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Web Hosting Realitychecknetwork.com
You come upon the Reality Check Network and are instantly taken aback, not by its in-your-face advertising or its flashy, bubble-bordered low price tag taking up half the page, but rather by its simplicity, by its sleek modernity that screams state-of-the-art. And yes, various dashed-words.
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An interesting – and definitely unique – appeal to the Reality Check Network promo is their full layout of the system and how it works. This nuts and bolts approach is a great and user-friendly way to navigate your ideas to fit not just the site but grasping the entire concept, which we all know can get tricky.
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Photo Credit: Michael Stipe
Former R.E.M. singer Michael Stipe will debut a new solo composition—officially, it's his first ever, according to a press release—at this year's Moogfest, which happens May 18–21 in Durham, NC.
The Moog-centric piece is "an exclusive audio-visual installation that will explore desire and movement, showcasing footage [Stipe] shot in New York City," according to Noisey.
Stipe's appearance at the North Carolina festival owes, at least in part, to an Athens connection. Last September, Stipe friend and Slingshot Festival founder Kai Riedl announced that he had been hired as Moogfest's executive producer.
The wide-ranging Slingshot began in 2014 to showcase local, national and international music, tech and art, and has taken place each spring since. Riedl confirms that the event will continue in Athens, but says this year's installment has been moved to the fall for logistical reasons.
"There have been a lot of moving parts, mostly due to me working full time at Moogfest, and it's pretty full on," Riedl says.


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Supplier Contact Details: email@example.com Supplier Phone: 0044 800 808 5701
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With lush coastal forest, striking mountains and expansive ocean views, the Sea to Sky Gondola provides the perfect backdrop for your next production. The Sea to Sky Gondola provides easy access to a variety of mountaintop locations, with stunning vistas in every direction and a professional team of experienced liaisons to assist on your next production.
- Easy lift access to mountain terrain
- Stunning mountain and ocean views
- Experienced film liaisons
- Helicopter landing pad
- Tube park
- 100m suspension bridge
- On-site crew and production parking
"Sea-to-Sky Gondola is an amazing filming location, one of the crown jewels actually for lower mainland mountain vistas and contemporary architecture in mountainous settings. The suspension bridge alone is worth the trip up. Staff are amazing, logistics easier than one would expect for getting crew and gear up 3000' feet, and they have a decent 4x4 road for getting larger trucks and gear up to their summit. I've had a really successful shoot there for huge Nature Valley commercial, and would highly recommend Sea-to-Sky to any production needing a mountain filming experience without the helicopter mobilization price! "
Michael Gazetas, Location Manager
"I can wholeheartedly recommend Sea to Sky Gondola as a filming location. The looks are spectacular and unique. The staff is great to work with, thorough and knowledgeable. Very helpful with logistics and moving people and equipment to the site. Costs estimates for fees were very fair with no surprises. Would go back anytime with no concerns."
Kirk Johns, Location Manager
"It is always a pleasure for the crew to film at Sea to Sky Gondola. I have personally filmed here over 10 times and its always been a success. Anne is always a pleasure to deal with and always comes up with amazing places to film at. I would highly recommend filming here so you can experience the breathtaking views and everything that an amazing BC location has to offer."
David Pink, Location Manager
"Without a doubt, filming at the Sea to Sky Gondola has been one of my career Location highlights. The views! Absolutely spectacular. The images we gathered for the film are stunning. The vistas are breathtaking. The staff! Just as amazing as the views! The coordination I experienced between our Locations Team and the Operations/Sales Teams at S2S Gondola was exemplary. Every role was clearly defined. Communication was clear, concise, and actionable. The cost estimates were clearly outlined prior to execution and there were no surprises when we finished filming. Questions were always answered and assistance was always provided when need during prep, through filming, and during wrap. Plus! Everything was handled and delivered with a lightness, sense of humour and care, that was refreshing to experience. I highly recommend and hope that others will bring more film projects to the Sea To Sky Gondola! Fluffy approved!!!"
W. Robert "Fluffy" Millar, Assistant Location Manager


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Teri and Don Page prepare Special Olympians for competition. They guide specially trained therapy horses to adapt to their riders with special needs. Providing moral support and encouragement, they impact the lives of people—both riders ad families—by volunteering with SIRE Therapeutic Horsemanship.
On most Thursdays, the retired energy industry professionals can be seen around the Hockley location. Pairing up to help the riders, Teri leads, and Don supports as a side walker. "I am very careful trying not to step on her feet as I sidewalk," Don confessed, with a laugh; they've been married 35 years
Twelve years ago, Teri discovered SIRE through her involvement with the Yellow Rose Chapter of the National Charity League when she spent two years volunteering as a side walker. She independently returned to volunteering at SIRE three years ago and has moved into a horse leader role. "The staff likes to challenge volunteers to lead and become more confidant with the horses, too," she explained. Don joined her 18 months ago, just two weeks after he retired.
Together they have been inspired by riders' determination and evolving skills and are pleased to have watched them progress. One rider with multiple sclerosis struggled early in her training with the fatigue of a 45-minutes lesson. As a side walker, Don and the other side walker would help support and gently push her legs up on the horse to provide relief during the ride. After a year on horseback and the strengthening exercises SIRE therapists suggested she perform at home, she is able to hold herself up in the saddle and ride almost unassisted. Another woman Teri worked with is blind. "It's amazing to see her be able to mount her horse and see her ride up and down the hills on the SIRE obstacle course," Teri said.
For the Love of the People
The Pages agree; they stay so involved because of the people.
"Being a volunteer is so wonderful," Teri said. "Everyone pitches in to help out, not just to help the riders but each other. We were used to working in the financial and technology fields, and this environment was new to us. Everyone opens their heart. It's an extremely positive, loving place."
Don enjoyed the atmosphere so much he decided to volunteer a second day each week to help with riders and simple maintenance projects on the property and buildings. Working with Facility Manager Roy Figueroa, Don (both pictured on the left) reinforced the walkway ramp to the office and repaired the temperamental fluorescent lighting system in the volunteer welcome wagon.
One day he and another volunteer, Mike Lyons, tackled the 12-year-old antiquated and broken fans in the horse stalls. They trekked to the home improvement store, split the cost of 20 new fans and installed one in each of the horse stalls to the relief of the herd and the humans.
Most weeks, Don helps clean up the barn. "I always joke that sweeping the barn—and mucking out the stalls—is my specialty," he said.
SIRE has become an integral, enriching component of their retirement, the Pages concurred. In addition to spending time with their 3-year-old grandson and fishing and boating, Teri loves crafting, scrapbooking and sewing outfits for the toddler.
They look forward to the Spring semester and helping riders train for the upcoming Houston Livestock Show & Rodeo's Top Hands and the Special Olympics horse shows.
"I love it out there," said Don. "I always tell others how nice everyone is at SIRE. One of the main reasons we volunteer is that the SIRE staff, the riders, and the other volunteers are really some of the nicest people we have ever met."


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Fridfinnsson and Gudmundsson in the Bienal de São Paulo
Hreinn Fridfinnsson and Sigurdur Gudmundsson participate in the Bienal de São Paulo. Since its first edition in 1951, the São Paulo Bienal has sought to examine contemporary cultural production from the vantage point of Brazil and its place within the international context. However, unlike other large-scale exhibitions held in cities with relatively small populations, it takes place in one of the largest metropolises in the world, in a country where access to art and the transformative power it wields is still severely limited.
The 30th Bienal de São Paulo, The Imminence of Poetics, is curated by Luis Pérez-Oramas with André Severo and Tobi Maier (associate curators), and Isabella Villanueva (curatorial assistant). It will be on view from September 7th through December 9th, 2012.
Hreinn Fridfinnsson's (b. 1943) work is a poetic and philosophical exploration of every day human experience. Transcending the mundane materials of which they are made, his simple, almost ethereal pieces paradoxically evoke the strongest of emotions.
Sigurdur Gudmundsson's (b. 1942) idiosyncratic work is difficult to separate from the energetic and witty artist himself. His art has been based on a non-hierarchical flow between photoworks, sculptures, performances and ´visual poems´. Gudmundson´s photoworks construct a certain poetic and philosophical vision and depict human existence in a humorous and pointed way as part of nature.
Hreinn Fridfinnsson, Attending, 1973
Image above Sigurður Guðmundsson, Study for Horizon, 1975


