procedures to Address Conflicts
2. Categories of Other Accounts Managed
C. Disclosure of Portfolio Manager Compensation Structure
D. Disclosure of Securities Ownership of Portfolio Managers
1. Securities Owned in Other Funds and Accounts
E. Removal of Exclusion for Index Funds
A. Identification of Portfolio Management Team Members
The Commission's proposal would require funds to identify in their prospectuses each member of a committee, team, or other group of persons associated with the fund's investment adviser that is jointly and primarily responsible for the day-to-day management of the fund's portfolio.3 Currently, a fund that engages a committee, team, or other group to manage the fund's portfolio is only required to disclose that the fund's investments are managed by a group; it need not disclose the names of the members of the group.4 The Commission's proposal would require funds to provide detailed information on each member of the portfolio management team, including the member's name, title, length of service, business experience, and role on the team.
The Institute supports the Commission's proposal to require more information about a portfolio management team than is currently required. We are concerned, however, that the disclosure requirements proposed by the Commission would not work for all management teams. In particular, while the proposed requirements may be appropriate for teams that consist of a relatively small number of members (e.g., five or fewer individuals), when applied to larger management teams, the disclosure could become unwieldy and less meaningful to shareholders.5 Indeed, so-called "research-driven funds," for example, may have portfolio management teams with as many as 60 individuals, each of which has responsibility for managing a specified portion of the portfolio. If these funds were required to identify and provide specific information on each and every team member of their management team, their prospectuses would be filled with page after page of information that would not be useful to investors, mainly because each individual team member typically would have responsibility for only a very small percentage of the fund's assets, thus making their individual identities and other individual information substantially less material to investors. This lengthy disclosure might distract investors' attention from more important information in the prospectus.
For these reasons, the Institute recommends that the Commission modify its proposal to permit funds with portfolio management teams that consist of more than five members to identify the five individuals with the most assets under management; provided, however, that disclosure should only be required of those individuals that manage at least ten percent of the fund's assets.6 We believe this recommendation would enable most funds that utilize a large portfolio management team to achieve the Commission's goal of providing investors with enhanced information regarding the portfolio management team, without inundating them with extensive disclosure that may not be particularly relevant or meaningful.
B. Disclosure Regarding Other Accounts Managed, Potential Conflicts of Interest, and Policies and Procedures to Address Conflicts
The Commission's proposal would require a fund to disclose in its SAI any other account for which the fund's portfolio manager is primarily responsible for the day-to-day portfolio management. 7 The proposal would also require the fund to describe any conflicts of interest that may arise in connection with the portfolio manager's management of the fund's investments, on the one hand, and of the investments of the other accounts, on the other. Moreover, the fund would be required to include a description of the policies and procedures used by the fund or the fund's adviser to address any such conflicts. Our comments on these proposed requirements are discussed below.
1. Conflicts of Interest
The Institute supports the Commission's goal of providing investors with information that alerts them to the types of conflicts that can arise when a portfolio manager simultaneously manages a mutual fund and other accounts. We have concerns, however, regarding the nature and extent of the proposed disclosure. First, we are concerned that the requirement to disclose "any conflicts of interest that may arise"8 is overly broad and open-ended. As a practical matter, it is impossible to identify with certainty every possible conflict. Firms may decide to err on the side of caution and provide a laundry list of all conflicts that could occur, however remote the possibility of their occurrence. Such an overly comprehensive list would not be helpful to investors. To alleviate this concern, we recommend that the Commission modify the proposal to require funds to disclose only material conflicts of interest that exist given the type of fund(s) and account(s) at issue. Requiring disclosure of material conflicts that typically exist (such as in the areas of trade allocations, short sales, etc.) would more appropriately tailor the requirement to elicit more relevant and meaningful information.
Second, we are concerned that requiring SAI disclosure of the fund's or the fund adviser's policies and procedures that address the conflicts of interest described would in many cases result in excessive disclosure.9 In our view, most fund investors would not find the details of how the policies and procedures specifically address such conflicts particularly useful.10 Moreover, the length and complexity of this disclosure would likely increase as firms develop and/or revise their policies and procedures pursuant to the Commission's recently adopted compliance program rules.11
To alleviate these concerns, we recommend that the Commission eliminate the proposed requirement to provide SAI disclosure of the fund's and the fund adviser's policies and procedures. Instead, we recommend that the Commission require the SAI to disclose that the fund and/or its adviser have policies and procedures in place designed to address the conflicts of interest identified, and that such policies and procedures have been approved and are periodically reviewed by the fund's board of directors.12 This recommendation would address our concerns related to excessive and unnecessary disclosure, while achieving the Commission's objective of informing investors as to the nature of the conflicts of interest that exist, and ensuring them that such conflicts have been addressed by appropriate policies and procedures that have been approved by the fund's board of directors.13
2. Categories of Other Accounts Managed
The Commission's proposal would require a fund to disclose both the number of other accounts managed by the portfolio manager and the total assets in such accounts within each of the following four categories: (i) registered investment companies; (ii) other investment companies; (iii) other pooled investment vehicles; and (iv) other accounts. For each such category, the fund would also be required to disclose the number of accounts and the total assets in the accounts with respect to which the advisory fee is based on account performance.14
The Institute supports the Commission's proposal to categorize the other accounts managed by a fund's portfolio manager, but we recommend that two of the proposed categories – "other investment companies" and "other pooled investment vehicles" – be combined, as they appear to overlap. For example, it seems that a private equity fund could be placed in either category. The Proposing Release does not explain how these two categories are meant to be defined or why breaking them out separately would be helpful in achieving the Commission's objective of enabling investors to assess the conflicts of interest to which a portfolio manager may be subject as a result of managing a fund and other portfolios.15 Accordingly, we recommend that the Commission combine the "other investment companies" and "other pooled investment vehicles" categories into one category, called "other pooled investment vehicles."
The Institute also recommends that the Commission clarify that the scope of the "other account" category includes only other accounts managed on behalf of the adviser that employs the portfolio manager. This clarification is necessary to avoid potential interpretive issues that could arise in situations such as when a fund's portfolio manager is managing an account in a personal capacity, e.g., a family trust. We do not believe that the Commission intended for the proposal to be applied this broadly.
C. Disclosure of Portfolio Manager Compensation Structure
The Commission's proposal would require a fund to disclose in its SAI the structure of, and the method used to determine, the compensation received by its portfolio manager from the fund, its investment adviser, or any other source with respect to management of the fund and any other account included by the fund in response to the disclosure requirement discussed above.16 The description would also have to clearly disclose any differences between the method used to determine the portfolio manager's compensation with respect to the fund and the methods used with respect to the other accounts. The purposes of the Commission's proposal are to help investors better understand a portfolio manager's incentives in running a fund and to shed light on possible conflicts of interest that could arise when the portfolio manager manages other accounts.17
The Institute supports the Commission's proposal. We particularly agree with the Commission's assessment that it is unnecessary to disclose the value of compensation paid to a portfolio manager.18 In addition, with respect to the scope of the proposed disclosure, we agree that salary, bonuses, deferred compensation, and certain retirement plan benefits would constitute the most significant aspects of a portfolio manager's compensation in order to help investors better understand the portfolio manager's incentives in running the fund, and therefore are appropriately included within the definition of "compensation" for this purpose.19 We recommend modifications to the proposed definition, however, as it appears to be overly vague and broad in certain respects.
For example, it is unclear what the Commission intended to capture through the use of the phrase "without limitation" and by including "non-cash" compensation. Would the definition encompass healthcare and life insurance benefits or free parking? We do not believe that it should, because including these types of benefits would result in disclosure that would not achieve the Commission's purposes. On a related point, in order for the information to be useful to investors, the term "compensation" should have clearly defined parameters. This would promote consistent application and facilitate compliance with the proposed reporting requirements. For these reasons, we recommend that the Commission delete the phrases "without limitation" and "whether the compensation is cash or non-cash" from the definition.
In addition, certain benefits that are expressly included in the proposed definition – namely, qualified retirement plans and arrangements that meet certain IRS requirements and that are generally available to company employees – should not be covered because they are either fixed in amount, subject to a pre-set limit, or both. While a portfolio manager may receive such benefits as part of his or her compensation package, disclosing them would not assist investors in assessing whether the manager's interests are aligned with those of the fund's shareholders.
D. Disclosure of Securities Ownership of Portfolio Managers
The Commission's proposal would require a fund to disclose in its SAI the ownership of securities of each of its portfolio managers in the fund and in other accounts, including investment companies, managed by the fund's investment adviser or the portfolio manager.20 The Institute's comments on this proposal are discussed below.
Before providing our specific comments on the proposal, however, we would like to discuss our concern with the implications of the explanation in the Proposing Release that disclosing the shares owned by a fund's portfolio manager in the fund and in other accounts could help investors, among other things, assess the level of confidence that the manager has in the fund's investment strategy.21 While the level of ownership arguably may be an indicator of the portfolio manager's confidence in the fund's investment strategy where the manager owns shares in the fund, it does not necessarily follow that a portfolio manager with little or no securities ownership has any less confidence or is any less concerned about the fund's performance than is a manager who has a large stake in the fund that he or she manages. There are a number of personal and professional reasons why a portfolio manager may decide not to invest in a fund he or she is managing. For example, the fund's objectives may be inconsistent with the manager's personal investment goals.22 In order to avoid creating any undue negative inference, we urge the Commission to make clear in the adopting release that the level of the portfolio manager's investment in the fund is not necessarily indicative of the level of confidence the manager has in that fund's investment objective or strategies.
1. Securities Owned in Other Funds and Accounts
The Commission's proposal would require a fund to disclose in tabular format the ownership of securities of each of its portfolio managers in the fund and in other accounts, including investment companies, managed by the fund's investment adviser or the portfolio manager. 23 The proposal would require the fund to disclose the manager's securities ownership using the following dollar ranges: none; $1.00 - $10,000; $10,001-$50,000; $50,001-$100,000; $100,001-$500,000; $500,001-$1,000,000; or over $1,000,000. We have several comments on this proposal.
First, the scope of the proposal is overly broad. As drafted, the proposal would require the disclosure of a fund portfolio manager's ownership of securities not only in the fund being managed, but also in other accounts across the entire fund complex, including accounts over which the manager has no primary responsibility or control. The Proposing Release explains that this disclosure could help investors assess the extent to which the manager's interests are aligned with theirs and potential conflicts of interest between investors' interests and the interests of other clients or investment vehicles in which the manager has an interest. We fail to see, however, how this disclosure would achieve those goals. What conclusion should an investor draw from the fact that the fund's portfolio manager owns securities in other accounts in the complex, particularly those that he or she does not manage?24 With respect to ownership of securities in accounts other than the fund managed by the portfolio manager, we submit that the other proposed disclosures concerning conflicts of interest (in particular, disclosure concerning compensation structure) would address the same purpose in a more direct and effective manner.
Second, the proposal is not adequately sensitive to portfolio managers' legitimate privacy interests. Requiring a fund to disclose its portfolio manager's holdings across the fund complex may raise privacy concerns in that it may provide too much insight into the manager's personal net worth, especially when coupled with the requirement to provide such information using a maximum dollar range of over $1 million. This disclosure would, in effect, require portfolio managers to disclose whether they are high net worth individuals.25 This invasion of privacy could have the unintended effect of encouraging portfolio managers to move their investments to other fund companies in order to preserve their privacy. Such a move could adversely impact the firm's relationship with its portfolio managers, particularly if the firm promotes employee investment in the firm. Even worse, it could discourage talented investment professionals from serving as portfolio managers to mutual funds.
We recommend two changes to the proposal to address these concerns. First, we recommend that the proposal be modified to require a fund to disclose only the dollar range of securities owned in the fund by the fund's portfolio manager and his or her immediate family. At the very least, the proposal should be modified to require disclosure of securities owned in (a) the fund and (b) the fund and other funds and accounts that are managed by the fund's portfolio manager, in the aggregate.26 This approach would be similar to the approach used for fund directors.27
Second, we recommend that the Commission reduce the maximum dollar range of securities owned to "over $100,000." We note that such a range would be consistent with the requirement for fund directors.28 We believe that a maximum threshold level of over $100,000 would provide an appropriate balance between two important competing interests – (1) providing information that would allow fund shareholders to assess the extent to which the portfolio manager's interests are aligned with theirs, and (2) avoiding undue invasion of portfolio managers' privacy.
2. Beneficial Ownership
The proposed securities ownership provision would apply to securities owned beneficially or of record. Specifically, the proposal would deem a person to be a "beneficial owner" of a security if the person is a "beneficial owner" under either Rule 13d-3 under the Securities Exchange Act of 1934, which focuses on a person's voting and investment power, or Rule 16a-1(a)(2) under the Exchange Act, which focuses on a person's economic interests in a security. The Commission has requested comment on whether the definition of beneficial ownership should be based on these two rules or limited to just one of them, and whether disclosure of record ownership should be required.
