text:
VIEWS: 23 PAGES: 17 CATEGORY: Education POSTED ON: 12/29/2009 Public Domain
AKIN G U M P S T R A U S S H A U E R & FELDLLP Attorneys at Law Richard B. Zabel 212.872.806Olfax: 212.872.1002 email@example.com December 16,2008 VIA ELECTRONIC FILING AND OVERNIGHT DELIVERY Florence E. Harmon Acting Secretary Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: Release No. 34-58785; File No. S7-31-08 Greenlight Capital, Inc.'s Comments on Interim Final Temporary Rule re: Disclosure of Short Sales and Short Positions by Institutional Investment Managers Dear Ms. Harmon: On behalf of Greenlight Capital, Inc. ("Greenlight"), we submit the following comments on the Securities and Exchange Commission's ("SEC") above-referenced Interim Final Temporary Rule (the "Rule") requiring institutional investment managers to disclose to the SEC certain information regarding their short sales and positions in securities covered by Section 13(f) of the Securities Exchange Act of 1934 ("Exchange Act"). Greenlight is in full support of responsible measures that will restore the marketplace to health, but this proposed Rule is not such a measure. It is merely a continuation of measures that have already proven unsuccessful. The Rule will neither put a stop to manipulative short selling nor aid the SEC in tracking ongoing manipulation. It will only restrict and hamper legitimate short sales, increase the possibility of issuer retaliation, and place a substantial burden on investment managers, exceeding any similar burden placed on long-side investors, at a time when such burdens are neither necessary nor beneficial to the securities markets. Because it inhibits legitimate short selling, the Rule will make markets less efficient and will artificially inflate the value of securities - effecting manipulation rather than preventing it. For these reasons, and as further explained below, we urge the SEC to rescind the Rule. One Bryant Park INew York, NY 10036 1212.872.1000 1 fax: 212.872.1002 1 www.akingump.com AKIN GUMP S T R A U S S H A U E R & FELDLLP Attorneys at Law Florence E. Harmon December 16,2008 Page 2 I. SHORT MARKET SELLING N O T THE CAUSE THE CURRENT IS OF CRISIS IS AN AND IMPORTANT COMPONENT THE SECURITIES OF MARKETS A. All Available Data Demonstrate that Short Sales did not Cause the Recent Market Collapse We begin by addressing what appears to be the primary impetus for the Rule, i.e., the SEC's stated concern that "artificial price movements . . . based on unfounded rumors" regarding the stability of financial institutions and other issuers might be "exacerbated by short selling."' The SEC has reiterated this concern in its recent emergency orders curtailing and banning short sales.2 But the SEC has provided no evidence whatsoever that short sales actually caused or exacerbated any "artificial price movement" in the past several months. To the contrary, all available evidence shows that our securities markets were overvalued and that the recent declines constitute a market correction. As Chairman Cox has stated, the root of our current market crisis was "the meltdown of the entire U.S. mortgage market,"3 prompted by the collapse of the housing bubble and the utter failure of banks, mortgage brokers, and rating agencies to accurately and appropriately measure risk. The effect of this meltdown on our securities markets was magnified because "firms and investors in every sector of the financial services industry I Disclosure of Short Sales and Short Positions by Institutional Investment Managers, SEC Exchange Act Release No. 58785, File No. S7-3 1-08 (October 15, 2008), at 8, available at http://www.sec.gov/rules/finaY2OO8/34- 58785.pdf. 2 See, e.g., Emergency Order Pursuant to Section 12(k)(2) of the Securities Exchange Act of 1934 Taking Temporary Action to Respond to Market Developments, SEC Exchange Act Release No. 58591 (September 18, 2008) (first emergency order requiring disclosure of short positions), at 1, available at http://www.sec.gov/rules/other/2008/34-5859l.pdf; Amendment to Emergency Order Pursuant to Section 12(k)(2) of the Securities Exchange Act of 1934 Taking Temporary Action to Respond to Market Developments, SEC Exchange Act Release No. 5859 1A (September 2 1,2008) (amended emergency order requiring disclosure of short positions), at 1, available at 1 i t t ~ : i l w w \ v . s e c . 1 r . 0 ~ ~ / r ~ ~ l e s ~ t h e r ~ ~ 0 0Emergency1 ~ , Pursuant to 1 4 - 5 8 5 9 Order Section 12(k)(2) of the Securities Exchange Act of 1934 Talung Temporary Action to Respond to Market Developments, SEC Exchange Act Release No. 58592 (September 18,2008) (banning short sales in certain financial companies), available at I~tt~:~!www.sec.~o~~lrulesiotheri2.008!34-5859:!.pdf. 3 Lessons From tlze Credit Crisisfor the Future ofRegulation: Hearing Before the H. Comm. on Oversight and Government Reform, 110th Cong. (2008) (testimony of Christopher Cox, Chairman, Sec. and Exch. Comm'n), available at httn:i'iwwn..sec.~o~~~newsilestii1~onyi2008i'ts10230cYc~.l~t1n. AKIN GUMP STRAUSS HAUER & FELDLLP Attorneys at Law Florence E. Harmon December 16,2008 Page 3 have been vulnerable to the effects of the toxic mortgage contagion...."4 Economist and Nobel Laureate Gary S. Becker explains: "Short sales did not cause the crisis, but reflect beliefs about how long the slide will continue. Trying to prevent these beliefs from being expressed suppresses useful information, and also creates serious problems for many hedge hnds that use short sales to hedge other risk^."^ Further, if the SEC wishes to act against "unfounded rumors" or "artificial short selling," it can do so without any additional rulemaking. In fact, it has been widely reported that the SEC has conducted and continues to conduct such an investigation relating to the short selling of several financial firms. To date, the SEC has not announced any findings of wrongdoing. Notably, the SEC does not appear as concerned about unfounded positive rumors promulgated by supporters of those same financial firms. Moreover, the available empirical evidence conclusively demonstrates that the recent market decline was not caused by short sales. All of the major indices experienced their most rapid declines during the period when short sales offinancial institutions were banned. From September 19 through October 8, the S&P 500 dropped 21.5%. During the same period, the KBW Bank Index - which tracks many of the financial institutions that were on the SEC's "no- short list" - dropped nearly 33%.6 The temporary ban on short sales also resulted in a decline in market quality and stock liquidity.7 By comparison, in the two months prior to the ban, the S&P Index dropped just 4.4% and the KBW actually rose 15%. In fact, it is likely that the SEC's actions against short-selling have worsened the stock market crisis and increased market volatility. For example, the ban on short-selling immediately disrupted the convertible bond market, as most investors in that market actively hedge their holdings of convertible bonds with short sales. As those investors found themselves unable to modify their hedge positions, their only choice was to sell their convertible bonds.* During the last recession, many companies avoided financial distress by issuing convertible bonds. But as a 4 Christopher Cox, Chairman, Sec. and Exch. Comm'n, Speech to the PLI 40th Annual Securities Regulation Institute: Building on Strengths in Designing the New Regulatory Structure (November 12,2008), 1 1OXcc ~ available at ~ ~ ~ ~ ~ ~ c ~ ~ ~ c ~ 1 1~ ~ . h t n ~ . ~ ~ ~ ~ ~ ~ ~ ~ ~ c I I ~ ~ O O X ~ S ~ 5 Gary S. Becker, Op-Ed, We're Not Headed For a Depression, WALLST.J., Oct. 7,2008, at A27. Oct. David Bogoslaw, Short-Sellers: Uizfairly Targeted in the Market Crisis?, BUSINESSWEEK, 13,2008. 7 Arturo Bris, Slzorting Financial Stocks Should Resume, WALLST.J., Sept. 29,2008, at A25. 8 Tom Lauricella, Short-Sale Ban Wallops Convertible-BondMarket, WALLST.J., Sept. 26,2008, available at ht_tl7;ill!!inc,~::~ .~m!!~cS3._..8!?._~r,43.h~! c~;ri!!I!22238_!~52!2_..t~. AKIN G U M P S T R A U S S HAUER & FELDLLP Attorneys at Law Florence E. Harmon December 16,2008 Page 4 result of the disruption in the convertible bond market caused by the SEC's short sale ban, companies could not take similar measures during the present market crisis. Moreover, there are many other investing strategies that require active hedging through short sales. As the SEC has shown a propensity to change the rules of short selling without notice, many investors have reduced their participation in the market due to the increased regulatory risk caused by such uncertainty. As such investors exited their short positions, many of them also sold their hedged long positions, thus reducing market liquidity. As a result, overall market volatility has increased. A recent Citigroup report noted that, since the SEC imposed its short-selling ban, there have been more days where the S&P 500 fluctuated more than 5% intraday than in the entire 50-year period between 1950-2000.~ B. Short Selling is an Important Component of the Securities Markets Prior to the recent market crisis, both the SEC and the public had recognized the benefits of short selling to our securities markets. In a December 1991 study on the effects of short selling, the House Committee on Government Operations found that short selling "has an important and constructive functional [role] in the equity market," and that "the psychological environment surrounding short selling has led investors to systematically overestimate the manipulative power of short seller^."'^ Former SEC Chairman William Donaldson has publicly stated that short selling "can add im ortant benefits to the market, such as facilitating liquidity, P' hedging, and pricing efficiency.. .." Moreover, "[all1 experts, including [the SEC's] own economists, are convinced that short selling provides the marketplace with liquidity and pricing efficiency."" Short selling also lowers market volatility and enhances market quality.'3 It is clear that short selling plays a vital function in ensuring accurate asset valuation. n ~ o t i o Sickness Quantified, Posting of Barbara Kiviat to The Curious Capitalist, .. . ~b1.~?~s.~~i~nc~.~.~~.n~i~.1908i~..~i~~.2,~n~.o_ti_o.r!~s.i.c.k.n_ess-wi!_n_t~.fi~~ !~!J~.;r?_"c~!!:!i?.~.s.~_a~rt!11.i$f (Dee. 2, 2008, 12:09 PM). l o Short-Selling Activity in the Stock Market: Market Effects and the Need for Regulation, H.R. REP.NO. 102-414, at 12-15 (1991). II Investor Protection Implications of Hedge Funds: Hearing Before S. Comm. on Banking, Housing and Urban Affairs, 108th Cong. (2003) (testimony of William H. Donaldson, Former Chairman, Sec. and Exch. Comm'n), available at l~ttv:i~~vww.sec.~,rnv!newsitestin~ony!04 10031swhd.htn1. 12 Roe1 C. Campos, Former Comm'r, Sec. and Exch. Comm'n, Speech at Sec. and Exch. Comm'n Open Meeting (July 12, 2006), available at l ~ t t p : i ' ~ ~ 1 ~ w ~ v . s e ~ ~ ~ ~ ~ ~ ~1206rec.lltn1. p e e c h O 7 !ine~~~!~ l 3 see, e.g., Jennifer Conrad, The Price Effect of Option Introduction, 44 J . OF FINANCE 487 (1989) (finding stock volatility lower after reduction in short sale constraints by option introduction). AKIN GUMP S T R A U S S HAUER & FELDLLP Attorneys at Law Florence E. Harmon December 16,2008 Page 5 Short sellers also play another essential role in our securities markets: their critical analyses of companies serve as a counterbalance to the almost uniformly bullish voices of issuers and investment banks. The ongoing market crisis is a devastating reminder of the need for precisely such a voice. Over the past several years, the bubble in the housing market reached unsustainable levels, investment firms made record profits through sales of packaged and re- packaged mortgage-backed securities and other derivatives that were impossible to value, and the ratings agencies ignored the risks associated with such securities. None of these groups raised any concerns, which is no surprise, considering that each of these groups had a financial incentive to breathe more air into the bubble. There was only one exception to this uniform chorus of positive voices: short sellers. For example, in April of this year, Greenlight voiced its concern that Lehman Brothers Holdings Inc. ("Lehman") was overvaluing its asset-backed securities ("ABS") (including sub- prime mortgage-backed securities) and was publicly underestimating its exposure to the ABS markets. Greenlight stated that the SEC should "guide Lehman toward a recapitalization and recognition of its losses - hopefully before federal taxpayer assistance is required."I4 Of course, no such recognition of losses occurred. What did occur was a public backlash against Greenlight. Lehman went even further, exploring the possibility of manipulating its own stock price to drive Greenlight out of its short position. In an e-mail to CEO Richard Fuld, a senior Lehman executive suggested that if Lehman obtained $5 billion in financing from Korean banks, "I like the idea of aggressively going into the market and spending 2 of the 5 [billion dollars] in buying back lots of stock (and hurting Einhorn bad! !)." l 5 Richard Fuld's e-mail response: "I agree with all of it."I6 But a few months later, the public, regulatory agencies and even Lehman's own trading counterparties had come to the same conclusion as Greenlight. This is only one of many such examples: short sellers such as James Chanos and David Tice exposed the problems at Enron and Tyco before regulators ever became involved. For this very reason, Chairman Cox publicly noted (as the mortgage crisis was reaching its peak) that "[slhort selling helps prevent 'irrational exuberance' and bubbles. Continued legitimate short selling in the securities of these financial 14 See David Einhorn, President of Greenlight Capital, Inc., Speech at the Ira W. Sohn Investment Conference: Accounting Ingenuity (May 2 1,2008), available at httv:.'!www.fooli11p~0n~e~eop1e.~o1n/n~ain~~CF~~~302008?'020Spee~h.~df. 15 See Causes and Effects of the Lehman Brothers Bankruptcy: Hearing Before H. Comm. on Oversight and Government Refomz, 110th Cong. (2008) (opening statement by Rep. Henry A. Waxman, Comm. Chairman), available at h ttv:lioversight.house.govidoc~~n~entslOO 1958.pdf. 100610 l6 ~d. AKIN G U M P S T R A U S S HAUER & FELDLLP Attorneys at Law Florence E. Harmon December 16,2008 Page 6 firms will act, as it is supposed to, as a way for market participants to invest in the downside and to hedge other positions."'7 The Rule and the SEC's many recent rules restricting or hampering short selling threaten to remove the counterbalance that short sellers provide to the securities markets. Short selling is already a difficult and risky process that need not be further hindered by sudden rule changes, overheated rhetoric by government officials and unnecessarily burdensome regulation exemplified by the Rule. The Rule will discourage investors who otherwise would have sold short a security based upon their legitimate belief that the security is overvalued. By discouraging short selling, the Rule will also discourage investors such as Greenlight fiom voicing their critical analyses of companies or industries. This is anathema to the fundamental principle underlying our securities markets: that the price of a security should reflect what the investing public is willing to pay based on all material facts about that security. The public debate about the value of a security should therefore be robust. A. Form SHs May be Subiect to Public Disclosure through FOIA Notwithstanding the SEC's promise of "confidentiality" to all Form SH filers, the Rule subjects Form SH filers' investment and trading strategies to a substantial threat of public disclosure. The SEC may exempt material from disclosure pursuant to the Freedom of Information Act ("FOIA") only if the material falls within an exemption fiom FOIA disclos~re.'