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Echosmith return with a new video and album announcement
We love listening to Echosmith, so the news that the Sierota siblings have released their new single and video, 'Goodbye' AND a new album, Inside A Dream, is coming on 29th September is music to our ears.
Echosmith has released their long-awaited new single "Goodbye," out today at all digital retailers. Opening with a finger-picked acoustic guitar entwined with frontwoman Sydney Sierota's breathy vocal, the song expresses frustration with a partner's indecisiveness, building into a danceable refrain colored by island-style keys and heavy bass as she finds the courage to finally say "Goodbye." Echosmith has also released the song's official video."Goodbye" is the first release off their highly-anticipated sophomore album, Inside A Dream, out September 29 via Warner Bros. Records. The 11-track set marks the long-awaited follow-up to the band's 2013 Gold-certified debut, Talking Dreams, which spawned the triple-platinum breakout hit "Cool Kids." Following the release, Echosmith will embark on a 6-week North American headline tour. See a full list of dates below.Inside A Dream marks a new and exciting direction for the LA-based alt-pop trio, showcasing a more mature and evolved sound. Led by charismatic frontwoman Sydney Sierota and rounded out by her brothers Noah (bass) and Graham (drums), the tight-knit siblings had to come to grips with the departure of big brother and guitar player Jamie, who chose to leave the band after the last album in order to spend more time with his wife and son. "We had to find ourselves as a trio instead of a quartet," admits Noah. Sydney explains, "That literally forced us on a journey of having to discover this sound. We still had electric guitars, but they weren't the center of the music anymore." In order to bring that vision to life, the group utilized vintage synths, keys, and drum machines. As a result, Inside A Dream is awash in shimmering synths, airy guitars, and heavenly vocals that wouldn't be out of place blasting from an eighties transistor radio during an episode of Stranger Things.Echosmith first emerged onto the scene in 2013 with their debut album Talking Dreams. The (Gold-certified) album produced the triple-platinum hit "Cool Kids," and platinum-certified "Bright." The band quickly earned rave reviews from the likes of ELLE, Rolling Stone, Teen Vogue, Billboard, NYLON, and more for their distinctive melody-minded, New Wave-influenced sound. They have performed on ELLEN, The Tonight Show Starring Jimmy Fallon, The Today Show, Late Night with Seth Meyers, The Late Late Show with James Corden, Conan and others. The Sierotas - Sydney (vocals/keyboard), Noah (vocals/bass), and Graham (drums) - have played to crowds of thousands at festivals and sold-out shows in the U.S. and Europe. The band has even joined Taylor Swift as a special guest on her 1989 Tour in Philadelphia to perform "Cool Kids."


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This simple and easy to put together salad combines a number of fruits to give the dish an exciting twist – give it a go and we're sure you'll agree! Maybe make more than you need so you can have the leftovers as a side salad to your following meal?
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- This event has passed.
Columbia Winery Charity Walk & Run
August 18, 2018 @ 8:30 am - 11:30 am
10 K Run | 5K Run/Walk | Kids Dash
This annual fundraiser is put on by The Run for Children's Guild. The Run for Children's Guild is a group of volunteers dedicated to helping children in the Northwest by raising money for uncompensated care at Children's Hospital. The need for uncompensated care grows each year and is expected to exceed more than $120 million this year.


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Moving companies in Norfolk and Virginia Beach are a dime a dozen. However, finding a trustworthy commercial mover in the area may be a bit more difficult. Not only are there less companies that offer these services, but also not all commercial moving companies operate the same. When choosing a company that offers commercial moving services in Virginia Beach or Norfolk, be sure to form a proper checklist for their services. Make sure your movers meet all of the following standards.
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Commercial Moves require commercial equipment. Oversized filing cabinets and office desk differ from beds and dress found in typical residential moves. Make sure your commercial moving company in Norfolk and Virginia Beach comes equipped with all the necessities to safely and efficiently move your business or office. Proper commercial equipment leads to proper commercial moving services. Between box dollies, furniture dollies, appliance dollies, wrap, straps, and much more, there are a lot of tools that can help facilitate a move. Make sure your commercial mover in Virginia Beach and Norfolk comes equipped with the best.
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Proper coverage helps to ensure that the value of all items being moved will remain the same at your new location. Beyond that, a properly insured commercial moving company in Norfolk and Virginia Beach grants peace of mind in an incredibly stressful time. It takes a lot of planning, effort, and patience to execute a move smoothly. Be sure in your planning efforts to remember to ask about coverages and insurances for the move. Commercial moving services provided by a commercial moving company in Virginia Beach or Norfolk should not qualify to move your business if they are not properly insured.
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Experience breeds excellence. You do not want a first-time commercial mover to handle your office move. Make sure the commercial moving company you choose has the proven track record of not only handling offices moves but office moves of your company's size. Commercial moving services offered in Virginia Beach and Norfolk vary from the size of offices and types of businesses serviced. A company's history is the best indicator of the result in the present (see how Scott's Oceana Moving history compares!). If your commercial mover in Norfolk or Virginia Beach cannot speak to their experience in similar style moves, then that is not the commercial moving company you want to trust with your business.
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We are featured in Nature's Pathways magazine each month with an article and profile. This month we discuss the importance of giving instead of gifting. This article holds true for all celebrations and relationships. At UpShift we totally believe in living life to it's fullest through experiences and connections while enjoying simple things in life.
Check out the full article here:


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Mr Crawford - Principal Teacher of Languages
Experience of working abroad:
- Two summers (3 months each) at a summer camp in New York (Camp Lakota)
Why did you decide to work abroad?
A friend of mine was planning to follow in his brothers' footsteps and work abroad in America at a summer camp at the end of our first year at University. It seemed like a great opportunity and having heard how much my friend's brothers rated the experience I agreed to give it a go too. I hadn't really looked into it in a great deal of detail but having thrived away from home for a year at uni I thought it would be a great way to further challenge myself while soaking up some sunshine.
Was it difficult to apply to work abroad?
The whole experience was organised by a company called Bunac who specialised in finding counsellors to go and work on American summer camps. Their forms were very straightforward to fill in and I had to part with no money up front as the flights and accommodation were just taken out of my wages at the end. I remember going to London to get my working visa from the embassy and then had a short interview with a rep who asked me about my skills, qualities and what I would be able to offer the camp. I was chosen to be a mountain bike instructor and each day I took groups of campers on long bike rides through the forests and trails that surrounded the camp.
What was the best part about working abroad?
I loved working with the kids and it meant that I had to be very responsible and think of their needs first which after a year at uni- only having to look after myself- was a good growing experience. The time away from my family (no mobiles or wifi in 2004) meant that I had to be very independent and resilient but there were loads of new friends for me to go out with once the day was over. The other counsellors were from England, Canada, Norway, Australia, America and Ireland so it was a great chance to meet people from different backgrounds and to further broaden my horizons. After the time at camp was over I used my pay check to travel around America with the friends I had made and I now return to Brooklyn annually to meet friends that I made during 2004 and 2005.
Top tips for pupils who decide to work abroad?
Throw yourself in at the deep end. It's a great experience and you will never know if it is for you until you sign up!


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This is another food review.. in fact it was my 1st food review for the year 2011 :)
Mayfair had just opened not too long ago.. so i won't blame you if you do not know where it is :P
Pictures courtesy of andy kho, as usual :)
Here's how the bartender did the mojito for andy
And..... TA DAH!
Aperol sour - rm22+
First came was the ceaser's salad & crispy salted beef - rm 14+
Tuna & mushroom pasta - rm 27+
Tender hickory pepper baby pork ribs - rm 60+
Crispy pork knuckle - rm 45+
Chorizo & bacon pizza - rm 27+
Mixed sausage platter - rm 60+
Warm bread butter pudding - rm 14+
It was served like this.. and then mei sze suggested they should serve it together with a scoop of vanilla ice cream and guess what? they ARE serving it with ice cream now! :D
Now, after filling up our tummy with food we did what we are good at most! haha
Tim devouring the pork knuckle and his guinness
Mei sze with her new glasses from malaya optical
Chatting with the chef, kenneth tan
Last picture of the day would be a group shot with the owner, thomas tan and the chef, kenneth tan
This is a place for you to just chill out with your friends or maybe have a quiet romantic dinner with your loved one.. hmmm.. since valentine's day is around the corner, why not celebrate it there?
Here's the address :-
Mayfair, English Kitchen & Bar
DG-03, Menara Taiko,
PJ Trade Centre, Jalan PJU 8/8,
47820 Petaling Jaya
Tel : +603-7726 4131
Website : http://www.mayfairkl.com.my
ps : prices are inclusive of the 10% service charge BUT no government tax at the moment


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Micky (noun)
- the Australian term for a wild, young, unmarked bull
The Micky bull is one of the most difficult to muster. It refuses to follow the herd. While others trudge towards an inevitable destiny, the stronger and more courageous Micky bull makes a break for freedom.
In the business and finance world, there are cattle and there are Micky bulls.
Micky.com.au has been created for the Micky bulls.
A news, media and content company, we have a focus on the blockchain and cryptocurrency industries.
Our journalists scour the internet and regularly speak with contacts to find out the latest happenings within blockchain projects, whether they're listed on CoinMarketCap or the ASX.
Micky also provides a platform for our network of clients to tell their stories to a new generation of savvy investors.
A revolution is under way. Micky is here to document that revolution.
– – – – – – – – –
Content on the Micky website is not intended as investment advice. Readers, viewers and listeners are urged to conduct their own research before making any investment decisions. The cryptocurrency market is volatile and there is a chance you could lose some or all of your money.