The Institute recommends using the Rule 16a-1(a)(2) definition to determine beneficial ownership and not requiring disclosure of record ownership. We note that the Commission took this approach when it adopted requirements for disclosure of directors' ownership of fund securities.29 In deciding to require use of the Rule 16a-1(a)(2) definition in that context, the Commission stated: "In light of our objective of providing information about the alignment of directors' and shareholders' interests, we believe that disclosure of record holdings should not be required and that the focus of 'beneficial ownership' should be on whether a director's economic interests are tied to the securities, rather than his ability to exert voting power or to dispose of the securities."30 We submit that the objective of the portfolio manager ownership disclosure requirement is very similar and, accordingly, it would be appropriate to use the same definition to determine "beneficial ownership" for that purpose and not to require disclosure of record ownership.
3. Calendar Year Reporting
The Commission's proposal would require funds to provide information about a portfolio manager's ownership of securities, as well as the information regarding other accounts managed and compensation structure, as of the end of the fund's most recently completed fiscal year.31 The Institute recommends modifying this proposal to permit funds to provide this information as of the most recently completed calendar year. It is not uncommon for fund complexes to have more than one of their funds and/or other accounts managed by the same portfolio manager. Imposing a fiscal year reporting requirement could cause such complexes to have to calculate and provide information on the portfolio manager based on different time periods, depending on each fund's fiscal year end. Permitting funds to make the calculation as of the end of the most recent calendar year would facilitate a more efficient process and provide greater consistency in reporting among those funds that have the same portfolio manager.32
E. Removal of Exclusion for Index Funds
The Proposing Release notes that the Commission intends to extend its proposed disclosure requirements to portfolio managers of index funds, which currently are excluded from portfolio manager disclosure. Specifically, the Commission proposes to remove the current provision in Form N-1A that excludes a fund that has as its investment objective replication of the performance of an index from the requirement to identify and provide disclosure regarding its portfolio manager. We disagree with this proposal and urge the Commission to maintain its longstanding exclusion for portfolio managers of index funds. As the Proposing Release explains, index funds were originally excluded from the disclosure requirement because their portfolio management is largely mechanical.33 We note that this is still largely the case today.34
The Proposing Release explains that the Commission's decision to remove the exclusion for index funds is based in large part on concerns that conflicts may arise when a manager is managing both an index fund and an actively-managed fund that invest in some of the same securities.35 In our view, however, subjecting the index fund to the disclosure requirement in that situation would serve little purpose inasmuch as there would be little or no conflict between the interests of the shareholders of the index fund and that of the portfolio manager where the fund's objective is to replicate the performance of an index. This is because the performance of an index fund is periodically measured and tracked against an identifiable industry benchmark, which is clearly disclosed in the fund's prospectus. As such, the index fund structure imposes strict constraints on the portfolio manager's actions.36 For these reasons, we urge the Commission to maintain the present exclusion for index funds that have as their objective to replicate the performance of an index.
F. Compliance Date
The Proposing Release notes that once the proposal is adopted, the Commission expects to require all new registration statements and annual reports on Form N-CSR, and all post-effective amendments that are annual updates to effective registration statements, filed on or after the effective date to comply with the new disclosure requirements. We note that funds will need time to collect this broad range of information and ensure an adequate level of review of this new disclosure. To provide a sufficient transition period, the Institute recommends that the Commission provide a compliance date that is at least 12 months after adoption of the final rules. If the Commission does not narrow the required disclosures as we recommend above, however, a longer transition period may be necessary.
The Institute appreciates the opportunity to comment on the Commission's proposal. If you have any questions concerning these comments or would like additional information, please contact me at (202) 326-5824, Frances M. Stadler at (202) 326-5822, or Barry E. Simmons at (202) 326-5923.
Amy B. R. Lancellotta
Acting General Counsel
cc: The Honorable William H. Donaldson
The Honorable Cynthia A. Glassman
The Honorable Harvey J. Goldschmid
The Honorable Paul S. Atkins
The Honorable Roel C. Campos
Paul R. Roye, Director
Paul G. Cellupica, Assistant Director
Sanjay Lamba, Attorney
Division of Investment Management
1 The Investment Company Institute is the national association of the American investment company industry. Its membership includes 8,632 open-end investment companies ("mutual funds"), 621 closed-end investment companies, 126 exchange-traded funds and 5 sponsors of unit investment trusts. Its mutual fund members manage assets of about $7.545 trillion. These assets account for more than 95% of assets of all U.S. mutual funds. Individual owners represented by ICI member firms number 86.6 million as of mid 2003, representing 50.6 million households.
2 See SEC Release Nos. 33-8396; 34-49398; IC-26383 (March 11, 2004); 69 Fed. Reg. 12752 (March 17, 2004) (the "Proposing Release").
3 We presume that the Commission's proposal would not change the current standard whereby a fund with a single portfolio manager with supporting staff identifies and provides disclosure regarding the portfolio manager only.
4 See, e.g., Form N-1A, Instructions to Item 6(a)(2).
5 We note that this concern is amplified by the fact that, under the proposal, the full panoply of proposed SAI disclosures discussed in this letter would be required with respect to each member of a team, including disclosures relating to other accounts managed, compensation structure, and securities ownership. See, e.g., Proposed Items 5(a)(2) and 15 of Form N-1A.
6 In unusual cases, such as research-driven funds, it is likely that no individual will meet the proposed ten percent threshold. We recommend that those funds could provide the disclosure currently permitted for funds with portfolio management teams. See, e.g., Instructions to Item 6(a)(2) of Form N-1A.
7 Proposed Items 15(a) of Form N-1A and 21.1 of Form N-2.
8 Proposed Items 15(a)(4) of Form N-1A and 21.1(d) of Form N-2 (emphasis added).
9 We note, for example, that it is not uncommon for a large fund complex to have detailed and complex trade allocation policies and procedures that exceed 10 pages. Inserting these policies and procedures alone into a fund's SAI would greatly increase the size of the document; obviously, including descriptions of policies and procedures designed to address all conflicts of interest (or even all material conflicts, per our suggestion above) would have a far greater impact. The problem would be significantly worse in the case of funds with multiple advisers, such as so-called "manager of managers" funds, inasmuch as the Commission's proposal would require SAI disclosure for each portfolio manager identified by the fund.
10 While some firms may decide instead to summarize their policies and procedures, many may decide not to do so because of potential liability and concerns about being second-guessed if certain items are not included in the summary. We also have concerns regarding possible inconsistent summary descriptions among funds that choose this option.
11 See SEC Release Nos. IA-2204; IC-26299 (December 17, 2003); 68 Fed. Reg. 74714 (December 24, 2003). The adopting release for these rules notes that an adviser's compliance policies and procedures would be expected to include policies and procedures related to trading practices and allocation of investment opportunities among clients. Id. at 74716.
12 The fund compliance program rule requires fund boards of directors to approve and periodically review the fund's and the fund adviser's policies and procedures. The rule also requires the fund to appoint a chief compliance officer who, among other things, will annually furnish to the fund's board a written report on the operation of those policies and procedures. See Rule 38a-1 under the Investment Company Act of 1940.
13 In the Proposing Release, the Commission requested comment on whether the proposed conflicts of interest disclosure requirement is sufficient or whether the Commission should prohibit portfolio managers of registered funds from managing certain types of accounts. Proposing Release at 12755. The Institute would oppose any such prohibition. In our view, prohibiting a portfolio manager from simultaneously managing registered and non-registered investment products would have a detrimental impact on investors, as it would reduce their access to the expertise of certain portfolio managers. It would have a particularly disruptive and anti-competitive effect on smaller investment management firms that have fewer employees and may not have the resources to maintain separate staff for different types of accounts. We believe that the disclosure approach proposed by the Commission, combined with requirements under the compliance program rules, provide a sufficient and preferable way to address concerns about conflicts arising from a portfolio manager's management of different types of accounts.
14 See Proposed Items 15(a)(3) of Form N-1A and 21.1.c of Form N-2.
15 See Proposing Release at 12754.
16Proposed Items 15(b) of Form N-1A and 21.2 of Form N-2.
17Proposing Release at 12755.
18 As the Proposing Release points out, the suggestion that portfolio manager compensation should be disclosed, just as executive compensation is for operating companies, ignores the fact that the closest analogue to executive compensation in the fund context is the advisory fee paid by the fund to the investment adviser. The advisory fee already is fully disclosed, including as part of the fee table in the fund's prospectus. See Proposing Release at 12755. We also point out that disclosing the value of portfolio manager compensation would raise privacy issues and consequently would act as a disincentive for talented portfolio managers to manage mutual funds, as opposed to other accounts (such as private accounts or hedge funds) that are not subject to such a requirement.
19 The Commission's proposal would define "compensation" to include, "without limitation, salary, bonus, deferred compensation, and pension and retirement plans and arrangements, whether the compensation is cash or non-cash." See Proposed Instructions to Item 15(b) of Form N-1A and Item 21.1 of Form N-2. The proposal would also require funds to describe the criteria on which each type of compensation is based (e.g., whether the compensation is fixed, based on fund pre-or after-tax performance over a certain period of time, and whether the compensation is based on the value of assets held in the fund's portfolio).
20 Proposed Items 15(c) of Form N-1A and 21.3 of Form N-2. The proposed disclosure requirement would apply to securities owned beneficially or of record in: (i) the fund; (ii) other accounts that the fund included in response to the proposed disclosure requirements regarding other accounts managed by the portfolio manager; and (iii) any other account, including an investment company, managed by an investment adviser of the fund, or by any person directly or indirectly controlling, controlled by, or under common control with an investment adviser or principal underwriter of the fund.
21 Proposing Release at 12755 (emphasis added).
22 In addition, in response to recent events, many fund groups have adopted or are considering imposing restrictions, such as holding periods, that would apply to investments by portfolio managers in funds they manage. While such restrictions serve a worthwhile purpose, they may act as a disincentive for portfolio managers to invest substantial amounts in funds they manage.
23 Specifically, the fund would disclose in a tabular format: (1) the name of the portfolio manager; (2) the investment company or account in which the portfolio manager or immediate family member owns securities; (3) the title of the class of securities owned; and (4) the dollar range of securities owned in the fund or account. See Proposed Items 15(c) of Form N-1A and 12.3 of Form N-2. For purposes of this disclosure, "immediate family member" would mean a person's spouse, a child residing in the person's household (including step and adoptive children), and any dependent of the person, as defined in Section 152 of the Internal Revenue Code.
24 The scope of the Commission's proposal would be even broader when applied to manager of managers funds. In such a case, the proposal would seem to require the fund to disclose the securities owned by a portfolio manager employed by a subadviser (or his or her immediate family members) in funds or accounts managed by any other subadviser to the fund, or by any entity that controls, is controlled by or is under common control with any other subadviser to the fund. For example, it appears that a fund would have to include shares owned by a portfolio manager's spouse through his or her 401(k) plan in a mutual fund managed by another investment advisory firm that happens to be a subadviser to the fund making the disclosures. Including this information within the scope of the required disclosure clearly would not serve the purposes intended by the Commission, and we do not think this result was intended.
25 In this regard, we note that the Commission requested comment on whether the proposal should require a fund to disclose the percentage of a portfolio manager's net worth, including the net worth of immediate family members, that is invested in securities of the fund or other accounts. For the reasons stated in this section, we do not believe it would be necessary or appropriate to require a fund to disclose the percentage of a portfolio manager's net worth that is invested in securities of the fund or other accounts.
26 As recommended in Section B.2 above, the other accounts should be limited to those managed by the portfolio manager on behalf of the adviser that employs the portfolio manager.
27 See, e.g., Item 12(b)(4) of Form N-1A.
28 See id. While the Proposing Release recognizes that the proposed requirement is similar to that required for fund directors' ownership in equity securities, it suggests that the proposed higher ceiling of over $1 million (as opposed to over $100,000 for fund directors) is needed to differentiate between an investment of $100,001 and an investment of $5 million, which would both be stated as over $100,000 if that threshold were used. See Proposing Release at 12756. Nevertheless, we do not believe that this desire for greater precision outweighs the privacy concerns noted above – which apply to portfolio managers as well as directors. For these reasons, we urge the Commission to adopt the $100,000 threshold.
29 See SEC Release Nos. 33-7932; 34-43786; IC-24816 (January 2, 2001); 66 Fed. Reg. 3734 (January 16, 2001) ("Fund Director Rules").
30 Id. at 3741. The Commission further stated that the Rule 16a-1(a)(2) definition, consistent with this goal, "emphasizes the economic incidence of ownership." Id.
31 The Proposing Release notes, however, that in the case of an initial registration statement or an update to a fund's registration statement that discloses a new portfolio manager, information with respect to any newly identified portfolio manager would be required to be provided as of the most recent practicable date.
32 We note that the Commission adopted a calendar year timeframe for reporting the dollar range of equity securities directors own in a fund complex. See Fund Director Rules, supra note 29.
33 See Proposing Release at 12757.
34 We recognize that index funds have evolved over the years to include "index plus" type funds, which have as their objective out-performing a specified fund index. Our comments focus, however, on the "plain-vanilla" index funds that have as their investment objective replication of the performance of an index. These funds, which typically do not have active managers who buy and sell securities based on research and analysis in an attempt to outperform a particular benchmark or the market as a whole, generally accomplish their objective by holding all, or a representative sample, of the securities that constitute the index in an attempt to mirror what the target index does.
35 Proposing Release at 12757.
36In this regard, we note that index funds are much like money market funds inasmuch as money market funds are also structured to impose strict constraints on the portfolio manager's actions. Indeed, it was on this basis that the Commission excluded money market funds from the disclosure requirement. See SEC Release No. IC-19382 (April 6, 1993) (excluding money market funds from the requirement to identify and provide portfolio manager disclosure because they must meet the risk-limiting conditions in Rule 2a-7 under the Investment Company Act, which constrains the role of the portfolio manager). The Proposing Release solicits comment on whether the Commission should subject money market funds to the proposed disclosure requirements. We believe that the current exclusion should be maintained inasmuch as the Commission's original justification for excluding money market funds still applies today.
Copyright © 2017 by the Investment Company Institute