~ Even if the SEC denies a FOIA request for Form SHs, determined FOIA requesters can seek redress in the courts. Courts have overturned the SEC7sFOIA decisions in the past.19 In other 17 Chstopher Cox, Chairman, Sec. and Exch. Comm'n, Op-Ed., What the SECReally Did On Short Selling, W A L L J., July 24,2008, at A15. ST. 18 5 U.S.C. # 552(b); SEC Letter to Confidential Treatment Filers, June 17, 1998, available at l i ~ t p : ! ~ w ~ ~ ~ ~ ~ ~ . s e c . ~ o v ~ d i v i s i o n s i i i s if~ i ttu i dn (noting that the Exchange Act and FOIA "set out the an~eI requirements under which the [SEC] may grant confidential treatment.. ." to materials). I9 See, e.g., Feshbach v. SEC, 5 F.Supp.2d 774 (N.D. Cal. 1997); see also SafeCard Sews., Znc. v. SEC, 926 F.2d 1197 (D.C. Cir. 1991) (finding SEC failed to meet burden of proving applicability of deliberative process exemption to FOIA and remanding for further proceedings). AKIN GUMP S T R A U S S HAUER & FELDLLP Attorneys at Law Florence E. Harmon December 16,2008 Page 7 instances, the SEC has responded to lawsuits by disclosing additional materials it had previously refused to disclose.20 Moreover, the SEC could change its position regarding FOIA disclosure of Form SHs at any time. Indeed, the SEC's own internal FOIA appeals process demonstrates that the SEC reconsiders and reverses its initial FOIA decisions with some regularity.2' We anticipate that FOIA requests for Form SHs will come from numerous sources, including the general investing public (hoping to engage in what the Commission has called "imitative short selling"),22 reporters, and issuing companies. Many such issuing companies have publicly attacked short sellers, initiated litigation against them and lobbied the SEC to s.~~ commence regulatory i n ~ e s t i ~ a t i o nThese companies have a financial interest in aggressively pursuing FOIA requests for Form SHs before the SEC and in federal court. Indeed, the feeding frenzy has already begun. It is now public knowledge that within six weeks of the Rule's announcement, the New York Times issued a request for all Form SHs filed to that point.24 Others have filed FOIA requests for selected Form S H S . ~ ~ have no doubt that We many of the filers of these specific requests are either members of the public hoping to capitalize on knowledge of short selling strategies or issuing companies hoping to find ammunition for their attacks on short sellers. 20 See, e.g., Gavin v. SEC, No. 04-4522,2007 W L 2454156 (D. Minn. Aug. 23,2007) ("Gavin's vigorous and persistent prosecution of the action - not the mere passage of time - forced the SEC to release the documents and comply with FOIA"). 21 See SEC Freedom of Information Act Annual Report for Fiscal Year 2007, available at (noting h~tp:'~ww\v.sec.~ov'lbiaiarfoia07.ll~m that, out of a total of 160 appeals decided between October 1,2006, and September 30, 2007,27 initial decisions were partially reversed and 29 were completely reversed). The evolution of the SEC's position on public disclosure of Form 13F is also instructive. See Edward Pekarek, Hogging The Hedge? "Bulldog's " 13f Theoiy May Not Be So Lucky, 12 FORDHAMCOW.& FIN.L. 1079, 1125 (2007) J. (noting that after 1998, SEC changed course and regularly denied requests for confidential treatment of Form 13Fs). 22 Rule at 23. 23 See Owen A. Lamont, Go Down Fighting: Short Sellers vs. Firms, Yale Sch. of Mgmt. & NBER, July 14,2004 (working paper), available at 11t~p:/Issim.con1/absti-act=56690 1 (listing the methods used by companies to attack short sellers). 24 See Ropes & Gray LLP, "FOIA Requests Seek Release of All Forms SH Filed with the SEC" (November 21,2008), available at ht~p::"www..ropesrrray.co~n!foiarequests seek release of all forms sh filed wit11 the see'. 25 Id. AKIN GUMP S T R A U S S HAUER & FELDLLP Attorneys at Law Florence E. Harmon December 16,2008 Page 8 B. Public Disclosure of Form SHs Would Cause Substantial Harm to Legitimate Investors and the Securities Markets Public disclosure of Form SHs would be disastrous to investors and counter-productive to the SEC7spurpose for issuing the Rule in the first place. Because the Rule requires short sellers to submit detailed descriptions of their short positions and transactions on a daily basis, disclosure of this information would enable the public to decipher investors' trading strategies. This would cause the greatest harm to long-term, value-oriented investors such as Greenlight. Because Greenlight holds its positions for months or years, its Form SHs would give a clear and complete picture of Greenlight's strategy, not just for one security but also for numerous comparable companies. Greenlight's Form SHs would tell the public: (1) when Greenlight first opened a short position; (2) when, how, and in what increments it built up its short position over time; (3) how long it held that investment; and (4) how and in what manner it unwound that position. This information would allow the public to recreate Greenlight's investment strategy with little effort. Moreover, because Greenlight often analyzes entire industries and sectors before selling short a single stock, the public disclosure of Greenlight's Form SHs would also enable the public to anticipate what other companies Greenlight might sell short in the future and how it will do so. Thus, disclosure of Greenlight's Form SHs would substantially impair both the value of Greenlight's current investments and its ability to make hture investments. C. Public Disclosure of Form SHs Would Lead to the Freezing Out and Intensified Intimidation of Short Sellers by Issuers Moreover, by collecting the information required on Form SHs, the SEC risks becoming a resource for companies that would attempt to "freeze out," intimidate and "short squeeze" short sellers to improperly prop up their stock price. Disclosure of Form SHs to these companies would cause substantial harm to short sellers. Once issuers learn that an institution has sold short the company's stock, the issuers are less likely to give that institution access to company management. It is already commonplace for investors known to have sold short a company's shares to be blocked from asking questions on investor calls or fi-om meeting with management. Greenlight has had this experience. This behavior effectively silences those ready to ask pointed and critical questions. Abetting these companies in restricting the access of independent analysts who may be critical is precisely the opposite of what the SEC should be doing. Indeed, it was only a few years ago that an investigation by the SEC and the New York Attorney General's Office revealed the conflicted AKIN GUMP S T R A U S S HAUER & FELDLLP Attorneys at Law Florence E. Harmon December 16,2008 Page 9 nature of most Wall Street analysis.26 It would be ironic and counter-productive if, just five years later, the SEC muzzled the few remaining independent, critical voices. Even worse, it is not hard to imagine an issuer using the information in a Form SH to intimidate a short seller. Issuers have a lon history of publicly attacking short sellers and intimidating short sellers through litigation.5 7 Not surprisingly, such attacks have only increased during the recent market crisis. It seems like every financial company caught up in the aftermath of the mortgage meltdown has publicly attacked short sellers in an effort to distract the public from its own wrongdoing and incompetence.28 Greenlight has often been on the receiving end of such attacks. In the past few years, companies in which Greenlight took a short position have: (1) illegally accessed Greenlight's phone records and the personal phone records of its employees; (2) publicly attacked Greenlight in the news media; (3) successfully lobbied the SEC and other regulatory agencies to open investigations into Greenlight's actions, only to have the regulators conclude that Greenlight had done nothing wrong; (4) attempted to intimidate others from publishing Greenlight's criticisms; and (5) attempted to purchase large amounts of their own stock in an effort to "squeeze" Greenlight's short position. By requiring short sellers to disclose their identities and their entire short portfolio every day on the Form SH, the SEC is greatly increasing the opportunity for issuers to target and "See SEC Litigation Release No. 18118 (April 28,2003), available at t r e 18.11ttnl (announcing settlement of research analyst conflict of interest h t ~ ~ : ~ : ' s c c . ~ o ~ ~ i l i t i ~ ~ ~ t i o n ' l i18 1 1 e a s e i L investigations with ten Wall Street investment banks). As the SEC discovered, several of these investment banks had tied the compensation of their research analysts to the analysts' success in generating investment banking revenue from public companies. Id. 27 See, e.g., Lamont, supra note 23 (noting approximately 250 instances in which issuers used extreme measures, such as false public statements, litigation or threats of litigation, to retaliate against short sellers). 28 See Heidi N. Moore, "If You Can't Save the Stock, Blame the Shorts," WALL ST. J., November 20, 2008, available at 1~tt~~:~~bIo~s.\i~sjicoi~~~deals~2.OO8~1 li2Oicitigro~1p-if-vnu-cant-~e-the-stock-b~~~e-the-~h0~~~ (Citigroup); Joseph A. Giannone, "Morgan Stanley CEO blames rout on short sellers," REUTERS, September 18, 2008, available at http:i,'www.reuters.co~n~artic1c~banki1~~Fina1~cial~idSNl753S~8~200809 18 (Morgan Stanley); Andrew Ross Sorkin, Ed., "SEC Should Investigate Bear Collapse, JP Morgan CEO," N.Y. TIMES, July 8,2008, available at l1~tp:~ideall~c~c~li.blo~s.i1vti1nes.c01ni20O8iO7iO8~~ec-~110~1d-i1i~:e~(i~~te-bear-~o11ap~e-i~-n1or~a11-ceo (JP Morgan Chase and Bear Steams); Louise Story, "Tough Fight for Chief at Lehman," N.Y. TIMES, September 10, 1 I ;'birsinessj11 2008, available at h~~~:~.'~~~v~v.nvti1~1es.c0111~20OX:O9fuld.11tml(Lehman). As Greenlight directly experienced, some of these efforts to attack short sellers have extended beyond public statements to direct manipulation of its own stock price. See supra at Section I(B) and n. 15 and n.16. AKIN G U M P S T R A U S S H A U E R & FELDLLP Attorneys at Law Florence E. Harmon December 16,2008 Page 10 retaliate against short sellers. The SEC should not adopt a Rule that can be used to marginalize, intimidate, and harass legitimate investors. 1. 11 THERULEDOESNOT PREVENT MANIPULATIVE SHORT SALES ACCOMPLISH OR ANY OTHERREGULATORYPURPOSE The SEC issued the Rule to address "possible unnecessary or artificial price movements that may be based on unfounded rumors and may be exacerbated by short selling."29 But the Rule will not in any way eliminate the source of the manipulation that the SEC claims was responsible for the recent market downtown - specifically, the "unfounded rumors" that the SEC claims led to the "artificial" price movements. The Rule does not target or impact the spreading of false rumors. In other words, even if rumors were the cause of the market collapse, which they were not,30and the Rule had been in place at the beginning of this year, it would have done nothing to prevent the downturn. As the SEC and the courts have repeatedly acknowledged, short selling in itself is not manipulative.3' Although a short position can be part of a manipulative strategy, any otherwise legitimate market activity - including the taking of a long position - can serve the same reprehensible purpose. Short sales are no more likely to serve as the basis of market manipulation than any other market activity. Nor does the Rule assist the SEC's efforts to combat market manipulation in general. To begin with, the SEC already possesses a formidable arsenal of weapons in the fight against manipulation, whether through short sales or any other method. Short sales are subject to all of the manipulation/fraud provisions of the securities laws, including Sections 9 and 10(b) of the ~' Exchange ~ c t , Sections 17(a) and 17(b) of the Securities Act of 1933 (the "Securities A C ~ " ) , ~ ~ 29 See Rule, supra note 1, at 8. 30 Similar to its conflation of manipulation based on unfounded rumors and short selling generally, the SEC has conflated its concerns about unfounded rumors and naked short-selling. These are two separate topics and the SEC has failed to show any evidence of an actual connection between them. 31 See supra at Section I(A) and (B); see also ATSI Commc'ns, Inc. v. Stiaar Fund, Ltd., 493 F.3d 87, 101 (2d Cir. 2007) ("short selling - even in high volumes - is not, by itself, manipulative"); GFL Advantage Fund v. Colkitt, 272 F.3d 189,211 (3d Cir. 2001) ("short selling is lawful, and courts have held that short selling, even in massive volume, is neither deceptive nor manipulative when carried out in accordance with SEC rules and regulations"); Sullivan &Long, Inc. v. Scattered Corp., 47 F.3d 857, 860 (7th Cir. 1995) (persons who engage in short sales "bet on a declining market, trusting that they have better information or better instincts than other traders"). 3' 15 U.S.C. $9 78i & 78j(b). AKIN G U M P S T R A U S S H A U E R & FELDLLP Attorneys at Law Florence E. Harmon December 16,2008 Page 11 and - if the investment manager is registered under the Investment Advisers Act of 1940 - Section 206(4) thereof.34 The SEC also recently issued Rule lob-21, which specifically targets fraud through "naked" short selling.35 The SEC claims that Form SHs will "provide useful information to the staff to analyze the effects of our rulemakings relating to short sales and in evaluating whether our current rules are working as intended...."36 We are not sure what the SEC means by this. If the SEC had hoped its various restrictions on short sales would somehow stabilize the markets, then the available data strongly suggest that the SEC's rules actually had the opposite effect. As noted above, the market experienced its most violent correction during the period when the SEC temporarily banned trading in financial stocks.37 Moreover, the evidence shows that the SEC's prior July 15, 2008 order (requiring anyone shorting certain securities to pre-borrow and deliver such securities at settlement) had the same negative effect on the securities markets.18 Enacting a more permanent rule to assess the efficacy of similar previous interim rules is simply circular. If the SEC seeks simply to collect data relating to short sales, whatever the purpose, we respectfully submit that such a purpose is insufficient to justify the Rule. Under normal circumstances, any intrusive regulation instituted for the purpose of collecting data, without an immediate tangible benefit to our securities markets, should be very carefully considered. But such a regulation is completely inappropriate today, when investors in the securities markets are hard-pressed even without the imposition of additional, unnecessary regulation. Moreover, the SEC can access data regarding short selling from several other sources without imposing such a burden on investment managers: Both the New York Stock Exchange and NASDAQ keep detailed records regarding short positions in securities traded on their exchanges, based upon information " 15 U.S.C. g 77q(a)-(b). " 15 U.S.C. # 80b-6. 