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Sweet Inn - Trastevere - Casa Lucio, Rome
- Free WiFi
- Collect nights
The location was perfect for our family vacation. We were in the Trastevere neighborhood,…
Nice big clean apartment. A few tips if your going to book. You must connect your cell…
Sweet Inn - Trastevere - Casa Lucio, Rome
More Info: 866-266-9798
- Apartment, 1 Bedroom (Vicolo Del Buco, 7 , I)
- Studio (Vicolo Del Buco, II)
- Apartment (Vicolo Del Buco, IV)
- Studio (1st floor (Vicolo Del Buco, III))
More great choices
What's around Sweet Inn - Trastevere - Casa Lucio, Rome
- In Trastevere
- Roman Forum - 12 min walk
- Campo de' Fiori - 12 min walk
- Piazza Venezia - 13 min walk
- Via del Corso - 14 min walk
- Circus Maximus - 14 min walk
- Piazza Navona - 15 min walk
- Pantheon - 16 min walk
Getting around
- Rome (CIA-Ciampino) - 22 min drive
- Rome Quattro Venti Station - 26 min walk
- Rome Trastevere Station - 29 min walk
- Rome Ostiense Station - 29 min walk
- Circus Maximus Station - 19 min walk
- Colosseo Station - 22 min walk
- Cavour Station - 25 min walk
At a glance
Key facts
- 4 apartments
Check-in and check-out
- Check-in time 4 PM-noon
- Check-out time is 11 AM
- Express check-in/out
Required at check-in
- Credit card, debit card, or cash deposit required for incidental charges
- Government-issued photo ID required
- Minimum check-in age is 18
- Free WiFi in public areas
- Free WiFi in rooms
- No parking
Payment types at the property
Other information
- Smoke-free property
At the property
- Concierge services
- Laundry facilities
- Luggage storage
- Multilingual staff
- Arabic
- Chinese
- English
- French
- Italian
- Portuguese
- Spanish
In the apartment
- Espresso maker
- Slippers
- Iron/ironing board
- Soundproofed rooms
- Premium bedding
- Individually decorated
- Individually furnished
- Private bathroom
- Shower only
- Bidet
- Designer toiletries
- Hair dryer
- Free WiFi
- Refrigerator
- Kitchen
- Stovetop
- Cookware, dishware, and utensils
- In-room safe
Also popular with travellers from Canada
Sweet Inn - Trastevere - Casa Lucio, Rome's small print
Also known as
- Sweet Trastevere
- Sweet Inn Trastevere
- Sweet Trastevere Casa Lucio
- Sweet Inn Trastevere Casa Lucio
- Sweet Inn - Trastevere - Casa Lucio Rome
- Sweet Inn - Trastevere - Casa Lucio Apartment
- Sweet Inn - Trastevere - Casa Lucio Apartment Rome
- Sweet Trastevere Apartment
All guests, including children, must be present at check-in and show their government-issued photo ID card or passport.
Cash transactions at this property cannot exceed EUR 2999.99, due to national regulations. For further details, please contact the property using information in the booking confirmation.
This property does not have elevators.
Mandatory fees
You'll be asked to pay the following charges at check-in or check-out:
- A tax is imposed by the city: EUR 3.50 per person, per night. This tax does not apply to children under 10 years of age.
Deposit: EUR 500.00 per stay
- Cleaning fee: EUR 60 per accommodation, per stay
We have included all charges provided to us by this property. However, charges can vary, for example, based on length of stay or the unit you book.
Recent reviews
Good 7.6 From 31 reviews
Check in process was SO EASY which is not always the case for renting an apartment. The location was completely amazing. They thought of everything - espresso, toiletries, fast WiFi, etc - and the apartment was clean and adorable. The AC wasn't SUPER cold but it worked.
It is located above a bar in a busy piazza in Trastevere. Trastevere is very pleasant for bars and restaurants so it is a good location and convenient for all the sights. The bedrooms are at the back of building and so are quiet even though the piazza itself is noisy until the early hours of the morning. The apartment is nice and the only problem we had was that the air conditioners were not working and we were staying there in August when it is very hot even at night. The building managers tried to fix them unsuccessfully. We also had problems with the hot water which they did manage to fix. I think that it is a newly renovated apartment that has only recently been used as a hotel so the owners are still dealing with these issues. Once they fix these it should be totally fine. Overall we have a good stay apart from this.
The area around the apartment is perfect for bringing on the fringes of the city and sightseeing. The apartment itself had several basic flaws. The check-in arrangements were a little stressful. I was checking in later and found the arrangements to get in worrying. So much so that I took up there chaffeur option just to ensure the someone would know I was there. The downstairs door was open (luckily The host declared) otherwise I'm not sure how I would have gained entry. The room itself is nicely decorated though it was slightly unnerving that the toilet is About a metre from the bed behind a see through glass screen. Their is a small Kitchenette which is the main reason I booked. I was disappointed there were no basics such as salt,pepper & oil. Not even a sponge to do the washing up. These little ammenties make all the difference. The host has arranged to come and collect a cleaning fee off myself at the flat at 9am the day after check-in. I went out in the morning and came back for the meeting so they could charge me 60 euros on top of the hotels.com cost for cleaning. There hours past and there was no sigh and I was losing precious hours out and about the town. At around 13pm I received a call asking if I was able to meet to pay! Not even an acknowledgement of our previous meeting. Finally met the host at 3pm and will he was in the flat with me I pointed out the TV was not working. He said they would have someone out to fix it....never happened. Not a great experience!
The apartment was wonderful. Located in Trastevere on a quiet square, a short walk to all of the action. We highly recommend this for your next trip to Rome!
Awesome location and was easy to find. No one was there to greet me as advertised. Luckily I had international cell service and called. They buzzed me in. Room was as pictured and comfortable. Bathroom could have been a little cleaner - floor was dirty in corners and behind door. I didn't realize I would not have daily cleaning service. Not sure why I had to pay a cleaning fee on top of the room cost. Air conditioning however you cannot turn on until May 1st. I was there at end of April and 80+ degree weather. Would have been nice to have a safe in the room to lock up valuables. Nowhere to store my passport securely. Wifi and cell service not great in the room. Overall happy with the room. Be sure to eat at Dar Sor Olimpio al Drago right next door.
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Furniture such as cabinet and vanity is also part of their cabinet. It's important to pay attention in this part time. It ought to be painted, stained, or not at all. And if you prefer to provide color in it, it is better to make it fits with the total color within the space.
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Divide the Room with Quite a Few Bar S
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If you belong to group or people which pride and style do matter, subsequently moving using the oil rubbed bronze faucets for cabinet is really value. The substances composing the taps are lasting and also work nicely with the remainder atmosphere. Once setting this faucet, you may enjoy the amazing finishing touch.
Being creative with all the counter could be carried out by putting in tiles onto it. It is likely to be different and fresh and fun for your own cabinet. You do not need to acquire costly granite to pay for it as you can certainly do the DIY project to set up the tile. It's amazing in contrast however merely corrected the tiles together with your cabinet fashion. There are lots of points you can certainly do to help the sake of decorative bathroom storage cabinets.


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-Mom's 61st. If she wasn't born, I wouldn't be here as I am, so yeh..
-Went to a new to me place today. Barnsdall Park. I like it. Sat with my back against a tree. Listened to music. Surrounded by trees, blue sky. Super nice weather today. Will go back this week for sure.
-Online support/social groups.
-toilet paper
What are you thankful for?