text: KINGSTON - New Zealand displayed discipline and caution over the first two hours of the first Test against the West Indies to reach 62 for one at the lunch interval after choosing to bat first at Sabina Park in Jamaica on Sunday. Opening batsman Tom Latham (37 not out) and Kane Williamson (17 not out) survived a determined examination from the bowlers after fast bowler Jerome Taylor marked his return to international cricket following a four-and-a-half year absence by having Peter Fulton caught at the wicket for one. Taylor and fellow paceman Kemar Roach then gave way to the specialist slow bowlers with the combination of Sulieman Benn, Shane Shillingford and Marlon Samuels accounting for 18 of the 32 overs bowled in the session. But the vigil of the New Zealanders, and particularly Latham, was not without incident. Wicketkeeper Denesh Ramdin, leading the West Indies for the first time, requested a referral of an lbw appeal in Samuels' first over, the "not out" verdict being upheld by television umpire Ian Gould. The TV official was called upon shortly after to examine the replays one more time when Latham challenged the verdict by on-field umpire Richard Illingworth to rule him caught at short-leg by Kieran Powell off Benn a few overs later. To the disappointment of the West Indies players and Latham's relief, the decision was overturned.Fans at Sabina Park were in celebratory mood at the start of the day with local hero Chris Gayle being honoured for becoming just the ninth West Indian, and second Jamaican after former fast bowler Courtney Walsh, to play 100 Test matches. While the hard-hitting opening batsman is less than 100 percent fit as he continues to receive treatment for a bulging disc in his spine, his determination to play in front of his adoring home fans won out in the selectors' final consideration over his fitness.Acutely aware of a pitch expected to offer considerable assistance to the slow bowlers, both teams opted for two specialist spinners with New Zealand giving a debut to 27-year-old off-spinner Mark Craig alongside leggie Ish Sodhi, who is appearing in only his seventh Test.ScoreboardNEW ZEALAND 1ST INNINGS:T Latham not out 37P Fulton c Ramdin b Taylor 1K Williamson not out 17EXTRAS: (b3, lb4) 7TOTAL: (one wicket, 32 overs) 62FOW: 1-9 BOWLING: Taylor 6-2-9-1, Roach 7-3-9-0, Bravo 1-0-2-0, Benn 11-5-17-0, Samuels 4-1-10-0, Shillingford 3-0-8-0.TOSS: New ZealandUMPIRES: Richard Illingworth (ENG) and Rod Tucker (AUS)TV UMPIRE: Ian Gould (ENG)MATCH REFEREE: Chris Broad (ENG)