35 Emergency Order Pursuant to Section 12(k)(2) of the Securities Exchange Act of 1934 Taking Temporary Action to Respond to Market Developments, SEC Exchange Act Release No. 58572 (September 17, 2008). 36 See Rule, supra note 1, at 8. 37 See suprn at Section I(A). " See Arturo Bris, Short Selling Activity in Financial Stocks and the SEC July 15th Emergency Order, August 12, 2008, available at http:i, \v\vw.~md.ch'i~ewsupload/Repoi-t.l~df AKIN GUMP STRAUSS HAUER & FELDLLP Attorneys at Law Florence E. Harmon December 16,2008 Page 12 submitted to them by all member organizations.39 Both exchanges publish semi- monthly reports describing the short interest overall as well as short interest in individual securities, both at the end of the period and on an average daily basis." Many institutional investment managers are registered under the Investment Advisers Act, and are therefore already required to keep substantial books and records, including records of all securities transaction^.^' Moreover, even those managers who are exempt from registration under the Investment Advisers Act still keep records of all transactions for years.42 Broker-dealers are required to keep complete records of all securities transactions and positions, including short positions, for a period of three years pursuant to SEC Rule 17a-3.43The SEC could easily audit or review such existing records from prime brokers (including details regarding which funds are shorting a particular security under investigation by the SEC for potential manipulation), rather than generating a new rule requiring redundant disclosure. IV. THESEC'S FAILUREO OFFER N FACTUALASIS THE RULECAUSESHE RULE T AY B FOR T TO BE ARBITRARYND CAPRICIOUS A For the reasons stated above, the SEC lacks any legal authority to issue the Rule. Any rule promulgated by the SEC must be supported by substantial evidence, may not be in excess of statutory authority, and may not be arbitrary and capricious.44 In other words, the agency action must be supported by substantial evidence,45and be rationally related to the ultimate factual 39 See, e.g.,N.Y.S.E. Rule 421 (requiring all member organizationsto submit periodic reports "with respect to.. . short positions in securities"). 40 These reports are available to the public for a fee. See, e.g.,NYSE Short Interest, available at http:ilwww.t1yxdata.con1Ji1yseciatai'default.aspx?tabid=748. 4' 17 C.F.R. # 275.204-2. 42 They do so for a variety of reasons, including (1) to allow their investors, often sophisticated funds or institutional investors, to conduct necessary due diligence; (2) because their investors and auditors require them to do so; and (3) so that they can confirm transactions and short or long positions with counterparties, broker-dealers and the exchanges. 43 17 C.F.R. 9; 240.17a-3. 44 5 U.S.C. 9; 706. 45 Hagelin v. FEC, 41 1 F.3d 237, 242 (D.C. Cir. 2005). AKIN GUMP S T R A U S S H A U E R & FELDLLP Attorneys at Law Florence E. Harmon December 16,2008 Page 13 findings of the agency.46 Evidence utilized by the agency that does nothing more than create a suspicion upon which the agency's action is based is insufficient to support valid agency action.47 An agency's speculation is also insufficient evidence to support valid r ~ l e m a k i n ~ . ~ * The SEC's failure to provide any factual basis for the Rule falls far short of the "substantial evidence" necessary to justify the Rule. Although the SEC claims that the Rule will prevent manipulative short sales, the SEC cites no evidence supporting its claim. In fact, for the reasons stated above, the Rule not only would fail to prevent manipulation, but would actually have a manipulative effect on the market by artificially reducing short selling.49 In the end, the SEC cites to nothing more than its unsupported "concern" that short selling "may" be disrupting the orderly functioning of the markets. Mere concern, suspicion, or speculation is not enough to support this type of regulatory action.50 Furthermore, the proposed Rule also conflicts with Section 13(f) of the Exchange Act, which clearly evinces Congress's decision to limit the SEC's authority to require disclosure by institutional investment managers. Section 13(0 provides the Commission with authority to require institutional investment managers to "file reports with the Commission in such form, for such purposes, for such periods, and at such times after the end of such periods as the Commission, by rule, may prescribe."5' Section 13(f) states, however, that "in no event shall such reports be filed for periods longer than one year or shorter than one quarter."52 46 Motor VehicleMfrs. Ass'n v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29,43 (1983). 47 Hoxie v. DEA, 419 F.3d 477,482 (6th Cir. 2005). 48 Corrosion ProofFittings v. EPA, 947 F.2d 1201, 1227 (5th Cir. 1991). 49 See supra at Section II(A) and (B). See, e.g., Hoxie, 4 19 F.3d at 482; New Valley Corp. v. Gilliam, 192 F.3d 150, 156 (D.C. Cir. 1999); Corrosion Proof Fittings v. EPA, 947 F.2d 1201, 1227 (5th Cir. 1991). 51 15 U.S.C. $ 78m(f)(l). 52 Id. (emphasis added). For the same reason, the suggestion made by a prior commenter that the Rule merely equalizes the filing requirements between investors who take short and long positions is incorrect. Form 13Fs are filed only once per quarter, are not due until 45 days after the calendar quarter has ended, and require only information about holdings as of the end of the quarterly period, not daily positional information. 17 C.F.R. $ 240.13f-1. AKIN GUMP STRAUSS HAUER & FELDLLP Anorneys at Law Florence E. Harmon December 16,2008 Page 14 In doing so, Congress clearly intended that institutional investment managers not be required to report more frequently than on a quarterly basis.53 Both Congress and the SEC expended substantial time and energy to determine the impact of Section 13(f)prior to its passage, a fact that should inform the SEC's effort to shape disclosure requirements for short sales. Prior to passing Section 13(f), Congress charged the SEC with the responsibility to "consider the cost and burden to such smaller institutional investment managers of preparing such reports."54 The SEC did so, and after reviewing extensive comments from numerous concerned parties, ultimately decided upon a quarterly reporting requirement because "requiring the filing of Form 13F on a quarterly basis will not significantly burden competition."55 The Rule, which was not preceded by any comprehensive study or examination, obliterates the careful balance struck by Congress and the SEC through Section 13(f). The SEC apparently recognizes this conflict, because - unlike its previous emergency orders, which specifically relied upon Section 13(f)- the Rule does not specifically cite to Section 13(f) as a basis for its authority. But the Commission may not overrule Congress through omission. Instead, each section of the Exchange Act must be read in light of the other sections of the Exchange Act to give effect to the true meaning of the overall statutory scheme.56 Any statute conferring general rulemaking authority on the SEC must yield to the specific limitation on such reporting contained in Section 13(f).57 Moreover, Congress instituted Section 13(f) of the Securities Act largely out of concern that institutional investors were talung increasingly large ownership positions in public companies, which in turn implicated corporate governance issues and the voting and ownership rights of other investors.58 Congress therefore required institutional investors to publicly 53 See S. REP. 94-75, at 86-87 (1975) ("It is expected that the Commission would require by rule that NO. institutional investment managers file reports quarterly.. .."). 54 Id. at *86. 55 Filing and Reporting Requirements Relating to Institutional Investment Managers, SEC Exchange Act Release No. 15461, January 5, 1979, available at 11ttp:i~sec.~ov!1ules/final~34- 1 .pdf. 1546 56 See Flu. Dep't ofRevenue v. Piccadilly Cafeterias, Inc., 128 S. Ct. 2326,2335 (2008) (quoting Davis v. Michigan Dep't of Treasury, 489 U.S. 803, 809 (1989) ("It is a fundamental canon of statutory construction that the words of a statute must be read in their context and with a view to their place in the overall statutory scheme.")). 57 See Gonzales v. Oregon, 546 U.S. 243,262-263 (2006) ("In light of these specific grants of * * * authority, we are unwilling to construe the ambiguous provisions.. . to serve this purpose [of creating further authority].") (brackets in original) (quoting Federal Maritime Comm 'n v. Seatrain Lines, Inc., 41 1 U.S. 726,744 (1973)). 58 S. REP. NO. 94-75, at 78-79 (1975). AKIN G U M P S T R A U S S HAUER & FELDLLP Altorneys at Law Florence E. Harmon December 16,2008 Page 15 disclose their ownership positions, so that the investing public could use information about institutional investors' holdings in making their own investment decisions.59 Short sales do not implicate any such concern. In short, the Rule is both unsupported by any factual evidence, thus rendering it arbitrary and capricious, and exceeds the SEC's authority to issue disclosure requirements under the Exchange Act. Such ill-considered rules will not withstand later scrutiny.60 V. ALTERNATIVE THE DISCLOSURE PROPOSED TO RULE For the reasons stated above, we believe that a rule requiring disclosure of short positions is neither necessary nor helpful, either to the SEC or to our securities markets, and exceeds the SEC's legal authority. However, if the SEC determines that some recordkeeping requirement is in fact necessary, we propose the following alternative to the Rule, which will minimize the burden to institutional investment managers, while retaining records that may assist in any subsequent anti-fraud investigation without impacting legitimate short selling in general. As noted above, many institutional investment managers currently retain complete records of their securities transactions going back several years, either because they are registered under the Investment Advisers ~ c tor because they voluntarily keep such records. ~ ' The SEC could require all investors to retain relevant records of short transactions, including locates and borrows, for a minimum of three years. The SEC could then review such records when appropriate or necessary for investigative purposes even though, as previously noted, such records exist and are currently available to the SEC through the recordkeeping requirements of the regulated broker dealers that act as prime brokers to such short sellers. We believe that this alternative is far less burdensome to investment managers, while still accomplishing the same purposes for which the Rule was intended. This alternative would eliminate the necessity and cost of preparing voluminous and repetitive filings and would minimize the risk of public disclosure of the information. To the extent the SEC believes that disclosure of short positions will discourage abusive short selling, having to retain such records 59 Id. at 82-83. 60 See United States v. Mead Corp., 533 U.S. 218, 227 (2001) (noting that courts will not defer to agency rules that are "arbitrary or capricious in substance," or "contrary to the statute.") '' See 17 C.F.R. $275.204-2. AKIN GUMP S T R A U S S HAUER & FELDLLP Attorneys a1 Law Florence E. Harmon December 16,2008 Page 16 would be an equally effective deterrent when combined with the knowledge that the SEC could request those records at any time.62 Only two years ago, in a statement to the United States Senate, current SEC Chairman Christopher Cox publicly counseled against exactly the type of regulation now proposed by the SEC: As a general principle, which I would apply both to the Commission's future regulatory actions in this area as well as to any potential legislation, I would counsel that to the maximum extent possible our actions should be non-intrusive. There should be no interference with the investment strategies or operations of hedge funds, including their use of derivatives trading, leverage, and short selling. Nor should the federal government trammel upon their creativity, their liquidity, or their flexibility. The costs of any regulation should be kept firmly in mind. Similarly, there should be no portfolio disclosure provisions. A hedge fund's ability to keep confidential its trading strategies and portfolio composition should be protected.63 The Chairman's words apply with particular force now, when the securities markets are struggling to regain their footing even in the absence of unnecessary and burdensome new regulation. Although we understand the reasons why the SEC issued the Rule, we believe the Rule itself does not further those goals and merely places substantial burdens on investors. We hope that the above comments are helpful in shaping the SEC7sdecision on whether to withdraw or amend the Rule. We would welcome the opportunity to further discuss these issues with the SEC. 62 This suggestion is somewhat similar to the SEC's suggestion that short sellers be subject to the Rule 17a- 3. 17 C.F.R. 9 240.17a-3(5). However, we do not believe that the more extensive recordkeeping required by Rule 17a-3 makes sense in this situation. If any new disclosure requirement is imposed, which it should not be, the disclosure currently required under Rule 13F is more than sufficient. 63 The Regulation of Hedge Funds: Hearing Before the S. Comm. on Banking, Housing and Urban Affairs, 109th Cong. (2006) (testimony of Christopher Cox, Chairman, Sec. and Exch. Cornm'n), available at http:!~sec.~ov~rie~~s~testin1o~1~~i2006~~~07250hc~.hti1~. AKIN GUMP S T R A U S S H A U E R & FELDLLP Attorneys at Law Florence E. Harmon December 16,2008 Page 17 Yours truly, cc: The Honorable Christopher Cox, Chairman The Honorable Kathleen L. Casey The Honorable Elisse B. Walter The Honorable Luis A. Aguilar The Honorable Troy A. Paredes Erik R. Sirri, Director Division of Trading and Markets Andrew J. Donohue, Director Division of Investment Management
Pages to are hidden for
"AKIN GUMP STRAUSS HAUER"Please download to view full document