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A year after shutting down its shop in India, Foxconn's lofty aspirations seem to have found wings as the manufacturer of Apple's iPhones has plans to open nearly 10-12 facilities here.
Surging manufacturing cost in Chinese markets is cited as the reason to shift its camps to India, where Foxconn is likely to set up factories and data center by 2020.
According to a brief statement to Reuters, Subhash Desai, Industries Minister of Maharashtra, "Foxconn is sending a delegation of their officers to scout for locations in a month's time."
For Apple, India could be a huge market where the iPhone faces tough competition from Samsung and other players regarding price. Notably, Apple's iPhone 6 with 16GB comes at around Rs.44,000/- ($687.82) in India as against Samsung's Galaxy S6 with 32GB at a price of Rs40,000 ($625.29).
According to Counterpoint Research Market Monitor, Apple has to compete with rivals like Samsung and Micromax as iPhone only enjoys 10% market share in India.
Responding to a query from media, Desai said Foxconn didn't make any firm commitment but said the company is planning to manufacture iPhone, iPad, and iPod for Indian and global markets.
It is noteworthy that under the new political leadership of prime minister Narendra Modi, India is set to expedite her manufacturing growth; however, the neighbouring country like China pauses a tough challenge as the latter boasts nearly unbeatable technological prowess and excellent assembly line production.
However, industry insiders also look at the other side of India's growth story. Experts believe that India needs to come of age regarding healthy infrastructure and suppliers, which are the biggest stumbling blocks to manufacture technology products. As a result, over 100 phone companies were forced to get their products manufacturer from companies in China and Taiwan.
Do share your feedback with us in the comment, on Facebook, Twitter, and Google Plus. Also, make sure to download our iOS app on your iPhone and iPad.
Source: IndiaTimes.com


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Put your wool coat in the back of your closet and free yourself from hats, gloves, and scarves – spring is here! And with spring comes the need for a stylish trench coat. We've already showed you some Chic Rain Trenches for Nasty Weather, but this season is all about bright colors and jungle prints too. And the silhouettes have really taken a turn for fashion and away from function. As trenches were originally made to keep you dry in the rain – now they're here to make us look fabulous no matter rain or shine.
The Via Spiga Zebra Print Trench Coat ($168) is water resistant – perfect for a rainy day. It's also machine washable for that grime and dirt we ladies pick up in our busy lives. Since the print of this coat is partially white, the washing-machine friendly fabric really makes buying this trench an easy decision – and its easy on the pocket-book. (Although its pattern is not for the faint of heart.)
For those of us who need a slightly more subtle option but still want to have some fun, try out one of these candy colored trenches instead:
Gallery Hooded Pleated Coat ($128) is a little less trench, and a little more adorable pleated dress you can wear as a trench. This citrus colored dream coat is water-resistant, fully-lined, and reasonably-priced.
TwillTwentyTwo Grace Double Breasted Twill Jacket ($242) has an adorable take on a peter-pan collar with a bit of shirring and notches like the classic trench. Other intricate details that add to the flair include starch-white oversized buttons, white top-stitching, double breasted front closure, shirring on the pockets, and balloon sleeves and hem.
Coffee Shop Single Breasted Bubble Hem Trench Coat ($78) has an iridescent shine that makes it oh-so-playful for spring. Subtle details make this coat a must-buy – and it's the most affordable of the lot.


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If you are looking for a reliable and environmentally friendly line of boat dock products in the Okanagan, Paradise Dock & Lift Inc. is the perfect choice. Our boat dock systems includes many innovative and additional features that are unique to our line of products only. So whether you need boat docks for freshwater or saltwater, we are able to create the perfect system for your needs.
Available boat docks for the Okanagan area:
If you have any questions regarding any of our boat dock products for the Okanagan area, contact us today at 1-888-411-DOCK or email us.
Or you can visit our head office in the Okanagan area and let us help you build the perfect boat dock for you!
Okanagan Head Office Location:
4311A – 25 Ave, Vernon, BC
Local: 250-503-8630


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Aspire Personal Training
Spa Bottom Farm, Haggs Road, Follifoot, Harrogate, HG3 1EQ
Tel: 07729 194 178
Spa Bottom Farm, Haggs Road, Follifoot, Harrogate, HG3 1EQ
Tel: 07729 194 178
Aspire PT focus on getting results so whether you're looking to lose weight, improve your overall health or even train for a marathon, they go out of their way to ensure you get the results you want.
Aspire Personal Training is based at the Rudding Estate Gym which is set within the beautiful Yorkshire countryside on Haggs Road (just off the Knaresborough bypass) between Harrogate and Wetherby. Their new personal training studio not only has state of the art fitness equipment but is also set in the most amazing scenic surroundings giving the perfect place for you to stay focused on reaching your desired goals.
Aspire offer three formats for training :
Personal Training
Personal training provides structure, variety, motivation and most importantly results to your exercise sessions. Having a regularly scheduled appointment is great for maintaining your motivation. Not only will you have someone else to report back to, you'll also be taking part in a structured and realistic programme designed to deliver maximum results in the minimum of time.
You'll start with an initial consultation to assess your current state of health and define your fitness goals - lose weight, improve posture or simply get fitter. This gives you an agreed starting point and a benchmark against which to measure your progress. Your personal training programme will be changed regularly, not only for variety, but also to allow for continued progression.
Group Personal Training
If you've wanted to train with a personal trainer but couldn't justify the cost, Aspire's Group Personal Training is a fantastic way to achieve your exercise goals. Not only is group personal training great value for money as the costs are shared but having the support of others in the group is a fantastic motivator to ensure you get the results you are looking for.
As there are a maximum of 4 people in each group session, you really do get that special attention that you would get from having your own personal trainer. So why not invite your friends to join you so you can take on the challenge and reach your goals as a team!
Boot Camp
Aspire also offer an indoor and ourdoor non military boot camp training programme. This provides a fast-track way to losing weight and getting fit for only 5.50 per week.
For more information or to make a booking call Ian on 07729 194 178 and quote the 'Simply Harrogate website'.
3 years ago I was looking for a personal trainer that could keep me motivated for longer than a couple of weeks. A friend of mine introduced me to Ian and since then I have never looked back. My body shape has changed so much, my muscle tone is the best it's ever been and my energy both during training and on a day to day basis has increased dramatically. I actually look forward to my gym sessions now; I couldnt recommend Ian highly enough!"
"I never enjoyed the gym until I started training with Ian. He always makes the sessions fun & enjoyable. Since starting I have lost 3 & a half stone, I feel amazing!"


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Marvel's Agents of S.H.I.E.L.D - The Hub
A regular guest star on American TV, Saffron Burrows, pops up in this week's episode of Agents of S.H.I.E.L.D. Only a couple of weeks back she was in The Crazy Ones as an object of some male attention, and she has made many such entries onto the small screen, my favourite being her season or so on Boston Legal. There she played an attorney with a dark secret and a neck that obsessed both Alan Shore and Denny Crane. This worked very well as Burrows' image is extraordinary - startlingly beautiful, giraffe elegant, and, above all, exceptional.Which brings me to the subject on review. The ABC network was so sure this series would be a hit that they ordered a full season very early on, but its audience stateside falls from episode to episode and square-eyed comic book fans are not impressed. You see, the draw of this stuff is the fact that all of our big movies currently live in this universe where Gods, genetically altered superheroes and that man in the flying suit all reside. Yet here we are seven episodes into a world that has proved disturbingly prosaic with soap opera tendencies and predictable, easily vanquished villains of the week.
To create some intrigue, we have a resurrected Agent Coulson, a newbie team member with dubious motives and some workplace crushes. This is all wrapped around the end story of The Avengers movie with very occasional nods to the other Marvel movies with cameos from the likes of Samuel L Jackson and Cobie Smulders. Yet, this has proved too little and disturbingly dull so far. Only in episode 3 with an origin story for a later villain and some proper spy action did the show elevate my pulse rate."The Hub" continues the early season fleshing out of the team by sending boffin Fitz out on a dangerous mission with Agent Shaw, the resident team hunk. They have to stop some breakaway separatist terrorist from using some tech...world war 3, yadda yaddy yak. In conventional TV format, the rest of the team worry about them and Sky hacks into Shields computers and discovers that the mission is even more dangerous than we thought and that the swan necked Agent Hand has kept information from Agent Coulson - queue 1:1 confrontation with the diminutive Clark Gregg armed with his trusty stepladder.
The tone is also wildly uneven as the previously restricted Sky digs into more secrets, the underused Simmons shoots a senior officer and slapstick around enduring torture makes up the running time. Above all, there are some serious cracks appearing in the concept. Sky is told to trust in the system, to give up her independent mind and accept S.H.I.E.L.D. as a benevolent overseer, yet clearly Coulson's team are playing by their own quickly re-written rulebook.I suppose this could be because a sub-plot of double agents will follow but I wonder if it's more evidence of lazy writing that hides behind the branding of the show. The lack of excitement is mirrored in the two main arching plot-lines of the show - just how did Coulson survive his death and what is the truth behind Sky's origins. The problem with both is I am not too bothered by either character and would be far more interested if the series developed some credible nemesis or an Arch-villain of its own instead. The whole new crew in training thing is wearing thin and the lack of depth to the characters and weak obvious stereotyping makes the whole thing as distinctive as processed cheese.