subset: commoncrawl


text:
A national security agency has used federal powers to block Australian access to websites, in the latest development surrounding revived fears of internet censorship.
Bureaucrats at the Department of Broadband, Communications and the Digital Economy, and the Attorney-General's Department separately confirmed at Senate estimates hearings that a total of three departments had requested internet service providers like Telstra and Optus to block specific websites from access within Australia.
The requests, known as section 313 notices, come under 15-year-old legal powers that require telecommunications carriers to cooperate with law enforcement in stopping unlawful use of their services. However, until recently the powers were not believed to have been widely used for the purpose of blocking websites.
DBCDE deputy secretary Abdul Rizvi said on Thursday that a total of three federal agencies were found to have used the powers to block website access, after a meeting was held on May 22 between 12 federal agencies to determine the scope of the issue.
Attorney-General's Department secretary Roger Wilkins later clarified that the third agency was a "national security matter" but refused to name it.
Extent of blocking investigated
Mr Rizvi acknowledged that the Australian Security Intelligence Organisation had attended a meeting of 12 government agencies late this month to ascertain the extent of system's use.
Investigation into the extent of their use came after the Australian Securities and Investment Commission inadvertently blocked access to more than 1200 websites over some networks, as it attempted to take down two sites it believed were behind a fraud campaign.
The incident sparked fears the federal government was pursuing an internet censorship regime, despite Labor dumping its previous proposal for a mandatory internet filter.
The Australian Federal Police is also known to have the powers to block access to child pornography websites targeted by Interpol, as well as other material related to terrorism material.
The bureaucrats conceded they were unsure exactly how much agencies were using the notices, and whether state government departments were also requesting website blocks. Communications Minister Stephen Conroy admitted he had been unaware that ASIC was using the notices.
'I'm very open'
"ASIC are an independent statutory authority, they're effectively our corporate policeman," he said. "I wouldn't expect them to need to come and tell me that there are criminals and fraudsters, and seek my permission to get compliance with the law."
Mr Conroy said he was pushing for greater transparency on the matter, including the possibility of setting up a website that alerts users when they visit blocked content.
"I've sought advice form my department, I'm very open to the same sorts of things that we've debated previously," he said.
ASIC chairman Greg Medcraft told a stockbrokers conference on Thursday that the agency was reviewing the way it used the powers to block website access but said that he did not apologise for using the powers to block criminal fraud sites.
"Cyber crime is something ASIC takes very, very seriously and we will keep fighting against these fraud sites," Mr Medcraft said.
with AAP
The Australian Financial Review


text:
Telecompaper is reporting that Germany may have dropped its universal service plan, which sought to add a universal broadband service to the German telecom law change has been dropped. The plan had received a lot of criticism from network operators. German federal broadband operators association Breko welcomes the decision to drop the universal broadband service proposal and claims that a lot of regional network operators, who would not have survived the introduction of such service, will justify the trust they received.
Read the hfull article at http://www.telecompaper.com/news/german-universal-broadband-service-plan-is-dropped
© Copyright 2017, International Telecommunication Union
The information presented within this blog comes from various organizations around the world. ITU encourages users to seek more detailed information from the original source through the links provided.
Links to third-party websites are provided for the convenience of all users. The ITU is not responsible for the accuracy, currency or the reliability of the content on these third-party websites. ITU does not offer any guarantee in that regard nor does ITU endorse the third-party organizations, their sites or content.


text:
Fawning Over You
$ 9.00
Fawning Over You (Lip Gloss) - a very warm-toned bronze gloss with buttercream scent.
This is packaged in a doe foot applicator lip gloss squeeze tube for easy application. This tube holds approximately 8ml (about 1.5 tsp) of product and has a dark charcoal gray cap to it. Tube is 4.125 inches tall (with cap).
Ingredients: Hydrogenated / Polyisobutene (and) Ethylene/Propylene Styrene Copolymer (and) Butylene/Ethylene/Styrene Copolymer Mica,Titanium Dioxide, Iron Oxide, Carmine, Boron Nitride, Sweet Almond Oil, Flavor Oil
Vegan?: No.
HydraGlaze's are made by our Sponsorship Manager, Piper. Each glaze is made by hand and with extra special care. Piper puts her all into this product and when applied a little goes a long way!
This product does not qualify for our GWP.