text:
The scissors scene cements it: Drew Barrymore can really act, and this is the role that will make people notice.
As Lauber, his eyes filling with tears, screamed for help, Romney repeatedly clipped his hair with a pair of scissors.
It seems pretty hard to believe that a person wouldn't remember pinning someone down and taking a scissors to his hair.
late 14c., sisoures, from Old French cisoires (plural) "shears," from Vulgar Latin *cisoria (plural) "cutting instrument," from *cisus (in compounds such as Latin excisus, past participle of excidere "to cut out"), ultimately from Latin caedere "to cut" (see -cide). Spelling with sc- is 16c., from influence of Medieval Latin scissor "tailor," in classical Latin "carver, cutter," from past participle stem of scindere "to split."
Usually with pair of (attested from c.1400) when indication of just one is required, but a singular form without the -s occasionally was used (cysowre, mid-15c.). In Scotland, shears answers for all sizes, according to OED; but in England generally that word is used only for those too large to be worked by one hand. Sense in wrestling is from 1904. Oh scissors! was a 19c. exclamation of impatience or disgust (1843). In reference to a type of swimming kick, from 1902 (the image itself is from 1880s).
1610s, "to cut with scissors;" 1961 with reference to leg motions (in the wrestling sense it is attested from 1968); see scissors. Related: Scissored; scissoring.