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Gold's Lower Price Is a Ruse: Eric Sprott
Eric Sprott founded Sprott Asset Management in 2001, and has been recognized as one of the most influentialMore >
The Sprott Group offers a wide range of investment products and services to U.S, Canadian and International Investors. Sprott Thoughts is an email letter written by Sprott advisors such as Eric Sprott, David Franklin, Henry Bonner and others. They have graciously given Wealth.net permission to reprint their observations here.


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You are here: Home - offer
We kindly invite you to enjoy the services of Hotel ''Jawor'' placed in the centre of Jawor in the Lower Silesia.
Hotel ''Jawor'' is a modern facility matching highest standards. We offer you 10 rooms, among them one adjusted to the use of the handicapped and three suites equipped with hydro massage bathtubs. All rooms have an en-suite bathroom (equipped with a hairndryer), TV set, telephone, mini-bar and Internet access. Soft, pastel colours of the rooms decor will bring you peace, rest and help you to relax. Every morning the hotel's dining room will offer you a delicious buffet breakfast, included in the price of the room.
Furthermore, we offer not only delicious home meals but also exquisite, sophisticated cuisine. It all depends on our guests' tastes and desires. In the drink bar we will fulfill your every wish. A wide range of drinks to choose from, from good Polish vodka to the best American whiskey will quench your thirst and satisfy you during long evenings. In the hotel you can arrange a private birthday party. business meeting or a romantic dinner for two. We will take care of all the details.
At the reception desk you can buy many souvenirs from Jawor. They will make cither a nice remembrance of our city or a great gift for someone close to you. On hotel grounds there is an attended parking monitired around the clock (fee 7zł/day) and garages.
We invite you to enjoy our services!


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Further plans considered for Balcombe oil well site
Plans for further oil and gas exploration at Balcombe have been recommended for approval.
It follows work last summer by energy firm Cuadrilla to test-drill for oil.
A report to West Sussex County Council (WSCC) said planning consent for last year's work expired before operations ended and this plan was for further tests before the well was sealed off.
Three parish councils and 889 third parties oppose the plans, which will be considered by county councillors.
The planning authority has received nine letters of support for the proposals.
Balcombe Parish Council said it opposed the plan after it held a local ballot and 59.8% of voters wanted the parish to object. Ardingly Parish Council raised concerns about close proximity to Ardingly Reservoir and possible water contamination.
Worth Parish Council, meanwhile, has raised concerns about an increase in traffic which it says would be caused.'Tankers of chemicals'
Issues raised by Frack Free Balcombe Residents' Association include the impact that flares and increased traffic would have on the area.
Its letter of objection refers to how close the test site is to residential properties, that tankers of chemicals would pass children's classrooms and a playground, and the impact of noise and pollution.
Campaigners also said future reliance on fossil fuels would undermine climate change obligations.
Fracking protesters from around the country gathered at Balcombe last year amid fears that Cuadrilla's test drilling for oil would lead to hydraulic fracturing - a method of extracting gas or oil from shale rock.
Cuadrilla has said it will not frack for oil at the site, but has said it still wants to test oil supply suitability using flow-testing, which is work to check the quantity and rate at which oil flows to the surface.
The company said it planned to circulate a dilute hydrochloric acid solution along the well to remove drilling mud and help facilitate oil flow.
It said the substance would be classified as non-hazardous at this dilution ratio and it was "an entirely safe process".
West Sussex councillors will look at the plans on 29 April. Officers have recommended that councillors grant permission subject to conditions.