text:
Impounded Cats and Dogs that are not claimed may be available for adoption. Unclaimed animals are generally available for adoption eight days from the impounded date. Prospective owners are encouraged to visit the Pound to meet and become acquainted with available pets.
Fee includes: animal, vaccination, worming, microchipping, vet check, registration.
Adopting an animal from the Pound can be a rewarding experience, but before you adopt a pet please take some time to consider the commitment you are about to make.
Adopting a pet is a lifelong decision that will have a major impact on your everyday life. Please remember that a cat or dog can live for up to 20 years and they will rely only on you for their wellbeing for their entire life.
View animals for adoption then phone the Local Laws team on 1300 367 700 and quote the animal ID number
Submit your interest to adopt an animal below.
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text:
|2013-07-12, 23:36
|Link #7861
Member of Little Busters
Join Date: Mar 2012
Location: Edmonton, Canada
|2013-07-14, 07:33
|Link #7862
A pervert
Join Date: Oct 2012
I'm wondering, how can the magic community here hide the existence of supernatural completely from the world? In Uldin's time the people are still in the know about the supernatural. And with how often Campione and heretic god wracking havoc in the world, it should be hard to hide their existence completely. Furthermore, do the mage really need to hide the heretic god existence? Shouldn't it be better if the common people aware of the dissaster that can happen?
|2013-07-14, 07:52
|Link #7863
Senior Member
Join Date: Mar 2012
|2013-07-14, 08:00
|Link #7864
Join Date: Apr 2013
Location: At the Edge of the World
|2013-07-14, 08:50
|Link #7865
Old Wine
Join Date: Jul 2013
Location: In my Body
Gods themselves are more of devices, Deus ex machinas, to the old myths. Mythologist Joseph Campbell, who studied the very origins of storytelling, says we tell stories to make sense of mortal life. Stories have always been about human beings, and Gods are more of Plot Devices (which explains their poor characterization). In other word, they aren't really important and thus why it is possible to 'forget' about them.
The Gods and Myths that still remains today are the ones that managed to survive the religion wars and struggle against science. Those who lost in them were 'forgotten' thus why their existence was not found out and hidden from the world.
As for whether it is better to hide them... I think so. Think about how would society, economy, and political collapse that would ensues from the mass hysteria of their existence being found out. The panicking masses would blame the governments and the ensuing chaos would definitely not be pretty. It would make the 'Ee ja nai ka' looks tame in comparison
|2013-07-14, 10:36
|Link #7866
Divine Monarch
Join Date: Jun 2013
I've been rereading the series and found something a little strange to me.
("No, that's not it. Leaving aside the other godslayers, because you were born at the ends of the east, I'm specially telling you this. On the island where Godou lives, sleeps the strongest 《Steel》, so you have to be careful, for the time being. Understand?"
"Yes, the strongest. Although the hero-sama you are fighting now is also strong, that person is even stronger."
".... Why would that kind of person be in Japan?"
"Because, that is the end of the east - beyond that lies only sea, in other words. There are many things that have been swept there, heaped up there... perhaps it might be fine, seeing as that has already been sleeping for so long."
"Regarding that, could you please elaborate further?"
"Sorry, no can do. We stand at the side of the gods, after all, so I can't tell you any more than that. This is the pact that we have with this world, rules that we absolutely have to abide by.... Furthermore, whatever I say here, won't you forget once you return? Even if I do elaborate, it won't be of any use."
"Now that you mention it, that's true..."
Godou replied in a soft voice. Her words did, after all, remain in this realm of unconsciousness.
Perhaps the sixth sense and instincts of the Campiones that Godou had, were the information that she had relayed from this realm.
"Be careful. That person, is really vulgar, an enemy of women, unfit for the title of 'hero'! If you end up having to fight him again, you definitely cannot lose! You must give him a thorough thrashing!")
It says here that Pandora can't do much because she is at the side of the gods. (Then why make Campiones that kill them?) Also it say that Artus is really vulgar, an enemy of women, unfit for the title of 'hero'. Isn't that weird for the Steel category?
|2013-07-14, 10:42
|Link #7867
Old Wine
Join Date: Jul 2013
Location: In my Body
^ From where was that again? The question is, can we trust her information? Technically, the same description could be applied to Godou (and it has, in-universe wise). As for her being in the side of Gods but creating Campiones... well, maybe she's just the administrator of the system and her allegiance is to Gods because she's one herself? Besides, I did said that she is rather suspicious and I personally do not trust her words (at least not at face value).
|2013-07-14, 11:35
|Link #7868
Join Date: Feb 2012
It's from V4C4. As for Pandora saying she's on the side of the gods, I think it means she's a goddess and thus bound by the rules.
As for how/why the existence of magic and gods is hidden... "because Godou couldn't have a normal life to develop away from otherwise", coupled with a good portion of "willing suspension of disbelief". If you want a more in-universe reasoning, in Europe magic associations keep it under wraps everywhere, China has the Luo Hao's cult, Japan the HCC. I'd assume other regions either have similar institutions or they're not as magically active. That keeps the large-scale news clean. Europe's magic associations (and China's cult) have enough resources (and reasons) to get major influence with all news agencies anyway. And on a small scale it's implied that the people are somewhat aware and decide to ignore it (or they're quickly brainwashed to some degree). See Vol 3 for that.
|2013-07-14, 22:52
|Link #7869
A pervert
Join Date: Oct 2012
Its not that I don't like the setting where the magic is hidden, I'm just curious why all the mage in the whole world decide they're better off hiding. Our current society is like this because science can really explain everything and myth is just really myth. But in Campione universe where god really exist and they still descend to the world all the time, for what reason the whole magic society suddenly decide in the past to hide theirself from common people when they are not powerless and doesn't have reason to fear persecution? For the heretic god and Campione who is almost invincible, why do they also make their existence as secret? Why does the god who should be fussy about their follower and worship is hiding their existence?
And what's going to happen if someday there is someone vain who become Campione, decide he want to rule the world or a country, attack and annihilate the goverment and take over a country and reveal the secret worldwide, I don't think there is any way for the magic community to hide if that happen. After all we can see from Uldin that its possible for Campione to has ambition like that. I'm curious how can it be in the modern time the secrecy is completely enforced when there is a lot of heretic god and Campione who don't follow common sense, and why in the first place the magic community decide to hide.
|2013-07-15, 01:27
|Link #7870
Old Wine
Join Date: Jul 2013
Location: In my Body
^ As far as I know, there are two kinds of Gods in general: The ones that represents nature and the ones that ascends from being humans (exaggerated stories of heroes, kings, and tyrants). The first one is denied by science while the latter is denied because they have the former type as the main foundation.
The movement of science being the actual explanations is older than you think it is. It's as early as in Ancient Greek, where Plato mostly uses Ideas/Forms rather than Gods (and when he does, it is only in a story). Meanwhile, Herodotus' accounts are questioned due to it having fantastical elements, despite him being the father of history.
Now, imagine such things piling up and eventually reaching where in present times, science are called as the explanation of phenomenons while things such as magics are considered fantasies or rationalization of the people of the past. Myths themselves are mostly spread through traditions, thus confined to an area while science are spread through things such as educations, newspapers, and public announcements. The natural result was the general skepticism towards myths and legends by the public.
The situation has become like that and combined with the fact that those Heretic Gods and Campiones are akin to natural disasters anyway, the mages decided that it would be best if the status quo remains. The acts of Heretic Gods and Campiones was attributed to natural disaster which is attributed to some scientific phenomenon, which is what the public generally accepts due to skepticism towards myths. The Gods themselves aren't helping as unlike the Old Gods in the American Gods, they only do as they like, causing disasters, instead of trying to assert themselves to remain relevant. When they do assert themselves, it is only done due to their narcissism (as the case with Perseus) and is more hypnotic in nature.
Due to the general chaos that would ensues from the revelation, it is natural action to try to preserve the status quo as long as possible. When it is revealed, then what happens happens. But until then, the masquerade must go on for the sake of world peace.
|2013-07-15, 02:25
|Link #7871
A pervert
Join Date: Oct 2012
^ Hmm, thanks for the explanation. I guess your explanation is quite possible, though its still quite hard to believe with so many heretic god roaming the world and how disastrous Campione are, the whole world can become that disbelieving toward supernatural being.
|2013-07-15, 14:27
|Link #7872
Senior Member
Join Date: Jun 2012
I dont think the author himself has thought about why the magic world does council the existence of Gods. Like someone said he probably simply needed it for his scenario.
But thinking about it could make logical sense. I mean what do we know about Gods? That they are born from myths. Some people in the magic field could have thought that the more people believe in a certain god the more likely it is that one will ascend and therefore they tried to limit their belief. I mean think about it. If people knew gods materialize, many people would know many more gods. Many more than your average man knows which might help in the birth of a god. So if everyone thinks that they are myths and the less gods everyone knows the safer the world is.
And why they keep campiones a secret is already explained. Because there are many really stupid people who might do stupid things which might mean the destruction of a city as a result.
|2013-07-20, 13:39
|Link #7873
Old Wine
Join Date: Jul 2013
Location: In my Body
Meta-wise, the reason is Theory of Narrative Causality.
You know, I think that Gods would be much more dangerous than they are right now should they have a long-term planning mentality. See, they could change themselves and their powers as much as they want. So, take an isolated village/tribal gatherings, get worshiped by them (thus creating a small legend) then start spreading it to other places. I have three possible results in my hypothesis:
1. The God permanently gains a new aspect/Authority.
2. The God gains a new aspect/Authority as long as the myths are being circulated as those myths aren't physically part of him.
3. The God gains a new aspect/Authority as long as the myths are being circulated and he is the place where the myths are circulated.
This create a new question/theory though: Could Gods appears in places that doesn't have their legends? Well, not exactly that (there's Uldin and his Authorities after all), but you get what I mean based on the above theories, right? Strictly speaking, thanks to the internet, their legends are everywhere and since this is in the present times, there's no way to prove it. I am really interested in how the Gods are in the past times. Which is why, I hope the Author clarifies it (the mechanism) in the next Volume.
|2013-07-20, 19:19
|Link #7874
Join Date: Feb 2012
Don't gods remain the same once they have descended (think Lancelot)? So even if they messed with their own legends, they wouldn't gain anything out of it, only in a next incarnation. Which, if it happens at all, may take a thousand years or more, when the changes they made may have been forgotten or led to a completely new god (think Artus).
And we can already speculate how gods descend: We know there needs to be a legend about them (take Perseus) and a trigger (a dragon appearing). Personally, I assume the location needs to fit, too. Perseus descended in a volcano in a country related to him, didn't he? A volcano is also related to fire, which is required to forge steel. It would also be reasonable to think of it as a place with dense natural magic energy which at least won't hinder the process.
Another example, Melqart: Legend check. Trigger is Verethragna looking for a challenge, check. Location is related to Melqart, too. He was probably the most powerful god related to the region... and weren't there even temples for him? Anyway, check.
Dunno how Artemis got into New York's Central Park, though... then again, we know nothing about that event so w/e~~
|2013-07-20, 20:46
|Link #7876
Old Wine
Join Date: Jul 2013
Location: In my Body
|2013-07-21, 02:08
|Link #7878
Join Date: Feb 2012
|action, campione, ecchi, godslayer, harem, light novel, myth, romance, sd bunko, shounen, supernatural, time travel, true harem
|Thread Tools


text:
The First Division outfit had offered £80,000, plus 25% of any ongoing transfer, for the player who impressed while on loan in Greenock last season.
Morton's website reported that Celtic said this was "still well short" of their own valuation of the player.
Ton manager Jim McInally had previously thought his chairman would not increase their initial offer of £65,000.
"I thought £50,000 would have been a fair offer, but the chairman went in with £65,000 only to be told it was not enough," added the Morton boss.
What are these?