subset: commoncrawl


text:
Here's where you can play any of the audio or video files available in our podcasting directory. Simply select a podcast Category below, then a program Title. The file will begin playing immediately. Enjoy!
|The Gene Valicenti Show
|465 episodes available
|1 episodes available
|The John DePetro Show
|161 episodes available
|The Dan Yorke Show
|195 episodes available
|The Buddy Cianci Show
|424 episodes available
|The Matt Allen Show
|155 episodes available
|Dan Yorke Endorsements
|12 episodes available
|John DePetro Endorsements
|7 episodes available
|Matt Allen Endorsements
|11 episodes available
|Morning Show Endorsements
|3 episodes available
|Buddy Cianci Endorsements
|42 episodes available
|RI Real Estate Insiders
|65 episodes available
|Tara Granahan Endorsements
|2 episodes available
|Tara Granahan
|24 episodes available
|Steve Klamkin
|72 episodes available
|Patricia Raskin
|3 episodes available
|Profiles with Patrick Austin
|4 episodes available
|RIIL BOYS DIVISIONAL and CREDIT UNION CHAMPIONSHIPS
|45 episodes available
|The John Loughlin Show
|62 episodes available
|Rhode Island Home & Life
|30 episodes available
|Weekend Shows
|39 episodes available
|Gene Valicenti's Tech Talk
|11 episodes available
|Benchwarmer's Podcast
|7 episodes available
|Cranston City Councilman Blasts Mayor Fung (10:59)
|Caller tells EBT card story (1:58)
|Brother Gary compares RI State name to Confederate Flag (7:21)
|John DePetro Birthday Show w/ Walter Miller & Ann (16:33)
|Debra Messing at the Pell Awards with K. DePetro (1:34)
|Ken Block & Fire Fighter Costs in RI (13:07)
|Ken Block Criticizes Speaker Mattiello (8:18)
|RIPTA Legal says "Case Closed" (5:08)
|JD talks with Camille Kostek from Benrus (27:31)
|JD talks with author Stephen Kurkjian (30:34)
|John DePetro talks with Brother Gary (live in studio) (14:25)
|Miss Rhode Island World - Amara Berry (IN-STUDIO) (10:09)
|JD discusses Hernandez trial with Attorney Lou Pulner (10:27)
|Warwick man left homeless after Warwick condo fire (16:05)
|Ken Block speaks out on excessive fire costs in RI (30:10)
|Rep speaks out on Gordon Fox corruption (4:37)
|Lou Pulner explains Gordon Fox charges (10:18)
|Rep Patricia Morgan discusses bills on fraud (8:59)
|Joe Paolino discusses snow problems in Providence (6:03)
|Ruth tells John about the DJ with the "pointed hat" (2:49)
|Boston Globe National Reporter talks with JD about Iowa (5:29)
|John DePetro talks with former NFL star Matt Light (4:37)
|John DePetro talks with rock legend John Cafferty (36:20)
|Caller describes wearing socks over shoes (2:00)
|JD talks with Acting coach & Author Howard Fine (26:25)
|John DePetro talks with Ned Kemble (15:06)
|John talks with State Representative Patricia Morgan (15:09)
|JD disagrees with Immigration advocate (9:23)
|Crazy Time - November 14th, 2014 (3:45)
|Rep Morgan calls for Union President to Resign (5:05)
|JD talks with Gene Valicenti @ the Veterans Day Parade (11:13)
|Arlene the smoker says her car don't stink (4:09)
|Crazy Time on The John DePetro Show (3:30)
|FBI Ready for Election Day (4:07)
|Buddy Cianci says bring the "Pride" back (31:02)
|Fung strikes back at Gina on Central Falls jab (3:14)
|Brown Poll Shows Raimondo Losing Democrat Support (12:43)
|JD gets a flu shot from Dr Fine (live on the air) (4:56)
|JD talks with Congressional Candidate Cormick Lynch (7:24)
|Republican Dan Harrop In-Studio on the Mayoral Race (34:59)
|Bob Healey explains "sniffling" during the debate (4:46)
|JD talks with a Liberian living in Rhode Island (4:11)
|Bishop Tobin talks voting (13:06)
|JD talks with Liberian Community President about Ebola (9:24)
|JD talks with RI D.O.H. about Ebola (5:43)
|JD talks with Ann from Cranston (4:01)
|JD talks with Arlene Violet (13:09)
|John DePetro has fun with a "Hip" Doctor (5:33)
|JD talks with Bob Healey about running for Governor (34:08)
|JD talks with Cranston Mayor Allan Fung (9:51)
|JD talks with Juan Garcia about illegals & licenses (4:44)
|Caller discusses "Race" with guest Brother Gary (1:26)
|JD talks with Dr Daniel Harrop (12:29)
|Jim Vincent - Providence branch of the NAACP (5:32)
|JD talks with a caller who supports the protesters (12:07)
|JD talks with Kara Sundlun (17:20)
|JD talks with Congressman Peter King (R-NY) (11:53)
|JD talks with Kathy Staab (Jane Pickens Theatre) (6:00)
|JD talks with Denise from the Samaritans of RI (4:33)
|JD talks with Author Marc Songini (33:25)
|Crazy Time - Friday, August 8th, 2014 (4:44)
|3 Dollar Bar owner speaks out (39:00)
|John DePetro talks with Bill Cosby (12:21)
|JD talks with Lou Pulner about the RI Beach controversy (9:51)
|Restaurant owner on Federal Hill speaks out (4:13)
|JD talks with John Carlevale (15:32)
|JD talks with author Ed Klein (11:22)
|Mark Zaccaria running against Senator Reed (15:41)
|Luis Vargas running for RI State Rep seat (15:25)
|John Wins Best Radio Talk Show 2014 (7:30)
|Dan Reilly Challenging Linda Fin for State House of Rep (19:03)
|Mike Smith Challenging Paiva-Weed for Senate (14:39)
|Red White & Blue Statehouse Salute (1:05)
|Crazy Time with John DePetro (2:12)
|JD talks with Courtenay Petracca (5:07)
|JD talks with Juan Garcia (8:00)
|John Robitaille Speaks on Republic Primary Season (31:51)
|Funny phone call from Joan in West Warwick (0:51)
|Controversy at the Ocean Mist in Matunuck (10:02)
|Homeless man living in car yells at John DePetro (16:58)
|JD discusses the latest poll #'s with Joe Fleming (10:36)


text:
Search results for invertebrates - terrestrial and freshwater – by date
Slender skimmer (Orthetrum sabina)
The slender skimmer (Orthetrum sabina) is a striking green to greyish-yellow dragonfly with black…
More about the Slender skimmer »
0 videos
Rose chafer (Cetonia aurata)
This beautiful iridescent beetle can occur in a variety of colours; the wingcases or elytra are…
Red admiral (Vanessa atalanta)
The red admiral (Vanessa atalanta) is a familiar butterfly, and is easy to identify thanks to its…
Hornet robberfly (Asilus crabroniformis)
This fearsome looking fly, large and giving every appearance of aggression is, nonetheless…
Heath tiger beetle (Cicindela sylvatica)
Cicindela sylvatica is the largest tiger beetle . It is bluish-black in colour, with a bronze sheen…
Painted lady (Vanessa cardui)
The beautiful painted lady butterfly is a long-distance migratory species, and is easily recognised…
Burying beetle (Nicrophorus vespillo)
Information on the burying beetle (Nicrophorus vespillo) is currently being researched and written…
More about the Burying beetle »
0 videos
Pearl-bordered fritillary (Boloria euphrosyne)
The pearl-bordered fritillary is pale orange brown in colour with black spots. The underside is…
Common striped woodlouse (Philoscia muscorum)
Woodlice are not insects, but are crustaceans; more closely related to crabs and shrimps than…
More about the Common striped woodlouse »
0 videos
Great diving beetle (Dytiscus marginalis)
The great diving beetle (Dytiscus marginalis) is, as the name suggests, a large aquatic beetle . It…
Large copper butterfly (Lycaena dispar)
The large copper butterfly (Lycaena dispar) has wings of a bright coppery-orange, fringed with black…
Weevil (Melanapion minimum)
This small black weevil has a ridged back, but otherwise has the classic 'weevil' shape, with an…
0 videos
Violet dropwing (Trithemis annulata)
The violet dropwing (Trithemis annulata) is a distinctive dragonfly that is well known for its…
More about the Violet dropwing »
0 videos
Toadflax brocade moth (Calophasia lunula)
Adult Toadflax Brocade moths are whitish-grey in colour with bluish-black markings , and are usually…
More about the Toadflax brocade moth »
0 videos
Karwar large burrowing spider (Thrigmopoeus truculentus)
Information on the Karwar large burrowing spider is being researched and written and will appear…
More about the Karwar large burrowing spider »
0 videos


text:
Cheungs Star Wall Décor
Special Offer:
12 Issues of Money Magazine
Included with purchase ($20 value).
Cheungs Star Wall Décor
Weights & Dimensions
|Subject: Abstract and geometric
|Style: Modern
|Finish: Green, Orange
|Distressed: No
|Handmade: Yes
|Primary Material: Metal
|Number of Items Included: 1
|Fasteners Included: Yes
|Wall Hook: Yes
|Outdoor Use: No
|Commercial Use: Yes
|Eco-Friendly: No
|Product Care: Wipe clean with a damp cloth
|Country of Manufacture: China
|Assembly Required: No
|Installation Required: Yes
|Product Warranty: 30 Day Manufacturer's Warranty
About the ManufacturerAfter two generations of decor and accent furniture manufacturing, Spencer Cheung founded Cheungs Imports in 1979, and it is still 100% owned by the Cheung family.
Cheungs Star Wall Décor
Customer Reviews
Tell Us What You Think!
Tell us what you think about this product. It will help us provide you with better products in the future and help your fellow shoppers make better purchases.Write the first review
OUR SKU # HEU1165Star Wall Décor is also sometimes listed under the following manufacturer numbers: FP-2579


text:
Top Definition
and southern way of saying terror threat.
When Pimp C went HAM on the hot 97.9 DJ because she wanted him to open at a concert for Baby and Lil Wayne....he said she called his P.O. and said that he TERRORISTICALLY Thredded Hur...Ya Dig!!!!!!!
by Shadi Ladi October 19, 2010


text:
Flight Update - Live Flight Status
By Silverware Software, LLC
Open iTunes to buy and download apps.
Flight Update is the MOST POWERFUL app for flight tracking! Enjoy the best flight tracking service combined with the best flight scheduling service in an easy to use and elegant app. *Get real-time Worldwide flight status At-a-Glance.
Christmas 2013 - Apple App Store - Travel Survival Kit
Use the app Hollywood stars use to track their loved ones'. Read all about it at: www.tinyurl.com/GwynethUsesFlightUpdate
June 24, 2011 - Chosen BEST Summer App by thaw www.tinyurl.com/BestSummerApps
October, 2010 - Pro version chosen BEST APP for Flight Tracking in the new book "Best iPhone Apps" www.tinyurl.com/bestFlightApp
Every airline traveler needs the most up-to-date information about their flight. Flight Update provides you with that by bringing you timely flight status information via the award winning FlightStats flight service. Best of all, its easy to use and packed with useful AND fun features for every traveler. We have full international coverage for worldwide flights!
To use Flight Update, all you need to do is select an airline, flight number and date of travel. Flight Update does the rest. It will validate each flight and then auto-fill all of the remaining information about your flight, regardless if the flight is one day, one month or even one year in advance.
KEY features include:
* Real-time flight status for gates, delays and cancellations using FlightStats (rated #1 by WSJ)
* Access to flights from over 1400 airlines covering US & International
* Worldwide coverage of more than 400 airports
* Find alternate flights with a tap
* Elegant and easy to use interface
ADVANCED features include:
* Concise display of layover times between your connecting flights
* Quickly check a single flight using the InstaFlight feature
* Calendar Mirroring with the built-in Calendar (customizable)
* View current weather, forecasts and airport delays
* Display key phone numbers and websites for airlines
* Search for alternates to a flight that was cancelled or one you might have missed
* Search for direct flights between cities to plan future flights
* View the SeatGuru seating chart of your aircraft
* Quickly email your itinerary and a message using the Quick Email feature
* Email your complete trip's flight itinerary (not just a flight at a time)
* Organize your flights into separate "Trips"
* Store your seat assignments
FUN Features include :
* Zoomable maps track flights as they travel across the country (US based flights only)
* Follow a flight's altitude, direction, speed and the city it is flying over. (US flights only)
* Track the incoming aircraft to your departing gate (then watch it pull up to the gate just as you expected).
* Save all of your favorite airlines for future use
* What Accolades has Flight Update received? Here's an abbreviated list of awards:
* Chosen one of "50 Apps You Need" and best flight status application by Laptop Magazine.
* Voted to be one of the "100 Essential iPhone Apps" by iLounge.com
* "Flight Update is among my top 5 iPhone apps" says tuaw.com
* "First class flight tracking with Flight Update" says ZDNet
* Rated Best Airline Flight Tracker on apparea.com
* Featured in App Store's 2009 Holiday Travel section
* Pro version chosen one of the best apps of 2009 by Apple
Are you a frequent flyer or demand even more convenience? Check out FLIGHT UPDATE PRO. This app adds the ability to link with TripIt, a free online service which you can simply email your flight confirmation emails and it will then build an online itinerary. This itinerary can then be downloaded directly to Flight Update Pro. You do not need to enter a stitch of information, your details instantly fill into Flight Update Pro for you.
Questions/comments? For a fast reply, email us at email@example.com
What's New in Version 6.02
* Minor bug fix
Customer Reviews
Downhill lately
Have had this app for around 5 years, and it used to be pretty nice, but lately patches make it worse.
An example is when looking at flight history it defaults to your oldest flight instead of recent flights and there is no way to change it. Pretty sure most folks would want to look at most recent flights the majority of the time and not the oldest.
Worst and becoming unacceptable is that some flights that I add crash when trying to look at their details. Same flights crash if you try to use instant status. Program completely crashes. I am about done with it and going to look for another app.
Just What I Need
I've had this app for years and tried several others. Although others may have more bells and whistles, I'm just an occasional traveller, and Flight Update has just what I need to save information for different flights. I've had a few hiccups with this app over the years, but it seems to be pretty stable now and offers a lot of good features. I'm sticking with this one!
Great App
This is a great application. I use it to track flights for all of the people who were coming in and out of town. It has been accurate to within minutes actual flight data. Weather delays also show. I love the live in-flight updates maps to track flights in progress.
- $4.99
- Category: Travel
- Updated: Nov 19, 2014
- Version: 6.02
- Size: 4.0 MB
- Language: English
- Seller: Silverware Software, LLC
- © 2008-2014. Silverware Software
Compatibility: Requires iOS 6.1 or later. Compatible with iPhone, iPad, and iPod touch. This app is optimized for iPhone 5.
Top In-App Purchases
- Flight Update upgrade$5.99