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This adorable boutique style outfit is perfect for your little girl this spring/summer season. The tank top is decorated with a flower on the chest and a ruffled bottom. The outfit is accompanied by an adorable pair of ruffled bottom capri leggings. Made of a 97% high quality soft cotton and 3% stretchy spandex blend, this outfit is soft, comfortable and just in time for summer!
Comfort and Summer Colors! Kids love the comfort of this adorable outfit and the fun colors will make this one your little girl's favorite!
97% soft cotton and 3% stretchy spandex fabric is soft, breathable and flexible. This is the perfect outfit for your little girl this summer! You won't get any fuss about putting this one on!
This set features a sleeveless tunic top decorated with a flower on the chest and a ruffle on the skirt bottom. An adorable pair of ruffled bottom capris completes the summer time look. This is the perfect addition to your little girls spring/summer wardrobe!
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How Much Blood to Cross the Northern Border? Reconsidering the Blood Quantum Requirement of INA §289
I wrote an article that was chosen for academic publication in the nation's first immigration academic journal by AILA (the American Immigration Lawyers Association). The article, below, discusses the Jay Treaty from 1795 that recognized the inherent right of indigenous tribes to pass freely over the USA-Canada border. This Treaty did not grant the right, rather it recognized the right which was ever present since the indigenous groups existed long before borders were formed. But the U.S. has increased the rules in an illegal way. Since the 1950s, the U.S. government has required at least 50% racial purity, denying all other tribal members the ability to cross the border under the Jay Treaty. I propose that this is racial discrimination, an affront to tribal sovereignty, and a dereliction of our international law commitments under the United Nations Declaration on the Rights of Indigenous Peoples.
This obscure area of the law has gone unquestioned for far too long. But one day a random client walked into Pilehvar Law. He is a card-carrying member of a Canadian indigenous tribe with the documentation to prove 25% blood quantum. His family knows that he is 50% blood quantum, but the government doesn't use literal blood tests to determine blood quantum. They require a showing of familial registry in Canada under their Indian Act, which is based on searches of tribal rolls and familial records. But these records are impossible to find for my client and many indigenous families. My client's mother and her family were displaced from their family and assigned by the Crown to a Canadian family. This indigenous assimilation strategy called "the Sixties Scoop" was rampant in Canada from the 1950s-1970s, and also happened in the United States, as discussed in the article. Because of this common issue he and many like him cannot demonstrate that they meet the blood quantum requirement for a "Jay Treaty green card." But I propose that the requirement of 50% racial purity to enjoy a benefit of tribal membership is unconstitutional. These blood quantum laws are tantamount to punishment to tribe members for the miscegenation (interracial breeding) of their ancestors, and an unlawful difference in legal treatment based on racial purity.
The text of the article is below. If you or anybody you know is a Canadian member of a First Nations tribe who is considering moving to the United States, contact Pilehvar Law today.
Should U.S. immigration law determine indigenous status under racial standards or political standards? At a time when national attention is focused along the U.S. southwest border, disparities in the admission of native American Indians seeking to cross our northern border also warrants scrutiny and a fair and humane resolution. This article posits that determining indigenous status by political standards better represents the intent of the underlying law in question and compels a federal statutory implementation that is more in line with modern standards.
The 1795 Jay Treaty recognized the tribal right of free passage over the U.S.-Canada border, but that treaty presently is being implemented in the United States by a statute that has significantly narrowed access to the benefits of the treaty by restricting the tribal right of free passage to those with "at least 50 per centum of blood of the American Indian race." This race-based definition represents an approach that frustrates the antidiscrimination provisions of the Immigration and Nationality Act (INA) and is disfavored by recent developments in numerous areas of law. The statutory deviation from the original treaty language deprives Canadian-born indigenous peoples with less than 50 percent indigenous blood of their right of free passage across the border—a sovereign right of their political class denied solely because of an insufficiency of racial purity.
This article examines section 289 of the Immigration and Nationality Act, entitled "American Indians Born in Canada,"[1] and compares it to the specific provision of the 1795 Jay Treaty that it is intended to implement. The current application of INA §289 is that a qualifying person can come to the U.S.-Canada border with evidence that establishes tribal membership and at least 50 percent blood quantum, at which point the border official, without requiring a fee, will create "a record of admission for lawful permanent residence, even if technically inadmissible or previously deported."[2] The USCIS Adjudicator's Field Manual clarifies that it is "not adjudicating an application to become a lawful permanent resident, [but rather] verifying a status which the person already has and issuing documentation thereof.[3] The 50 percent blood quantum requirement was not contemplated in the Jay Treaty.
The first section discusses the history of the Jay Treaty and its interpretation, including its modern statutory application pursuant to INA §289. The second section discusses the barriers to a legal challenge based solely on INA §289's deviation from the Jay Treaty. The third section contends that INA §289 is out of line with modern evolutions in U.S. immigration law, federal Indian law, and international human rights law. The article suggests that rescission of the statutory blood quantum requirement contained in INA §289 is an appropriate way to strengthen that statute's compliance with antidiscrimination provisions of the INA and to more closely align U.S. immigration law with modern standards of tribal sovereignty and self-determination found in domestic and international law.
I. The Jay Treaty Originally was Interpreted Along Political Rather Than Race-Based Lines
In contrast to the current U.S. race-based definition of "American Indian" in regard to free passage, for which immigration law imposes a blood quantum requirement, the Jay Treaty recognized free passage for "Indians" on a political basis. The rules governing immigration to the United States are derived from a variety of sources, including federal statutes, regulations, treaties, executive orders, and administrative policy. Given the impact of immigration laws on the social and economic character of the United States, consideration of the underlying intent of these laws is warranted to avoid misalignment of existing laws with our progressing social and political values.
I.a The Jay Treaty was originally interpreted to define the designation "Indian" on a political basis
In 1794, shortly after the American Revolution, the U.S. signed a treaty with Great Britain that was intended to stabilize postwar relations between the two countries, including relations with the British-owned colony of Canada that shared a border with the United States. That treaty, known informally as the Jay Treaty,[4] included a provision that recognized the right of indigenous peoples on the North American continent to pass freely across the U.S.-Canada border. It reads in pertinent part as follows:
It is agreed that it shall at all Times be free to His Majesty's Subjects, and to the Citizens of the United States, and also to the Indians dwelling on either side of the said Boundary Line freely to pass and repass by Land, or Inland Navigation, into the respective Territories and Countries of the Two Parties on the Continent of America.[5]
This two-century-old treaty provision remains alive in U.S. immigration law, though it is not being applied in its original form. In 1928, U.S. Congress passed legislation codified at 8 USC §226a to implement U.S. obligations under the Jay Treaty.[6] The 1928 legislation had no blood quantum requirement but did restrict the benefit of admission by adding that adopted tribal members could not enjoy the benefit of free passage. In the years that followed, the Board of Immigration Appeals (BIA) interpreted §226a along political lines. For example, an early BIA case on the subject is Matter of S–, in which a non-native Canadian woman married a native Canadian man, thereby gaining her tribal membership according to the rules of the tribe.[7] Her claim to right-of-passage was vindicated by the BIA, which determined that, with the exception of the statute's bar against membership-by-adoption, the Jay Treaty intended to define "American Indian" along political affiliation lines.[8] Also of note in Matter of S– is the liberal degree of deference given by the BIA to the tribe's own membership requirements. Nevertheless, this era of construction along political lines would not last.
I.b Interpretation of the Jay Treaty shifted to a race-based approach in the mid-20th century
In 1947 a federal district court in New York considered the case of United States ex rel. Goodwin v. Karnuth, which presented facts converse to Matter of S–. In Goodwin, a Canadian-born native woman had married a non-native man, thereby losing her tribal status under then-standing Canadian law.[9] While present in the United States she was placed in deportation proceedings, which she challenged based on §226a, the predecessor to INA §289. The federal court determined that despite being stripped of her political affiliation from the tribe, she was still entitled to the benefits of §226a because she was of tribal blood, thereby relying on racial connotations to establish her inclusion.
While Matter of S– was an administrative decision, Goodwin was the result of the same issue being decided by a federal court. This decision was made in a time that the federal government was transitioning into a period of Indian policy known as the "Termination Era."[10] This period was marked by federal actions intended to dissipate its trust relationship with the natives, curtail tribal sovereignty, and disencumber tribal land for federal government use, often by integrating natives into the American lifestyle and minimizing the importance of tribal membership and decreasing the number of tribal members.[11] This overarching federal goal was consistent with the Goodwin decision, which shifted the Jay Treaty interpretation away from the recognition of membership as decided by sovereign tribes and shifted towards a race-based interpretation, which would also result in a more narrow class of indigenous persons who could enjoy free-passage.
The Goodwin decision ushered in a new era of Jay Treaty interpretation in which "American Indian" was determined along racial lines instead of political ones. In 1952, shortly after this decision, Congress repealed 8 USC §226a and replaced it with INA §289, which is still good law and reads as follows:
Nothing in this title shall be construed to affect the right of American Indians born in Canada to pass the borders of the United States, but such right shall extend only to persons who possess at least 50 per centum of blood of the American Indian race. [Emphasis added.]
Thus, the amended U.S. version of its Jay Treaty obligations imposes a significant restriction on the inherent indigenous right of free passage recognized in the treaty.
The statutory blood quantum requirement of INA §289 is a significant restriction on who can exercise their right of free passage compared to those contemplated in the Jay Treaty, and one that deserves reconsideration in light of antidiscrimination provisions in U.S. immigration law, as well as modern trends in federal Indian law and international law. Whether or not Congress's intent in setting the 50 percent threshold of racial purity was motivated by "Termination Era" goals of eradicating tribal sovereignty and society, the blood quantum requirement in INA §289 could rightly be seen as racial discrimination, a trespass to tribal sovereignty, and a failure of U.S. international political obligations regarding indigenous self-determination. The fact that INA §289 deviates significantly from the treaty on which it is based is not a cause of action to litigate the antiquated statute, though other causes of action could be entertained.
II. INA §289's Deviation from the Jay Treaty is Not Likely Vulnerable to Legal Challenge