text:
[Date Index]
[Thread Index]
[Author Index]
Re: surface plot of an image
Hi Ale,
hidden in your picture, there is an array of grey values. You may locate
it by using InputForm or FullForm. If you e.g. import a BMP file it has
the form: Raster[{array}_,___]. You would extract this by:
arr = Cases[g, Raster[x_, ___] -> x][[1]];
Having extracted the array arr you may e.g. use ListContourPlot to look
at it.
alemarabi at gmail.com wrote:
> Hi,
> I have a microscopy image in gray levels and would like to convert it
> to a surface plot, in order to visualize the differences in grey values
> accros the picture.
> Is there an easy (or already) existing way to do that?
> Thank you in advance,
> Ale


text:
Prep Basketball Results; Apollo Boys Beat Rocori
Boys Basketball:
Apollo 51, Rocori 44
(Brett Maslonkowski led the Eagles with 22 points. Jonah Eisenschenk led Rocori with 18 points)
Tech 62, Sartell-St. Stephen 61 (overtime)
(Andy Foley made the game-winning basket for Tech. He finished with 27 points for the Tigers. Tim Immelman led Sartell with 18 points)


text:
Beam steering with high front-to-back ratio and high directivity on small platforms using decoupled antenna pairs
Tang, Xinyi, Mouthaan, Koenraad, & Coetzee, Jacob Carl (2011) Beam steering with high front-to-back ratio and high directivity on small platforms using decoupled antenna pairs. In APMC2011 Proceedings, Melbourne Convention and Exhibition Centre, Melbourne, VIC, pp. 1326-1329.
Accepted Version
(PDF 329kB)
Beam steering with high front-to-back ratio and high directivity on a small platform is proposed. Two closely spaced antenna pairs with eigenmode port decoupling are used as the basic radiating elements. Two orthogonal radiation patterns are obtained for each antenna pair. High front-to-back ratio and high directivity are achieved by combining the two orthogonal radiation patterns. With an infinite groundplane, a front-to-back ratio of 21 dB with a directivity of 9.8 dB can be achieved. Beam steering, at the expense of a slight decrease in directivity, is achieved by placing the two antenna pairs 0.5λ apart. The simulated half power beamwidth is 58°. A prototype was designed and the 2-D radiation patterns were measured. The prototype supports three directions of beam steering. The half power beamwidth was measured as 46°, 48°, and 50° for the three respective beam directions. The measured front-to-back ratio in azimuth plane is 8.5 dB, 8.0 dB and 7.6 dB, respectively.
Impact and interest:
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|ID Code:
|Item Type:
|Conference Paper
|phased array, beam steering, mutual coupling, compact array, phase shifter
|Australian and New Zealand Standard Research Classification > ENGINEERING (090000) > ELECTRICAL AND ELECTRONIC ENGINEERING (090600) > Electrical and Electronic Engineering not elsewhere classified (090699)
|Past > QUT Faculties & Divisions > Faculty of Built Environment and Engineering
|Copyright Owner:
|Copyright 2011 [please consult the author]
|Deposited On:
|04 Sep 2011 23:30
|Last Modified:
|14 Jul 2017 08:01
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text:
BBC 6Music celebrates 10 years on air on Sunday, March 11. To mark the occasion, Andy Welch finds out more from station stalwart Gideon Coe, daytime star Lauren Laverne, 6Music editor Paul Rodgers, and even has a go at broadcasting.
When the BBC launched 6 Music on March 11, 2002, digital radio was in its infancy and no one really knew if it was going to be a success.
As the first new channel the broadcaster had launched in 32 years, to cater for those not served by Radio 1 and 2, added to the fact hardly anyone in the country even owned a DAB (Digital Audio Broadcast) radio to receive the channel, the venture could have been a dismal, if well-intentioned, failure.
So one story goes, on Boxing Day 2003, 18 months after the station's launch when average listenership was 154,000, then breakfast show presenter Phill Jupitus appealed for anyone listening to email in. Just one listener responded.
A decade later, however, and the audience currently stands at just under 1.5 million listeners per day. In part, that's thanks to the arrival of high-profile presenters such as Pulp frontman Jarvis Cocker, ex-Catatonia singer Cerys Matthews and Elbow's Guy Garvey, who all present weekend shows, and Lauren Laverne, who has helmed the station's flagship 10am-1pm programme since late 2009.
"It's a very special station," says Laverne, seconds after turning down the fader on her microphone.
Sitting in the studio to observe her show, it becomes clear just how much work goes into making something appear effortless.
Laverne and her producer switch around songs at the last minute to ensure a balanced show, discuss upcoming events and answer emails, texts and Twitter messages - a platform on which she's particularly active - from fans.
All this at the same time as enthusing about the latest records they've heard and settling in live session guests.
"It's so important to react to what people are talking about," she says. "I want the show to have a community feel, like we're all listening together, but I'm in charge of the stereo."
Having come such a long way, during which time they've seen off a serious threat of closure, it's hardly surprising all at 6 Music want to celebrate its landmark 10th birthday.
Gideon Coe, who's been at the station since day one and can be heard on Monday to Thursday from 9pm, says: "I remember being given this adaptor for my radio at home so I could actually listen to the station I was working for. No one owned DABs then.
"I think the gradual rise in figures says a lot about the quality of what we're doing here, and it's more popular than ever," he adds, citing the recent Rajar figures (Radio Joint Audience Research), which show listeners are up 27% on the previous year.
Coe's 'if you build it, they will come' mantra is shared by station editor Paul Rodgers, who's been at 6 Music for the past three years.
"We've doubled our audience in the last 18 months or so," he says, "but I think we can get a lot more.
"There is a tallest tree in each forest, and there's obviously a maximum figure a station like this can achieve. But we're not there yet.
"I honestly don't believe popularity leads to dilution of purpose and I'm here to make sure that doesn't happen. We'd be shooting ourselves in the foot if we were to change."
In March 2010, the BBC's own Strategic Review, under pressure from the government to downsize the organisation, suggested the station, along with the Asian Network, should be closed.
Using the 'inform, educate and entertain' mission statement of Lord John Reith, who oversaw the BBC's formation as a public corporation in 1927, listeners picked apart the argument for closure and lobbied the BBC Trust to reverse their decision.
After many rallies, concerts and petitions signed, it was announced 6 Music would be saved.
The media spotlight won new listeners, but crucially, the majority have left their radio dials alone since discovering the digital-only station.
"Lots of people thought it was a clever publicity stunt at the time," says Coe. "But for those of us that work at the station, it was very, very real. Without the effort of campaigners, we wouldn't be here now, but ultimately it was the quality service 6 Music provides that saved it."
"People might have tuned in because they heard about the closure in the news, but if they didn't like what they heard, they wouldn't have come back," adds Rodgers. "6 Music is a place where like-minded people can consume brilliant things, and hear knowledgeable people speak about them.
"It's quite simple really, but harder than you might think to pull off."
Another example of the community spirit is Steve Lamacq's Round Table, which takes place each Thursday. Three guests are invited into the studio to pass judgement on the coming week's biggest singles in a Jukebox Jury-style manner. On the station's website, listeners are invited to do exactly the same, with scores averaged at the end.
A few weeks back, I was invited on to sit alongside James Brown of Pulled Apart By Horses, and James Endeacott, who discovered The Strokes and The Libertines during his time as the A&R at Rough Trade Records.
Talking to friends about music is something I've done since I was 12, just never before in front of a massive audience. Fortunately, after more than 20 years broadcasting, 'Lammo' as he's known, is hugely gifted in making his guests forget they're being listened to by around a million people.
"Just don't swear, libel anyone or be boring," is his only advice, and during the hour we listen to and award scores out of 10 to Gorillaz, Alabama Shakes, The Wild Mercury Sound, Graham Coxon, Santigold, Azealia Banks and Sleigh Bells, with Alabama Shakes's Hold On rightfully coming out on top.
And as Lauren Laverne scuttles off to organise more anniversary celebrations (set to include a series of live sessions at the BBC's Maida Vale studios, featuring the likes of Paul Weller), she concludes: "People might it's all a bit much. But we're 10, and 6 Music is definitely worth shouting about."
:: BBC Radio 6 Music celebrates its tenth anniversary on Sunday, March 11. For more information, visit www.bbc.co.uk/6music


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Congress requires the Bureau of Transportation Statistics (BTS) to report on transportation statistics to the President and Congress. Transportation Statistics Annual Report 2000 is the seventh such report prepared in response to this congressional mandate, laid out in 49 U.S.C. 111 (j). The report discusses the extent and condition of the transportation system; its use, performance, and safety record; transportation's economic contributions and costs; and its energy and environmental impacts. All modes of transportation are covered in the report.
The report has a new format this year, intended to make it easier for readers to find the information in which they are interested. The BTS publication, National Transportation Statistics has more comprehensive and longer time series, tabulated data than could be accommodated by the new format. Another BTS report, Transportation Indicators, provides quarterly, monthly, and in some cases, weekly updates for over 90 indicators pertinent to transportation. Both of these documents are available online at www.bts.gov.