text:
Search Results For "Kasabian"
kasabian - Switchblade Smiles
Substance is meaningless Follow "By Sigrid Huber Bawling. Beer. Bold Heads. Bursting atmosphere. There are only a few bands still out there that have…" Posted on Dec 9th, 2014 →
Kasabian - Eez- Eh
Minored In MusicFollow "L: Kasabian - "Eez-Eh" Mm, this is kind of hot, Kasabian. It speaks to me in a way Chromeo kind…" Posted on Oct 22nd, 2014 →
Kasabian - stevie
surviving the golden ageFollow "Passenger "27" Passenger's latest single is "27" which features with all the things running through his 27 year old mind.…" Posted on Oct 17th, 2014 →
Kasabian - Bumblebee
We All Want Someone To Shout ForFollow "Remember when thee free iTunes single of the week meant something? Well, back in 2004 it did. As a young,…" Posted on Sep 29th, 2014 →
Kasabian - Sesame Street Good Vibrations Mashup
Music From Go to WhoaFollow "http://fbiradio.com/wp-content/uploads/12-Tais1.mp3 Oxen Calm Having had a good run of 7+ years blogging my favorite music, I've decided that it's time…" Posted on Sep 8th, 2014 →
Kasabian - Sesame Street Good Vibrations
repeatbuttonFollow "A bit of kookiness for you now on Repeat Button. UK rock band, Kasabian, were on Triple J recently and…" Posted on Aug 18th, 2014 →
Kasabian - Velociraptor!
The 'SpillFollow "Download: 11-cobra-movement.mp3 Download: 08-tricky-turtle.mp3 Download: 05-snakes.mp3 Download: 01-snake.mp3 Download: 01-turtle-bonobo-mix.mp3 Download: 10-chameleon.mp3 Download: 01-turtles-have-short-legs.mp3 Download: 08-the-reptiles-and-i.mp3 Downlo" Posted on Mar 19th, 2014 →
Kasabian - Club Foot
Indie ShuffleFollow "Watching soccer players like Lionel Messi and Cristiano Ronaldo do their thing on the field is truly a thing of…" Posted on Mar 12th, 2013 →
Kasabian - Re-wired
Frequenze IndipendentiFollow "- Frequenze 2012 Radio Playlist - Un tempo si sarebbe chiamata Frequenze Chart. Oggi non è più esattamente una classifica.…" Posted on Dec 30th, 2012 →
Kasabian - Days Are Forgotten +2 remixes
One A DayFollow "Somehow, in the midst of everything, the hype and the excitement and the Facebook and the Global Financial Crisis and…" Posted on Sep 7th, 2012 →
Kasabian - Reason Is Treason
out the other...Follow "Okay, I think it's about time I revive this feature... and actually revisit it on a weekly basis. Now that…" Posted on Apr 7th, 2008 →
Kasabian - Days Are Forgotten KOAN Sound Remix +1 more
Your Music RadarFollow "A fresh mix for you hot off the press from Koan Sound! This one's of the track 'Days Are Forgotten'…" Posted on Apr 16th, 2012 →
Kasabian - Bruises, Fire
TonegentsFollow "Today it's about crusty old British geezers vs. shiny new black rappers... First, representing the geezers, we have punk legends…" Posted on Mar 8th, 2012 →
Kasabian - Video Games (Lana Del Rey) Live on BBC1
Music From Go to WhoaFollow "Lana performed her hit song, "Video Games" on the Jonathan Ross Show, with special lighting to make it even more…" Posted on Jan 8th, 2012 →
Kasabian - I'm So Tired (The Beatles cover)
The 405Follow "Mix/Cover/Live #548 (feat. The Morning Clouds & more) Today's Mix/Cover/Live includes The Beatles, The National and The Morning Clouds. Remix…" Posted on Nov 4th, 2011 →
Kasabian - Video Games (Lana Del Rey cover) (BBC Radio 1 Live Lounge)
AudioPorn CentralFollow " Kasabian – Video Games Lana Del Rey cover Kasabian recently covered Lana Del Rey's song Video Games as part of…" Posted on Oct 29th, 2011 →
Kasabian - Too Much Too Young (Specials cover)
Town Full of LosersFollow "A preview of the second episode of the new series of Later with Jools Holland." Posted on Sep 27th, 2011 →
Kasabian - La Fee Verte
And Everyones A DJFollow "Tracklisting 1. Hunx & His Punx – Tonite Tonite 2. IceAge – New Brigade 3. Wild Flag – Glass Tambourine…" Posted on Sep 24th, 2011 →
Kasabian - natalie.cervelliLa Fee Verte
365 Days of MusicFollow "I have always really liked Kasabian. I saw them by accident a couple of years ago, and have since been…" Posted on Sep 22nd, 2011 →
Kasabian - Re-Wired (The Wunderstation Re-Work)
blahblahblahscienceFollow "wunderstation East LA electro collective The Wunderstation 're-wire' said track from Kasabian's forthcoming beast of an LP. You know what…" Posted on Sep 19th, 2011 →
Once a week, Stack delivers a mix of the most interesting new music on the web, handpicked by the Hype Machine team. Here's a recent mix.
We post good stuff on Twitter, Tumblr and Facebook. Follow us there.
We have awesome apps for the iPhone, Android, BlackBerry 10, and our friends have built an app for Windows Phone.
Check them out!
All information on this page is available in RSS and JSON formats for non-commercial, attributed use (CC) by developers.


text:
to explore
sign up (free!)
Related Pins
I find I am attracting and accepting the possibility of happy surprises and exciting experiences in my daily life. Order by Henning Ludvigsen
Wizard by boscopenciller.de... on deviantART
wizard - #fantasy #art (Artist unknown. If you know who painted this, please let me know so I can attribute the picture)
And Curunir, Saruman, fell from his high errand, and becoming proud and impatient and enamoured of power sought to have his own will by force, and to oust Sauron; but he was ensnared by that dark spirit, mightier than he.
"Kingdom Age - Mage" by Dustsplat (Deviantart) [ Mage - Wizard - Witch - Sorceress - Magic - Sorcery ]
Still cool, even if it is Merlin, aka Gandalf, aka Dumbledore, aka every wizard that pops in your head when you hear the word wizard ever. (If you say Harry or Harry I would suggest you admit to yourself that they are less iconic wizard and more typical hero.)


text:
News & Public Affairs
Interactive art exhibit gives voice to Polish children of WWII, and Indiana governor defends Religious Freedom Law listen03/31/15 Rob Lorei
MidPoint with WMNF News Tuesday Listen to this entire show:
Tags: Wojtek Sawa, Poland, WWII, The Wall Speak- Voices of the Unheard, Interactive Art, Multimedia, The Florida Holocaust Museum, Nazi Germnay, Soviet Union, Indiana, Religious Freedom Restoration Act, George Stephanopoulos, Mike Pence, LGBT, wmnf, Rob Lorei
Today on Radioactivity we talk with Wojtek Sawa, a Polish-born visual artist based out of Sarasota. Sawa is the the author of The Wall Speaks - Voices of the Unheard, an interactive multimedia exhibit currently on display at The Florida Holocaust Museum. The exhibit tells the story of the Polish experience of World War II, of a country that at one point was simultaneous besieged by Nazi Germany and the Soviet Union. Like many Polish families, Sawa's was personally affected by the war; His f...Be the first to comment
Interviews with Two Veterans: Former Congressman Sam Gibbons and Veterans for Peace Activist Dwight Lawton11/11/10 Robert Lorei
Radioactivity: Live Call-In (Thursday) Listen to this entire show:
Good afternoon. I'm Rob Lorei. It's Veteran's Day and today we have two interviews with former members of the US military.
First up retired Tampa Congressman Sam Gibbons who was a young paratrooper during D-Day in WWII.
Later we'll hear from Dwight Lawton of St. Petersburg. Lawton served on a US Navy destroyer in the early 1950's reaching the rank of lieutenant. For many years he's been active in peace and social justice causes- including as a leader with the group Veterans for Peace....Be the first to comment
- 2015
- 2014
- 2013
- 2012
- 2011
- 2010
- 2009
- 2008
- 2007
- 2006


text:
to page content
to site navigation
Explore the Entrepreneurship.org Resource Center to find resources. Designed with entrepreneurs in mind, our resource center allows you to find materials to grow great ideas.
Every marketing plan starts the same way: by defining the target customer. Only then can an entrepreneur figure out the best way to reach them. Naturally, different types of target customers, or audiences, require different media and campaigns -- referred to as a promotional mix -- to reach them most effectively and efficiently. This tool takes a look at some different types of promotional media, and discusses the pros and cons of effectively reaching a target audience through each.
This tool takes a look at different types of promotional media and discuss the pros and cons of effectively reaching a target audience through each.
The U.S. Trade and Development Agency (USTDA) advances economic development and U.S. commercial interests in developing and middle income countries. The agency funds various forms of technical assistance, early investment analysis, training, orientation visits and business workshops that support the development of a modern infrastructure and a fair and open trading environment
Agencia Federal para el desarollo de La Pequena Empresa
This link is itself a collection of useful links offering a wealth of information about managing products and services.
This article provides a general sequence of steps to follow for developing the pricing of a new product. A bonus is frequent links to references in connection with business terminology used in the article.
The following tool will guide you through the process of pricing your products and services, including conducting market research, reviewing pricing models, and determining if prices are profitable.
Regularly reviewing your business plan ensures that you meet the needs of a growing enterprise. This allows you to identify key growth areas that you want to target.
With recent changes in consumer shopping habits, many companies are adopting sales and marketing strategies that reflect a more personalized approach to servicing their customers. This tool focuses on personalization and on ways you can gear your business to provide products and services individualized to your customersand#39; tastes and needs.
The focus of this tool is to provide a general discussion concerning bringing in partners or outside investors to a company. The methods a business can use toward achieving this goal and the problems a business is likely to face in the process will also be addressed.
Want to get connected? Sign up to receive regular news, polls and updates from The Kauffman Foundation.
A robust online curriculum for entrepreneurs.
Explore Founders School >
A network of U.S. cities facilitating a weekly entrepreneur education program. Go to 1 Million Cups >
Whether you are starting or growing a company, FastTrac will help you live your dream at each stage.
Get started with FastTrac >