The material deviation of INA §289 from the Jay Treaty on which it is based is not a cause of action in U.S. courts, though they would entertain other causes of action in litigation over the statute, such as antidiscrimination (see infra Section III.a). The interplay between international treaties and federal statutes makes a legal challenge based solely on the deviation unlikely to succeed in this case due to the non-self-executing nature of the Jay Treaty, Congress's plenary power over immigration, and other caselaw on the subject.
II.a The Jay Treaty is not enforceable in U.S. courts because it is non-self-executing and must rely upon an implementing statute to become enforceable
International treaties are considered "the law of the land" just like congressional statutes, but they are not automatically enforceable in U.S. courts, as explained by the U.S. Supreme Court in Medellin v. Texas.[12] That case made clear that treaty obligations come in two varieties: self-executing and non-self-executing. The Court distinguished "between treaties that automatically have effect as domestic law, and those that—while they constitute international law commitments—do not by themselves function as binding federal law."[13]
In Medellin, the Court was presented with the question of whether an opinion from the International Court of Justice (ICJ) was binding on U.S. courts by virtue of the United States—at the time—being a party to a treaty in which it agreed to ICJ jurisdiction and certain ICJ protocols. The Court looked at numerous factors to determine whether a treaty is self-executing, or whether only an implementing statute can provide a right of action. In particular, it noted that the language of the relevant treaty obligation did not "indicate that the Senate that ratified the [treaty] intended to vest [it] with immediate legal effect in domestic courts" and that instead the treaty language "[called] upon governments to take certain action."[14] The Court ultimately held that the relevant treaty was not self-executing and therefore no private right of action existed unless and until Congress enacted an implementing statute.
Similar to the treaty in Medellin, the Jay Treaty language does not suggest that it was intended to be self-executing. For example, Article III of the Jay Treaty, which deals with the indigenous right of free passage, reads in part: "It is agreed, that the respective Governments will mutually promote this amicable Intercourse, by causing speedy and impartial Justice to be done, and necessary protection to be extended, to all who may be concerned therein" (emphasis added).[15] This language implies that the Jay Treaty was intended to be non-self-executing and therefore can only be enforced domestically through its implementing statute. As such, a Canadian-born tribal member cannot seek judicial relief in U.S. courts for suspected immigration violations based solely on the treaty.
II.b The material deviation of INA §289 from the Jay Treaty is not likely to be vindicated in U.S. courts
The Jay Treaty was not a grant of the right of free passage to Canadian-born natives but rather a recognition of the indigenous population's inherent right of free passage. This inherent right has been severely restricted by the addition of a blood quantum requirement in INA §289. But a lateral attack on the statute based on its material and substantive departure from the Jay Treaty is likely to fail for a number of reasons.
Established precedent holds that when statutes and treaties conflict one another, each being "the supreme law of the land," that which is "last in date must prevail in the courts."[16] In regard to indigenous free passage, INA §289 would be considered the governing law because it was enacted more than a century after the Jay Treaty. Accordingly, there is no recourse in U.S. courts based solely on the fact that a statute deviates from the treaty it is intended to implement, no matter how material the deviation.[17] Making litigation more difficult is the fact that Congress has plenary power over immigration laws.
Congress can enact statutes that contradict international treaties. The indigenous right of free passage in the Jay Treaty has been held as above the reproach of immigration laws unless specifically exempted.[18] The addition of the blood quantum requirement in INA §289 would likely be considered a very specific exemption that would be upheld under existing precedent.
The U.S. Supreme Court considered this subject during the Chinese Exclusion Case, or Chae Chan Ping v. United States.[19] The Chinese Exclusion Case involved an 1868 treaty between the United States and China that granted certain immigration benefits to Chinese nationals.[20] Years later, Congress passed the Chinese Exclusion Act of 1882 and the Scott Act of 1888, which collectively curtailed the immigration benefits previously granted to Chinese nationals by treaty.[21] Mr. Chae Chan Ping was in the middle of returning to the United States from a visit to China when Congress changed its policy on Chinese immigration, suddenly rendering defunct his reentry permit.[22] He filed suit after being excluded at the border and his case reached the Supreme Court, which affirmed his exclusion despite the fact that it violated the treaty with China. The Court espoused the plenary nature of Congress's power over immigration, stating the following:
The powers of government are delegated in trust to the United States, and are incapable of transfer to any other parties. . . . The exercise of these public trusts is not the subject of barter or contract. Whatever license, therefore, Chinese laborers may have obtained [to reenter the United States] is held at the will of the government, revocable at any time, at its pleasure.
While federal courts might entertain a lawsuit based on a different cause of cause of action (see infra Section III.a), they are unlikely to order that the language of a statute be changed solely because it deviates from the treaty on which it is based. Accordingly, any challenge to INA §289 would need to be based on other causes of action, or Congress could modify the language of INA §289 on its own accord. Numerous evolutions in the legal and social landscapes that touch on this subject matter indicate that social trends are no longer in line with the race-based approach in INA §289, and that the blood quantum requirement is out of line with U.S. immigration law and modern practices regarding the concepts of tribal sovereignty and self-determination.
III. Modern Legal Trends Are Not Ideologically Aligned with the Blood Quantum Requirement of INA §289
Despite the difficulty of a legal challenge to the INA's current blood quantum requirement for Canadian-born indigenous persons who wish to cross the U.S.-Canada border, a number of legal developments have occurred since the 1952 passage of INA §289 that are ideologically incongruent with the statute as it now stands. This article proposes that current legal trends in federal Indian law and international human rights law would be in line with a congressional reconsideration of the blood quantum requirement in INA §289. Doing so would bolster that statute's compliance with antidiscrimination provisions of the INA and reaffirm modern U.S. commitments to tribal sovereignty as well as the related concept of self-determination.
III.a The current language of INA §289 is out of line with the antidiscrimination provisions of the Immigration and Nationality Act
INA §289 acknowledges the tribal right of free-passage as memorialized in the Jay Treaty, but refuses that right to tribal members born in Canada who lack the sufficient quantum of "blood of the American Indian race."[23] This requirement, absent in the treaty itself, is tantamount to discrimination based on racial impurity, depriving tribal members of their treaty-protected right of free passage, and in effect, punishing tribal members because of the miscegenation of their ancestors.
The blood quantum requirement of INA §289 could be interpreted as a violation of the antidiscrimination provision of the INA, which provides at 8 USC §1152(a)(1)(A) that "no person shall receive any preference or priority or be discriminated against in the issuance of an immigrant visa because of the person's race, sex, nationality, place of birth, or place of residence" (emphasis added). The Jay Treaty was originally interpreted according to an individual's political affiliation with tribes rather than the current race-based interpretation of INA §289 (see supra Section I.a). A return to the political interpretation of "Indian" would insulate INA §289 against any claim of race-based discrimination.
The issue of discrimination in U.S. immigration law recently was in the world spotlight when President Trump issued an executive order (EO) suspending the entry of nationals from certain countries, known informally as the "travel ban."[24] Although the executive order purported to disqualify or preclude the admissibility of persons from certain countries, critics of the EO contended that in practice it essentially banned the admission of persons based on race and religion. Nationals of banned countries challenged the constitutionality of the travel ban in Trump v. Hawaii.[25] In that litigation, the State of Hawaii and the aggrieved non-U.S. citizen plaintiffs claimed that the president's executive order was discriminatory due to, inter alia, pre- and post-inauguration statements by the president that would lead a "reasonable observer [to] conclude that the Proclamation was motivated by anti-Muslim animus."[26]
The president's first two attempts at imposing the travel ban were judicially estopped before his third attempt was affirmed by the Supreme Court after the addition of specific national-security concerns, the addition of some non-Muslim countries, and other procedural changes.[27] The Court looked at the facial language of the president's order, ruling that "The Proclamation is expressly premised on legitimate purposes: preventing entry of nationals who cannot be adequately vetted and inducing other nations to improve their practices. The text says nothing about religion."[28] The Court upheld the executive order.
Unlike the travel ban, the statutory language of INA §289 is facially race-based, requiring at least 50 percent "blood of the American Indian race." Further distinguishing the travel ban from INA §289 is the fact that the former was based on and judicially upheld because of presidential powers during exigent circumstances, while the latter is a congressional creation that is not based on any national security interest or other exigency. These distinctions would support a lawsuit against the U.S. government for the race-based discrimination of INA §289, as would other precedent regarding the INA's antidiscrimination provisions.
The antidiscrimination aspect of the INA was also discussed in the LAVAS case (filed by the group named Legal Assistance for Vietnamese Asylum Seekers).[29] In that case, Vietnamese refugees who had escaped their war-torn country into Hong Kong were refused consular processing by U.S. officials in the Hong Kong consulate because of a new policy issued in reaction to the high number of Vietnamese refugees.[30] They filed suit, claiming that the consulate's refusal to serve them was a violation of the INA's antidiscrimination law in 8 USC §1152(a).[31]
The government argued that it must merely demonstrate a rational basis for the discriminatory action being taken, which it stated was "the goal of encouraging voluntary repatriation" of Vietnamese nationals to Vietnam.[32] But the D.C. Circuit Court of Appeals reversed and remanded the case, stating that the government's actions should be judged with a higher scrutiny than mere rational basis. It said, "While we need not decide in the case before us whether the State Department could never justify an exception under the provision, such a justification, if possible at all, must be most compelling — perhaps a national emergency" (emphasis added).[33]
The dicta in the LAVAS case indicates that discriminatory immigration laws are held to a strict scrutiny standard: i.e., the discriminatory action must be in furtherance of a compelling government interest and must be narrowly tailored to achieve that interest—the highest level of judicial scrutiny. Even without explicitly specifying that this matter was held to strict scrutiny, the court was clear that discriminatory actions by Congress would only be approved in response to the "most compelling" circumstances." That court even cited another case that stated that "under 8 U.S.C. Sec. 1152(a), INS has no authority to discriminate on the basis of national origin, except perhaps by promulgating regulations in a time of national emergency."[34] Just like for the cessation of consular processing for Vietnamese nationals in the LAVAS case, the government has not espoused any exigent reasons to discriminate against those Canadian-born indigenous persons whose racial composition is below 50 percent blood quantum.