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Nov. 18
Project Success Lanier Career Academy
2723 Tumbling Creek Road, Suite A, Gainesville
Score: 96, Grade: A
Food items out for use being left on both sides of designated hand sink. To prevent any possible contamination of food items by hand washing splash, keep food stored away from this area. Cloths used to drain, air dry kitchenware, utensils at 3-compartment sink. Serving utensils stored for use with food, lip contact surfaces presented for handling.
Inspector: Laurie Wentworth
Jalepenos No. 1
1784 Atlanta Highway, Gainesville
Score: 88, Grade: B
Items plated on truck below hot holding temperature.Three trays of food on truck without items being individually wrapped.
Inspector: Kathleen McDuffie
Lakeview Academy (G.I.S., Inc.)
796 Lakeview Drive, Gainesville
Score: 95, Grade: A
Ice machine baffle has some mold, mildew. Ice scoop holder has some accumulated residue. Can opener had bits of metal shavings accumulated.
Inspector: Shelby Finch
3446 Winder Highway, Flowery Branch
Score: 98, Grade: A
Hand sinks, 3-compartment and prep sinks no longer attached to wall. Hood system dripping. Floor needs better cleaning, especially under equipment, sinks, etc.
Inspector: McDuffie
Salsa Grill
4251 Winder Highway, Flowery Branch
Score: 100, Grade: A
Inspector: McDuffie
Nov. 19
The Hickory Pig
3605 Thompson Bridge Road, Gainesville
Score: 70, Grade: C
Food handler donning gloves to work with food without first washing hands. Open styrofoam cup of tea on edge of hand sink in kitchen. Hand sink with personal papers wedged between sink and wall, cell phone, aspirin bottles, tea in styrofoam cup in front of hand sink, bananas lying in hand sink. Hand washing taking place in 3-compartment sink. Ribs, pork loin, brisket in roasting pan over portable burner not maintaining required 135 degree hot holding temperature. Cooked-ahead meats in walk-in cooler not date-marked. Several bottles of ibuprofen on counter next to hand sink in kitchen area.
Inspector: Laurie Wentworth
Gamed Restaurante Y Salon de Fiestas
4257 Atlanta Highway, Gainesville
Score: 95, Grade: A
Improper thawing of container of previously cooked chicken. Container sitting in prep sink (meat sink) with water being run on closed lid of container. Current inspection sitting on back counter of bar/service area (improper location). Several ceiling panels have damaged covering. Coved baseboard and wall damaged under and along wall with prep sink (vegetables).
Inspector: Wentworth
Subway No.
5160 A Cleveland Highway, Gainesville
Score: 96, Grade: A
Employee food and drink on prep table.
Inspector: Donna Black
Dairy Spot
4841 Cleveland Highway, Gainesville
Score: 95, Grade: A
All drinks in kitchen must be in a single-service cup with straw and lid. Knife stored in-between grill and table.
Inspector: Black
Ninja Steak House
5753 Old Winder Highway, Braselton
Score: 98, Grade: A
Gaskets of several coolers split - replace ASAP to provide a smooth, durable, easily cleanable nonabsorbent surface. Shelves and shelf liners need better cleaning. Bulk storage containers need outside surfaces cleaned. Dumpster open. Trash on the ground. Floor throughout, especially under, behind equipment, needs detailed cleaning.
Inspector: McDuffie
The Dam Bar
3280 McEver Road, Buford
Score: 88, Grade: B
Soda guns and bar area and holders with heavy residue. Chemicals, medications stored on shelf with foods and items used for customer. Prep sink broken and laying in floor. Vents, hood with grease and need to be cleaned. Floor tiles cracked, damaged in walk-in cooler and in bar area.
Inspector: Black
Nov. 20
Chicopee Woods
Agricultural Center
1855 Calvary Church Road, Gainesville
Score: 79, Grade: C
No certified food safety manager on staff. Slaw served at concession made at home kitchen. Food handlers not wearing hair restraint. Coffee stirrers for customers must be individually wrapped or come from a dispenser if offered for customer self-service. Washed kitchenware, utensils in hand sink.
Inspector: Wentworth
Nov. 22
Biscuit Delite
3605 Thompson Bridge Road, Gainesville
Score: 94, Grade: A
Food handler washing hands in 3-compartment sink. Hood vents very greasy. Baseboard throughout kitchen (including under sink) need to be sealed at floor/wall juncture. Personal items - phone, checkbook - on biscuit table.
Inspector: Wentworth
Court Yard Restaurant
400 E.E. Butler Parkway, Gainesville
Score: 91, Grade: A
No certified food safety manager on staff. No dates on foods. Tools, personal items need to be in a designated area away from kitchen.
Inspector: Black
Lauren Blais


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Prepare better for storms
One of the measures of success for governmental entities is how well they have prepared for and been able to meet crises such as the recent sleet and ice storm. In Texas, from state government on down, they have failed.
While they may be excused for closing things on Friday, Dec. 6, they had the weekend to clear roads. Excavators and general contractors have equipment for removing ice; the cities could have plows to fit dump trucks. Technology exists for destroying ice; instead, governments made meaningless gestures.
Government managed to close the churches through its inactivity. Denton, the county seat, was inaccessible to its residents. Since schools were closed for three days, working parents had to struggle to find care for the students.
People lost income by not getting to work, or if they did go, it was at great risk to personal safety and damage to their vehicles on the cobblestone ice. Losses to businesses in a major shopping weekend before Christmas were in the millions, let alone the loss in sales tax revenue.
This was not an unusual occurrence. Two years ago we had an ice storm and a couple of years before that, a sleet storm. Over the years, these storms happen with enough frequency to warrant greater preparation. Governments fritter away money on nonessentials.
Perhaps our governmental leaders think Texans aren't worth the bother.
Walter Lindrose,


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In the acting world it's called committing to the moment, in the world of romance it's called committing to a lover and in the football world it's called…heck, I don't know what it's called because it's probably the first time it's ever happened. New York Jets head coach Rex Ryan was seen on vacation sporting a tattoo, presumably of his wife Michelle, in a Mark Sanchez jersey, 'Tebowing.' They don't call him Sexy Rexy for nothing!
As usual with Rex Ryan, this is something you just can't make up. If anyone was wondering why Ryan didn't pull the chord on Mark Sanchez as the Jets starting quarterback, we may now know why. It's clear that Ryan has an affinity for Sanchez and wants him to succeed. It also means he was lying through his teeth when he said recently that he didn't believe his future was tied to Mark Sanchez. Actually, it literally does mean that because of the tattoo.
Or maybe, and I'm just throwing this out there, the tattoo is a fake? Maybe Rex is having a little fun with us all and seeing what the reaction would be? Stranger things have happened, especially with Ryan and the Jets. That theory isn't likely since the New York Daily News reports Ryan said, "Oh s***," when he was spotted and ran away with his wife. Oh snap is right Rex.
The whole situation is seems pretty funny but I'm guessing there aren't too many Jets fans who are laughing. Ryan's belief in Sanchez led him to play the quarterback for way too long this season and it resulted in a 6-10 season. Remember all those times this year when Ryan said he believed in Sanchez and nobody bought it, well Rex sure proved everyone wrong! He really believed in Mark Sanchez and he's got the 'mark' on his arm to prove it.
At a time like this, one can only wonder what kind of tattoo Fireman Ed has?
you can chat with and follow Ben on twitter @BenGrimaldi


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As the years passed by Ferndale Luxury Bed and Breakfast became very special to us – not only for the imagination to run wild and the vision to create a sanctuary from everydays stress but for the comfort and luxury to indulge. In the heart of Achill island the furthest west you can possibly be in the gorgeous county of mayo we created a little paradise of our own. The landscape is stunning and living here at the edge of europe is a dream come through. So when we set out to conquer this little paradise nobody was aware what Ferndale would become. We started with 3 bedrooms nicely fitted and with comfort in mind. Big beds and ensuite for every room was essential. At that time we where very caucious with the furnitures and layouts. For a time that was fine but then the creation bug striked and ever since we tried to achieve a heaven of luxury and indulgence. Not only we continued to extend to now six lovely rooms, but to theme everyone of them to hopefully the highest possible standard. We tried to achieve a tranquil and peaceful setting in the rooms matching the tranquil and peaceful surroundings with half the rooms facing the sea and stunning views over to the minaun cliffs and the 4 mile beach streching from keel to the cliffs. To the left of Ferndale rises the highest mountain on Achill – the Slievemore – and beside a few miles towards the sea is Keel Lake. All this and more can be seen from some of our windows. No wonder we became very attached to Achill and the way we live. No matter what the weather to be here and live the life so close to the sea is a dream come through and as we watch the clouds pass by and the sun shines on the waters of the beach and the lake we wonder how priviledged and fortunate we are to found this fantastic place to spend our life.
Brand new for 2016:
Into our 14 year in business we did something spectacular: we created for 2 of our seaview rooms a fantastic seating aerea with floor to ceiling windows to let a maximum of light into the rooms those to newest additions are now even more luxurious then before. We as well installed minibars into every room and gave a face lift to everyone of them. So here we are with our stunning historically themed bedrooms and mini suites as well as one sumptious royal suite. To welcome you to our humble abode and to give you dear guests and yet to become guests of Ferndale Luxury Bed and Breakfast a unique experience and a fantastic stay with us Jon, Alexander and our Heidi dearest.
Please do not hesitate and contact us for any information.