text:
About us
About WAGGGS
About Girl Guiding and Girl Scouting
|With ten million Girl Guides and Girl Scouts from 146 countries across the world, the World Association of Girl Guides and Girl Scouts (WAGGGS) is the largest voluntary movement dedicated to girls and young women in the world.
|Girl Guiding and Girl Scouting are open to all girls and young women whatever their religion, ethnic group or background. A Girl Guide or Girl Scout accepts the Promise and the Law based on spiritual values, personal development and commitment to helping others.
What we do
|The World Association of Girl Guides and Girl Scouts works with many national, regional and international organizations and alliances to further its mission to enable girls and young women to develop to their fullest potential and become responsible citizens of the world. It has partnered with the United Nations for over 60 years.
|Through its Member Organizations and through working directly with girls and young women, WAGGGS delivers high quality non-formal educational programmes and international opportunities that provide girls and young women dynamic, flexible and values-based training in life skills, leadership and citizenship.
Your expertise, skills, interests, life experience, and availability are needed! Without the commitment of the nearly 1.5 million volunteers around the world, Girl Guiding and Girl Scouting could not happen.
Your comments
View oldest comments first
Senaida - 29 January 2014 - 2.03AM (GMT)
Hi Im Senaida from USA. Im a brownie. Every year we do a world thinking day and this year my troop is going to New Zealand. Im excited to learn about the girls there.
Emma - 28 January 2014 - 12.13AM (GMT)
Hello guides and scouts! I am very excited to be doing the WAGGGS booth this year in Chicago IL this year!
Margaret - 23 January 2014 - 11.15PM (GMT)
I am in Cape Cod. I learned a lot about Bangladesh. I am in third grade.
Lakshini Senevirathne - 18 January 2014 - 5.21PM (GMT)
Hi, I'm Lakshini.I learnt lot of things as a guide. And I'm really proud to be a girl guide in 1st Sri Lanka Girl Guides Troop.
nileesha jayaweera - 15 December 2013 - 5.03AM (GMT)
I'm proud to be a girl guide!!!
Sruthi k s - 7 December 2013 - 3.06PM (GMT)
hai i am sruthi i am from kerala. i love all guides.
SRUTHI K S - 7 December 2013 - 2.58PM (GMT)
Hai i am sruthi. i am from kerala. iam studying mount carmel high school jellippara. i proud to become a guide.
Raveesha Somawansa - 3 December 2013 - 2.44PM (GMT)
Hi, I'm Raveesha from SriLanka.This is my second year as a girl guide. Throughout these two years I experienced how important is guiding. From my experience I had throughout these two years, now I know how much girl guiding does to a girl. I wish you all the best!!!!!!. I'm proud to be a girl guide.
Raveesha Somawansa - 3 December 2013 - 2.41PM (GMT)
Hi, I'm Raveesha from SriLanka.This is my second year as a girl guide. Throughout these two years I experienced how important is guiding. From my experience I had throughout these two years, now I know how much girl guiding does to a girl. I wish you all the best!!!!!!. I'm proud to be a girl guide.
Keara - 22 November 2013 - 10.24AM (GMT)
Hai! I'm Keara, and i'm in Girl Guides. Me and my friends, Nora-May, Sorcha and Sarah are going up to Dublin for the National Table Quiz. Wish us luck!
Page 5 of 65
Have your say
Post your comments about this page here. For general questions, go to Contact. When posting comments, please be considerate of others and refrain from abusive or off topic posts. Comments will only be uploaded if they are considered appropriate. Email addresses or any other personal details will not be allowed. HTML code will be removed from comments; linebreaks will be kept intact.


text:
Mimir Chamber Music Festival opens with spot-on performances
The first two concerts at Texas Christian University's PepsiCo Recital Hall were particularly fine, with enterprising programs and superb playing.
The first two concerts at Texas Christian University's PepsiCo Recital Hall were particularly fine, with enterprising programs and superb playing.
The Vietnamese pianist, winner of the 1980 Chopin Competition in Warsaw, was the final recitalist in this year's PianoTexas.
Open to pianists 13 to 17, the contest will showcase 23 players from 13 countries, complete with a concerto round.
In the first U.S. production of the 1727 opera, the British king gains his betrothed by defeating an island tyrant.
Two decades after its Santa Fe premiere, the opera's union of Oedipal drama and evocative music again proves gripping.
Beneath superficial nods to Viennese operettas, the composer plumbs the ambiguities of love in music of trademark lushness.
Concluding the DSO's revived organ-recital series, Jacobs dispatched a major program with the greatest élan — from memory.
The May festival featured musicians and artists from abroad who have settled and worked, at least for a time, in the U.S.
TCU's PianoTexas and the Lev Aronson Legacy Festival at SMU include public performances as well as training.
Current exhibitions in the 1987 main building include works by Barnett Newman and Takis.
Presented by Chamber Music International, the young Korean-born musician certainly validated her multiple first prizes.
Last week's Mahler Third Symphony displayed a fine orchestra, with a new music director, but also a problematic home.
Start to finish, music director Jaap van Zweden had a commanding grasp of the piece, and the orchestra sounded fabulous.
Maybe, wedged between the DSO's challenging Bernstein and Mahler concerts, the orchestra's musicians were overextended.
Two baroque-music groups join in Handel's tuneful, imaginatively textured celebration of music's hypnotic powers.
Music by Theofanidis and Revueltas got vivid performances, but pianist Barry Douglas disappointed in 'Rach 2.'
The orchestra's first-ever performance of the 'Kaddish' Symphony was electrifying, and the Serenade was compelling, too.
Legendary mezzo Marilyn Horne has become a major figure training and promoting young voices.
Adding DSO musicians as needed, the Amernet String Quartet played Korngold, Britten, Rands and Maw.
Artist-in-residence with the DSO, the 20-year-old pianist displayed formidable technique, but he sometimes pushed tempos.
Works by classic movie composers Max Steiner, Erich Wolfgang Korngold and Miklós Rózsa made for a lively evening.
The Dallas Symphony Orchestra's new festival had both hits and misses at Dallas City Performance Hall.
DSO musicians played works by American immigrants and visitors, from Dvořák to Stravinsky to Osvaldo Golijov.
Dallas' modern-music ensemble again deftly mixed brand-new pieces with "legacy" modernism.
The Fort Worth Opera Festival presents a gripping, if coarsely staged, argument for an unjustly neglected opera.
The three-week festival brings together other visual and performing-arts organizations.
The new work in this year's Fort Worth Opera Festival explores a family's desperation in post-apocalyptic disaster.
The chorus and orchestra sounded wonderful, but the singing was uneven, and the first act was too hyperactive.
The program will include concerts by the Israel Philharmonic, Dallas Opera Orchestra and the Youth Orchestra of Colombia.
It's the second installment in a four-year rollout of a Wagner "Ring" cycle that originated in Valencia, Spain.
With only partial power restored to the Scott Theatre, just two excerpts of the new opera were presented.
The youthful French foursome closed the Dallas Chamber Music Society season Monday night with sparks flying.
A baritone and two mezzos took the top prizes in Sunday performances with the Dallas Opera Orchestra at the Winspear.
The Dallas and Fort Worth opera companies combined have tipped the scale too much toward the new.
It includes two regional premieres, David T. Little's critically acclaimed "Dog Days" and Ambroise Thomas' "Hamlet."
The recital demonstrated the kaleidoscopic possibilities of the Nichols & Simpson instrument, and Robinson's virtuosity.
German composer Wolfgang Rihm's gnarly year-old Trio Concerto was paired with the Mozart Requiem.
There was some fine singing and playing, with period instruments, but quirky conducting sometimes loosened the ensemble.
The fairy-tale story requires some suspension of disbelief, but the music, composed alongside 'Nutcracker,' is beautiful.
Still in his 20s, and a flamboyant figure on the podium, the conductor got incisive, lovingly inflected performances.
Rarely performed outside Russia, Tchaikovsky's last opera portrays a young princess awakened to light and love.
A longtime musical fixture in Fort Worth, Giordano has chaired the Cliburn Competition jury and led the Fort Worth Symphony.
Southern Methodist University's student orchestra played spectacularly in Mahler's 'Das Lied von der Erde.'
To be staged at Dallas City Performance Hall, it's the work of writer Rosalyn Story and composer Mary Alice Rich.
Both the Rachmaninoff First Piano Concerto and Berlioz 'Symphonie fantastique' got high-intensity performances.
In bohemian 19th-century Paris, the characters come vividly to life, and sing as if their lives depend on it.
The orchestra's music director exhibited new elegance and expressivity, and Cliburn winner Kholodenko played splendidly.
The Canadian born pianist played all 32 sonatas Saturday at the Dallas City Performance Hall
The conductor's account of the Fourth Symphony was a marvel of high drama and fine detail, and the orchestra played gloriously.
Canadian pianist Stewart Goodyear will perform the sonatas in a marathon, 10 a.m. to 10:50 p.m., at Dallas City Performance Hall.


text:
Orbitz Worldwide Inc. – PR: Orbitz Worldwide, Inc. to Participate at the RBC Capital Markets' Technology, Internet, Media and Telecommunications Conference Chicago, November 7, 2013 - Orbitz Worldwide, Inc. (NYSE: OWW) today announced that it will participate in the RBC Capital Markets' Technology, Internet, Media and Telecommunications Conference in New York on Wednesday, November 13, 2013. Barney Harford, Chief Executive Officer of Orbitz Worldwide, will present at 2:30 p.m., Eastern Time. A live audiocast of the session will be available to the public through the company's Investor Relations website at investors.orbitz.com. A replay of the audiocast will be available on the Investor Relations website for approximately 30 days. About Orbitz Worldwide Orbitz Worldwide (NYSE:OWW) is a leading global online travel company using technology to transform the way consumers around the world plan and purchase travel. Orbitz Worldwide operates the consumer travel planning sites Orbitz (www.orbitz.com), ebookers (www.ebookers.com), HotelClub (www.hotelclub.com) and CheapTickets (www.cheaptickets.com). Also within the Orbitz Worldwide family, Orbitz Partner Network (www.orbitz.com/OPN) delivers private label travel technology solutions to a broad range of partners including some of the world`s largest airlines and travel agencies, and Orbitz for Business (www.orbitzforbusiness.com) delivers managed travel solutions for companies of all sizes. Orbitz Worldwide makes investor relations information available at investors.orbitz.com. Media Contact: Chris Chiames +1-312-894-6890 email@example.com Investor Contact: Brian Wolf +1-312-260-8301 email@example.com ------------------------------------------------------------------------------ This announcement is distributed by Thomson Reuters on behalf of Thomson Reuters clients. The owner of this announcement warrants that: (i) the releases contained herein are protected by copyright and other applicable laws; and (ii) they are solely responsible for the content, accuracy and originality of the information contained therein. Source: Orbitz Worldwide Inc. – PR via Thomson Reuters ONE HUG#1741567
Orbitz Worldwide Inc. – PR: Orbitz Worldwide, Inc. to Participate at the RBC Capital Markets' Technology, Internet, Media and
Press spacebar to pause and continue. Press esc to stop.


text:
Off-White - Plush - Size XL (16) - Bath Robes
- Page 1 of 1
+Quick View
+Quick View
- Page 1 of 1
Thu Jan 13 00:00:00 MST 2011nwmomie Rating:5.0
I purchased this robe for my husband. I was a little worried it wouldn't be as plush and i hoped. However, it was. he has loved wearing. The robe is very thick and well made. The terry on it soaks up all moisture that he doesn't dry off with the towels. ( that was his main concern). I have wrapped my self up in it a few times and believe it better then some of the robes i have purchased in the past at actual spas! I am definitely purchasing one for my self. The size was perfect for my husband too. He's on the small side of a L at 5.9 and the l/xl fit great. He doesn't like things too snug or tight.
Fri May 03 00:00:00 MDT 2013leslieadn Rating:5.0
Delivery was very fast as always with Overstock. The robe itself is quite beautiful and of very good quality. I have stayed in many luxury hotels who had robes exactly like this one and it is difficult to see any difference in the quality. I ordered a L/XL and it is a nice, slightly oversized fit (probably good for women sized 10-16), just above the ankles with slightly long sleeves that can be rolled. Very soft inside and out, cream color that has a tan/yellow hue which is a nice contrast with the white interior. Very glad that I ordered this one instead of the one I saw on another website for $95!
Shop Overstock™ and find the best online deals on everything for your home and your family. We work every day to bring you discounts on new products across our entire store. Whether you're looking for memorable gifts or everyday essentials, you can buy them here for less.Overstock.com ® Your Online Outlet ®


text:
2 bedroom bungalow to rent Llantrisant Road, Beddau, PONTYPRIDDA detached bungalow in a village location, 2 bedrooms, 2 attic rooms, lounge/diner, fitted kitchen, driveway parking. More details ›
£400 pcm
1 bedroom apartment to rent Commercial Street, BEDDAU CF38 2DDModern First Floor Flat within easy walking distance of Local Shops. Talbot Green Retail Park within 7/10 minutes Car Drive. Church Village Bye Pass close by for Easy Access to Pontypridd. Unfurnished. Available ASAP. EPC Rating EER: C. Tenants Fees apply. Credit Check £25.00 per applicant. ... More details ›
£525 pcm
2 bedroom house to rent Heol Seward, , BeddauA modernised, 2 bedroom semi detached property with driveway parking in Beddau. The house briefly comprises of an entrance hallway, living room, modern kitchen with ample space for a small table, 2 good size bedrooms and a family bathroom. To the rear is a good size garden with patio space. Non ... More details ›
£550 pcm
3 bedroom semi-detached house to rent Cynan Close, PONTYPRIDD, CF38A modern, 3 bedroom, unfurnished semi-detached house situated in Beddau. The property comprises of a hall, a good size lounge with dining area, and patio doors to garden, a fitted kitchen (no white goods included), 2 double bedrooms, 1 with fitted wardrobe, and a box room, and a family bathroo... More details ›
Added on 25/06/2015 by Cedar Properties (Cardiff) Ltd, Cardiff. Call: 029 2243 0149 Local call rate
- 1
Thank you.
Your information has been sent to 0 out of 4 agents who have property to rent in the area you specified.


text:
A collection of news and information related to The Simpsons published by this site and its partners.
Top The Simpsons Articles
Displaying items 78-88
Bears-Packers not a rivalry anymore
'Goodfellas' actor sues Fox over 'Simpsons' character
'The Simpsons Family History' celebrates show's 25th anniversary
Candidates for H.B. council, city attorney stake out positions at final forumStory | Oct 17, 2014 | 2:27 PMMore than 100 people gathered at the Huntington Beach Central Library on Thursday evening to hear candidates for City Council and city attorney make their case one more time before the public hits the polls Nov. 4. The League of Women Voters of...
'GoodFellas' actor sues Fox, saying he created a 'Simpsons' character
'Walking Dead' vs. Peyton Manning: Both win
How 'Simpsons World' Went from Deal Point to Immersive App Via FX NetworksStory | Oct 20, 2014 | 2:30 PMThe genesis of "Simpsons World" -- the authenticated app that is the multimedia playground for all things connected to the iconic toon -- was a deal point in the megabucks syndication deal that brought "The Simpsons" to reruns to FXX. As FX Networks...
Danny Elfman talks about Halloween concerts of Tim Burton movie music
Q&A With John Lovitz, "I Do What Is Funny To Me."
TV Picks: Foo Fighters, twins, Simpsons, 'Web Therapy,' more
TV This Week Oct. 19 - 25: 'The Good Witch's Wonder'


text:
Website Developed By CatapultK12™
Copyright © 2012 Harvest Preparatory Academy and its licensors. All rights reserved
Welcome, HPA High School Students!
We have no restricted enrollment practices.
- no tuition fees
- no required parent volunteers
- no entrance exam
- every child should be given the chance to thrive


text:
Palm Warbler, Cal City
Expand Messages
- Hi all, a Palm Warbler (palmarum) was occupying the sw corner of the irrigation pond next to Neuralia Road, north of California City. It was there yesterday, Oct. 28, around 1:00. Galileo was very very quiet on Wednesday, Oct 27. The Osprey and Long-eared Owl found by Stan Gray on Oct. 23 were still present, the owl being in one of the small tamarisks at the trap and skeet area. Good birding, Dave Goodward
Your message has been successfully submitted and would be delivered to recipients shortly.


text:
Plateau SL Series 2-Shelf Audio / Video Rack
Plateau SL Series 2-Shelf Audio / Video Rack
Weights & Dimensions
|Product Type: Audio rack
|Style: Contemporary
|Material: Wood
|Hand Painted: No
|Hardware Material: Brushed nickel assembly hardware
|Product Care: Use Windex to clean
|Solid Wood Construction: No
|Finish: Black satin paint
|Number of Items Included: 1
|Total Number of Shelves: 3
|Shelf Material: Glass
|Adjustable Shelving: No
|Scratch Resistant Shelves: Yes
|Cabinets Included: No
|Cloth Back Included: No
|Glass Component: Tempered glass
|Multimedia Storage: Yes
|Casters Included: No
|Sand or Lead Fillable Legs: No
|Stabilizer Feet: Yes
|Ventilation Thermal Management: Yes
|Lighted: No
|Cable Management: Yes
|Country of Manufacture: China
|Weight Capacity: 300 Pounds
|Shelf Weight Capacity: 70 Pounds
|Commercial Use: Yes
|Assembly Required: No
|Installation Required: Yes
|Additional Parts Required: No
|Product Warranty: 90 days
About the ManufacturerIt is important that you choose the right speaker stand or component rack to ensure that you will be hearing the best sound quality. All of Plateau's products are designed to be flexible and strong, with something to meet everyone's needs.
From the first time recorded music was made, people have been striving to improve sound quality. Plateau Corporation has contributed to this search for excellent sound and is ready to help you experience the difference.
Plateau stands are deliberately designed to enable every listener to hear music the way it was intended: uninterrupted, beautiful and clear. No matter what your taste – no matter what room you are in – Plateau has a stand for you.
Plateau component racks offer the ability to customize your setup using the audio and video components you choose. Durable and versatile – Plateau components will help improve your overall sound quality and allow the versatility to expand and change your system easily and efficiently.
Plateau SL Series 2-Shelf Audio / Video Rack
Customer Reviews
|5 star
|4 star
|3 star
|2 star
|1 star
Fantastic end piece for a couch to hide your entertainment gear in
Evan from Santa Clara, CA – Verified Buyer
Pros: 1.) Looks fantastic in my living room 2.) The price was incredibly reasonable 3.) it's short enough it can be used as an end table Cons: 1.) one of the holes for the top feed were not drilled, but that was an easy fix 2.) wood looks like cheaper wood, but once installed you don't really notice anything Overall this entertainment stand is great. GAF is high, and it saves me having to wall mount an entertainment stand in my living room. My cable modem, router, AV receiver, cable box, HTPC and a few other devices all fit easily inside, the glass has cable routing holes in it to ease hiding cables. I couldn't be more happy with this item. As a side note, I had to request two pieces of glass as RMA's due to top and middle pieces having what appeared to be spray paint marks, like whoever coated the glass black did a poor job. Other than that, I would highly recommend this
Exactly as Advertised
William from Leesburg, VA – Verified Buyer
Fits very nicely into my cut out area for an entertainment center. Very sturdy.
A/V Rack
Ron from New York, NY – Verified Buyer
Everything expected and more. Superior Quality with Looks to match! Very Satisfied and Looking for more of the Same!
Perfect size.
Jason from CA – Verified Buyer
The 3 shelf rack is great. It's the perfect size. I measured everything and had the specs. I had no problems with it!
OUR SKU # PT0271SL Series 2-Shelf Audio / Video Rack is also sometimes listed under the following manufacturer numbers: SL-3V (26) (B), SL-3V (26) (B)-BG


text:
Sports physicals are $35
Sports physicals are available at Sage Primary Care and Mesa Primary Care for $35. Call for your appointment today!
read more
Safe Kids Swim Night
Join us for Safe Kids Swim Night, 5:30 to 7:30 p.m., July 15 at the Paradise Valley Swimming Pool.
read more
Glow Run
Join us on July 11 for the WMC Glow Run at Crossroads Park.
read more
WMC Awards & Recognitions
Learn more about the Awards and recognitions that Wyoming Medical Center has received.
read more
Health Fair Lab Draws
The WMC lab offers health fair draws every day of the week. No fasting or physician order needed. Walk-ins are welcome at 2 convenient draw stations.
read more
The Pulse: Life Inside WMC
The Pulse is a community health blog featuring stories from the heart of the Wyoming Medical Center – its people.
read more
Diabetes Care Center
Our nationally recognized Diabetes Care Center can help make living with diabetes every day easier.
read more
For Your Health Magazine
For Your Health is a quarterly publication of Wyoming Medical Center, with the intent of providing information on managing health over a lifetime.
read more
WMC Speakers Bureau
Wyoming Medical Center offers a variety of presentations, for free, to various clubs and community organizations.
read more
UW Family Medicine Residency Program
Wyoming Medical Center is proud to be a teaching hospital for the University of Wyoming Family Residency.
read more
Masterson Place
The WMC Foundation manages and funds the Masterson Place, a small hotel serving the lodging needs of our patients and their families for just $40 per night.
read more
Like us on Facebook
Find us on Facebook for healthy tips, upcoming events, construction updates, sneak peeks and more...
read more
Gentle Hands
July 1, 2015 (9:15am)
Cancer Support Group
July 1, 2015 (11:00am)
Hepatitis C Support Group
July 1, 2015 (6:00pm)
NAMI Connections/All Diagnosis Support Group
July 1, 2015 (7:30pm)
Alzheimer/Dementia Caregivers Support Group
July 2, 2015 (10:00am)


text:
I'd like to allow an end user to enter a city and return a list of tweets geotagged with the user-entered city. Does Twitter4j have a class that allows for this type of query?
I see the GeoQuery class but that requires you to pass a lat/long to the constructor.