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Gossamer Gear Lightrek 4
|Weight per pole
3.3 oz (Short), 3.4 oz. (96 g) (Regular)
|Weight trekking baskets
0.4 oz (11 g) each
Short adjustable from 85 cm (33 in) to 125 cm (49 in), Regular adjustable from 90 cm (35.5 in) to 140 cm (55 in)
Insanely light, exceptionally comfortable, crazy expensive…
Source: bought it new
Price Paid: $175 plus shipping
Insanely light, exceptionally comfortable, crazy expensive trekking poles that needs lots of TLC, and that I found too fragile for klutzes in mountainous terrain.
- Wicked light
- Comfortable, ergonomic handles
- Adjustable across a wide range
- Expensive to purchase
- Requires routine maintenance
- Repair parts expensive
- Carbon fiber snaps under heavy stress
- Do not collapse small enough to fit inside pack
When I began looking at reducing the overall weight I'd be humping while hiking the Appalachian Trail, I started hearing about new, lighter hiking poles. My old Black Diamond poles weighed 18 ozs, and they seemed a good candidate for lightening.
Besides using them to help propel me up mountains, slow me down when going down them, and providing balance in stream crossings, I planned on having them hold up my tent. So, whatever I chose would have to be adjustable from about 115cm where I like to cruise, to at least 130 cm to work with my tent.
BD came out with a new line called Distance trekking poles that fold up like avalanche poles. They come in both fixed lengths, and in an adjustable version using a flick-lock. The weighed from 15.2 to 16oz a pair, depending on length, and list at $119.95. Which seemed like a lot to pay to save 2 ozs ... But more importantly, the one length they had that extended far enough to support my tent (120-140cm), did not collapse enough to support me in the manner to which I have become accustomed.
Enter GG LT4s - Then someone in a hiking forum professed his loved for his GossamerGear's Lightrek 4 adjustable carbon fiber trekking poles. Adjustable from 90cm to 140cm, and weighing only 7.2 oz a pair - That's right, I said a pair! Less than half the weight of my good ole BDs! Online reviews were all positive, and implied that they are as rock solid as the BD flick locks.
And in a bonus for me, the wrist straps are attached to the top of the poles with screws, and when taken off, an optional camera adapter can be screwed in. I could leave a few ounces of camera support at home!
My Experience - One downside is that they only collapse to about 33" making them too long to fit inside my pack. Another is that they are really spendy, and shipping is spendy. The price quoted on their page is for a single pole ... Once I worked thru the five stages of grief I go through with any such purchase, I ordered a pair from their website, along with the optional camera adapter. They arrived a few days later, unscathed in a heavy-duty cardboard tube.
My first reaction was how beautiful they are in their simplicity. Matte black shafts, uncluttered by locking mechanisms, tan ergonomic handles, and robust looking tips. Then I was blown away by their weight. Or rather, their lack thereof. I found the poles adjusted easily, requiring only a couple of twists to lock them securely. The "Kork-o-lon" grips were very comfortable.
I hiked 114 miles thru Georgia and into North Carolina on the AT with these poles, and had no problems. They held securely, adjusted easily, and held my tent up perfectly.
I went home with an injury, and started again southbound from Maine. My second day in the 100-Mile Wilderness, I sunk up to my knee in a deep mud puddle, along with one of my poles. I lost my balance, fell forward, and snapped the lower section right where it met the upper section. A phone call to GG from a mountaintop had another lower section waiting for me in Monson, for $45 plus shipping.
Meanwhile, with about 230 miles on them, the other pole started getting hard to adjust. Then nearly impossible. The rubber expander had begun to deteriorate, and was getting sticky. I was ultimately unable to adjust the pole. Emails to GG resulted in them sending me a rebuilt lower pole section from their "hiker box" in exchange for the old section. Plus shipping.
A few days later, I was descending Wildcat Mountain in the rain. I slipped on exposed rockface and fell on my butt. One of the poles was behind a rock, and snapped on my way down. This time an upper section ...
In 434 miles I had to replace three sections - two of which requiring me to whip out a credit card. To be fair, they were some tough, mountainous miles. But, it occurred to me that the "Light" in "Lightrek" is as much a reference to the type of hiking for which they are designed, as to their weight.
Well, at least that's what I preferred to think, rather than, you know, the possibility that I was just too dam hard on 'em ...
At that point, I shipped those parts home, and bought a set of Lekis at a local outfitter to get me thru the Presidentials and points south…
A High Maintenance Relationship - These poles need regular maintenance. Separate the poles when not in use, clean them regularly. Still, replacing a worn out tip means purchasing a "Replacement Tip Section" which includes the whole bottom section of the pole for $45. Replacing both would be $90 plus shipping… Replacing expanders … The life-cycle cost of these could be astounding. I had them for a year, and they cost me $331.
Bottom Line: I replaced that broken upper section, and I'll use the LT4s for hiking in less than hairy, wet, mountainous conditions.
Another great review, Bill. Do you know your base weight in those rugged mountains? Your comment about the significance of "light" made me curious. Would you ascribe these failings to the classic low weight vs. higher fragility trade-off (in other words, an inevitable possibility owing to the lightness of material), or to suspect design?
3 years ago
BB, my base weight at that point was about 19 lbs, carrying shoulder-season gear. Yes, I think its more a case of low-weight/higher fragility trade-off than of poor design. In both cases in which they snapped, the tip was dug in, the shaft was up against a log or rock, and I fell forward forward. They snapped because of the material. Aluminum would have bent. They might not have snapped if they were built more robustly, but then they wouldn't be so light. So it's a trade-off.
3 years ago
You cannot count on these poles to lock everytime.
Source: bought it new
Price Paid: $160
You cannot count on these poles to lock everytime.
- LOVE the light weight
- Great hand grips
- Not dependable to lock.
- Very expensive for something that you cannot count on.
I bought these poles spring of 2011. From the beginning I had trouble getting them to lock. Being I use them for my tent support I found it most frustrating.
Sometimes it would only take twisting them for a few seconds or a minute, other times I would work on it up to 10 minutes. At that time it finally worked or I just gave up. I could get one to lock but not the other one, or both.
Sometimes if I wetted the inside lock rubber washer it would catch. Several times I had to hike with one pole or none because of them not locking. I have had to look for branches to set my tent up with. Being many other people have also had this same problem I don't understand why they don't fix the problem at Gossamer Gear.
After hiking over 8,000 miles in the last decade I…
After hiking over 8,000 miles in the last decade I have come to appreciate product quality and ingenuity. Gossamer Gear's Lightrek 4 Trekking poles give me everything I need from poles (balance, support, ease) but with the added benefit of not weighing a lot.
They are so light that when I am not using them, say to grab a snack or read my map, I just tuck them under my arm and forget about them. Or if I'm in a town or on asphalt, I break them down and put them in my pack. It's nice not to have the extra weight of heavier poles. And yet, I still use them to catch me when I trip, to leapfrog over streams, for balance as I tear down steep mountains and for support as I head up them.
One of my favorite design features are the comfortable soft handles that are shaped so that I can keep switching my grip to four different positions. It keeps my wrists from getting sore. The poles have become an extension of my body as I hike, I forget about them, yet would miss them if they were gone.
This is the collapsible version of the Gossamer Gear…
Price Paid: $160
This is the collapsible version of the Gossamer Gear Lightrek 3 poles and aside from the weight -- the 4's weigh a half oz. more than the 3's -- there isn't a lot of difference between the two. Both are made of ultralight graphite fiber composite.
These poles are so light that you'll never get over how light they are. What sets one collapsible pole apart from another is grip comfort, strength, ease of adjustment and weight.
When it comes to weight, other collapsible poles don't come close to these. They weigh 3.4 oz. each! The amazing thing is, this doesn't appear to come as a result of a compromise with strength. I put a lot of weight on them especially on steep, rocky descents and they take it.
As far as comfort goes, they're winners. The soft grips keep discomfort and fatigue to a minimum. When I'm descending, I usually have the top of the grip against my palm the way I'd use a cane to support my weight. The wide soft top distributes the load across my hand for maximum comfort.
The adjustment locking is of the twist-to-tighten variety. I much prefer a lever lock for speed and reliability, but at Gossamer Gear, weight gets priority and the levers add weight. That said, I've found that once locked, they stay locked so it hasn't been a problem. I don't use my poles to hold up a tent so I'm not adjusting them twice a day, just at the beginning and end of the trip. The first time I used these poles, one pole wouldn't lock. I slipped the bottom section out and tightened the adjuster about a quarter turn, expanding it enough to grab the top section. I haven't experienced a recurrence.
Where to Buy
Similar Products
Gossamer Gear Lightrek 4
$160.00 - $175.00
The Gossamer Gear Lightrek 4 is not available from the stores we monitor.


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-Mandarin Oriental New York brings together an unprecedented combination of outstanding service luxurious accommodations and prime location as the jewel of the Time Warner Center overlooking Central Park at Columbus Circle. -Steps away from Lincoln Center midtown Manhattan and Broadway theatres Mandarin Oriental is the ideal location for leisure and business travelers alike -The superbly appointed guestrooms and suites are located on floors 38 - 54 and feature breathtaking views of the Hudson River Manhattan skyline and Central Park. -The trend-setting 35th floor restaurant Asiate offers contemporary cuisine and an award-winning wine list. Also available is the stunning Lobby Lounge with captivating views of Central Park and the Manhattan skyline and the chic MObar. -The Five-Star Spa at Mandarin Oriental features bamboo-detailed treatment rooms - Oriental Tea lounge - relaxation lounge - vitality pool - amethyst crystal steam room - Thai Yoga Room and a luxurious VIP Spa Suite. -Restorative treatments complemented by Asian-based rituals offer guests a journey of the senses. A 75-foot naturally-lit lap pool and state-of-the-art sports and fitness center complete the unparalleled recreational opportunities.
- Mandarin Oriental New York enjoys prime position - occupying floors 35 to 54 of the Time Warner Center at Columbus Circle. - Located in the heart of Manhattan - the hotel features breathtaking views of Central Park - the Hudson River and the city skyline and offers direct access to world class shopping and entertainment. - La Guardia Airport - approx. 35 Minutes by taxi 10.5 Miles 16.9 Km - JFK Airport - approx. 50 Minutes by taxi 15.5 Miles 24.9 Km
Cuisine - Asiate contemporary with Asian influences - presents unforgettable views of Central Park - Manhattan skyline - Located 35F - Opening Hours - 0700 - 2200 Mon - Sat - 0700 - 2100 Sun - Dress Code - Lunch - Smart Business - Dinner - Smart ElegantLobby Lounge
Located on the 35 F sky lobby - Light fare or afternoon tea or cocktails and late night desserts with dramatic views of Central Park and the City skyline - Opening Hours - 0800-2330 Mon to Thu 0800-0030 Fri to Sat 1200-2330 Sun - Dress Code - Smart CasualMO Bar
Cuisine - Chic cocktail bar - Opening Hours - Bar Service - 1600-0030 Tue - Sat Light Fare 1600-2300 Tue - Sat Closed Sun and Mon - Dress Code - Smart Chic