The above cases demonstrate that 8 USC §1152(a) prohibits immigration laws from discriminating on the basis of race, religion, or nationality in the absence of a national exigency. Accordingly, these cases support the proposition that the blood quantum requirement in INA §289 is a violation of – or at least offends the thrust of — the INA's antidiscrimination provision in 8 USC §1152(a) because it treats Canadian-born indigenous persons differently on the basis of their racial composition. Among the Canadian-born indigenous persons whose free passage was recognized in the Jay Treaty, INA §289 treats the tribal member having at least 50 percent "blood of the American Indian race" differently from a person with a lower blood quantum.
The language of the Jay Treaty, especially as it was originally interpreted, would not be considered racially discriminatory because it treated the term "Indian" as a political designation instead of a racial one. Congress can cure the facially discriminatory nature of INA §289 by rescinding its blood quantum requirement and determining qualification based on political affiliation with recognized indigenous groups. This modification would not only bolster INA §289's compliance with antidiscrimination provisions of the INA, but it would also bring the government's approach to that statute more in line with progressive legal trends relating to tribal sovereignty and self-determination.
III.b The principle of tribal sovereignty is offended by the blood quantum requirement of INA §289
The United States' relationship with its "domestic dependent" tribes is a unique one in which federally recognized tribes are considered sovereign entities, but are nonetheless under the protection and plenary power of Congress.[35] Of utmost importance in this ward-guardian relationship is the preservation of tribal sovereignty to the fullest extent permissible under the U.S. Constitution. Although this government responsibility does not extend to tribes or tribal members in Canada, the principle of indigenous sovereignty compels the U.S. to treat indigenous populations on both sides of the border in an ideologically and practically consistent manner.
A key component of tribal sovereignty is the question of "who:" who gets to become a member, who gets to make the rules of membership, who gets to make membership decisions. The U.S. government ultimately leaves this question to each tribe, stating on the official Department of Interior website that "Tribal enrollment criteria are set forth in tribal constitutions, articles of incorporation or ordinances. The criterion varies from tribe to tribe, so uniform membership requirements do not exist."[36] Some situations may seem like exceptions, but they are not. For example, some tribes' membership decisions are reviewed by U.S. federal agencies, but this is because those tribes drafted constitutions in which they expressly ceded certain membership decisions to the U.S. Bureau of Indian Affairs.[37] The tribal sovereignty wasn't destroyed but rather was affirmatively exercised in a way that invited U.S. involvement.
A more pertinent example of tribal sovereignty involving the United States is the Cherokee Freedmen controversy, recently settled in Cherokee Nation v. Nash, in which a tribal scheme to disenroll lineal members of their former slaves was barred based on a treaty between the United States and the tribe.[38] The Nash controversy arose in the 1990s when the Cherokee Nation began rejecting qualified membership applicants and eventually disenrolled members whose claims were based on lineal descendancy from the "freedmen" tribal members, former black slaves of the Cherokee who became members of the tribe according to an 1866 treaty with the United States after the Civil War.[39] In 2007 the Cherokee Nation modified its constitution to eject the freedmen descendants by limiting citizenship to "to only those persons who were Cherokee, Shawnee, or Delaware by blood."[40] The aggrieved descendants of the freedmen filed suit. A decade of litigation culminated in the 2017 decision by the D.C. federal district court, which held that because the Cherokee nation endowed the freedmen and their descendants with membership, they were to be treated on equal-footing to native-blooded members of the tribe, thereby barring the disenrollment of the freedmen descendants.[41]
The Nash case is relevant because of its bearing on the modern approach to tribal sovereignty, membership decisions, and the definition of "American Indian." The Cherokee Nation had ultimate sovereignty over its membership decisions, which it modified by treaty to include the freedmen, and only triggered U.S. involvement when the Cherokee violated a treaty they signed with the United States decades ago.[42] Even though the U.S. government held the tribes to the terms of the 1866 treaty, it was merely enforcing a decades-old membership decision that the tribe made by treaty in its sovereign capacity. In this sense, the government's action reflects respect for the tribe's sovereignty by enforcing the tribe's own treaty obligations regarding membership.
The statute at INA §289 is a unique U.S. immigration law that deals with indigenous status, and it should ideally be consistent with U.S. federal Indian laws. Though they are distinct legal subject matters, they both deal with U.S. policy towards indigenous peoples. Accordingly, they should be guided by consistent principles. To demonstrate the current inconsistency in the two, imagine if the Cherokee Nation's ancestral territory straddled the U.S.-Canada border. How would the U.S. government apply the ruling in Nash? To only recognize the citizenship of freedmen descendants on one side of the border would be an absurd application of the decision, but the blood quantum requirement of INA §289 would not give a Canadian-born freedman descendant the same rights as the members of his tribe with "blood of the American Indian race," as Nash requires. The Nash opinion states that the freedmen descendants "have a right to citizenship in the Cherokee Nation that is coextensive with the rights of native Cherokees."[43]
The race-based interpretation of "American Indian" being applied in the immigration context under INA §289 is ideologically incongruent with the government's position in Nash. In Nash, the U.S. government enforced a treaty that was clearly based on political status, and not race. In light of the recent landmark decision in Nash, it is time for Congress to reexamine the issue and increase respect for tribal sovereignty by removing the blood quantum requirements from INA §289.
III.c International obligations to respect self-determination will be advanced by the removal of blood quantum requirements from INA §289
In addition to its self-imposed ward-guardian obligations to its domestic dependent tribes, the United States also has made international commitments to respect the self-determination of such tribes under the recent United Nations Declaration on the Rights of Indigenous Peoples (U.N. DRIP).[44] Self-determination, closely related to tribal sovereignty, is the idea that a group of affiliated peoples can "freely determine their political status and freely pursue their economic, social and cultural development."[45] The United States expressed its support for the U.N. DRIP in 2010,[46] agreeing to adhere to international law obligations to treat the provisions therein as the "minimum standards for the survival, dignity and well-being of the indigenous peoples of the world" (emphasis added).[47]
Like many international human-rights instruments, the U.N. DRIP is not strictly binding and it is not a self-executing treaty. Nonetheless, the United States has willfully expressed support for it, and therefore assented to a number of provisions having a direct bearing on the application of INA §289, including provisions on border crossings and membership determinations. For example, Article 36 of the U.N. DRIP is directly on point regarding this subject, providing:
Indigenous peoples, in particular those divided by international borders, have the right to maintain and develop contacts, relations and cooperation, including activities for spiritual, cultural, political, economic and social purposes, with their own members as well as other peoples across borders.
States, in consultation and cooperation with indigenous peoples, shall take effective measures to facilitate the exercise and ensure the implementation of this right.
The language of Article 36 makes clear that the U.S. commitment to allow free passage for indigenous peoples is to be based on their membership, and the U.N. DRIP does not qualify this obligation with race-related requirements such as blood-quantum. Notably, the U.N. DRIP does not provide a definition for indigenous peoples. Rather, it places membership decisions squarely with the tribes themselves, stating in Article 33:
Indigenous peoples have the right to determine their own identity or membership in accordance with their customs and traditions. This does not impair the right of indigenous individuals to obtain citizenship of the States in which they live.
The concept that tribes should choose and apply their own membership rules is one that touches on both sovereignty and self-determination. This is the foundation of the "political" approach to defining "American Indian." Indigenous tribes should have the right to decide in a sovereign capacity whether or not to require a blood quantum for membership, if one is to exist for any purpose. In the absence of such a requirement by the tribe itself, any denial of benefits (such as free passage under INA §289) based on insufficient blood quantum is an infringement of indigenous rights, placing the United States in contravention to its political obligations under the U.N. DRIP. Accordingly, U.S. political commitments in the U.N. DRIP would be greatly advanced by a congressional rescission of the blood quantum requirement from INA §289.
The blood quantum requirement in INA §289 does not exist in the Jay Treaty. The U.S. definition of "American Indian" at the time that INA §289 was enacted was based on racial factors, an approach that this article suggests is antiquated and most likely in violation of the spirit, if not the letter, of the antidiscrimination provisions in immigration law.
Precedent shows that immigration laws that distinguish classes based on race or nationality must pass strict scrutiny, and the blood quantum requirement in INA §289 is susceptible to failing even the more lax rational-basis test. Further, there have been major shifts in federal Indian law and international law since 1952, when that statute was enacted. The 2010 U.S. accession to the U.N. Declaration of the Rights of Indigenous Peoples introduced an international political commitment to respect tribal free-passage as well as tribal membership decisions. The 2017 decision in Cherokee Nation v. Nash was a watermark decision upholding a definition of membership based on political connotations.
These important developments indicate a progressive new approach to the relationship between the rights of indigenous peoples and the territories they may occupy, both foreign and abroad. These evolutions in indigenous relations should demonstrate to Congress that the United States is committed to fully respecting tribal sovereignty and membership on a political basis instead of perpetuating the current enforcement of vestigial race-based requirements. Elimination of the blood quantum requirement of INA §289 would bring U.S. immigration laws in line with immigration antidiscrimination provisions, modern federal Indian law principles, and U.S. international obligations under the U.N. DRIP. As such, this article urges Congress to rescind the blood quantum requirement of INA §289 and fully implement the Jay Treaty by defining "American Indian" for immigration purposes along political lines according to the membership decisions of recognized indigenous groups.
[1] Immigration and Nationality Act (INA) §289 is codified at 8 USC §1359.
[2] Department of Homeland Security, United States Citizenship and Immigration Services, Adjudicator's Field Manual, Redacted Public Version, 23.8 ("Section 289 Cases"), available at www.uscis.gov/ilink/docView/AFM/HTML/AFM/0-0-0-1/0-0-0-8624/0-0-0-10065.html.
[3] Id.
[4] Treaty of Amity, Commerce, and Navigation, Between His Britannick Majesty;—and the United States of America, By Their President, with the Advice and Consent of Their Senate, Nov. 19, 1794, U.S.-U.K., T.S. No. 105 [hereinafter Jay Treaty].
[5] Id. art. III (emphasis added).
[6] An Act To Exempt American Indians born in Canada from operation of the Immigration Act of 1924, Pub. L. No. 234, ch. 308, 45 Stat. 401 (Apr. 2, 1928) (formerly codified at 8 USC §226a, reading: "Be it enacted [that the Immigration Act of 1924] shall not be construed to apply to the right of American Indians born in Canada to pass the borders of the United States: Provided, That this right shall not extend to persons whose membership in Indian tribes or families is created by adoption."
[7] In the Matter of S–, 1 I&N Dec. 309 (BIA 1942).
[8] Id.
[9] United States ex rel. Goodwin v. Karnuth, 74 F. Supp. 660 (W.D.N.Y. 1947).
[10] Charles F. Wilkinson and Eric R. Biggs, The Evolution of the Termination Policy, 5 Am. Indian L. Rev. 139, 145 (1977).
[11] Id. at 145–50.
[13] Id. at 504.
[14] Id. at 508.
[15] Jay Treaty, supra note 4, at art. III.
[16] J. Ribas y Hijo v. United States, 194 U.S. 315, 324 (1904).
[17] For example, U.S. immigration laws on refugees deviate from international laws on refugees in conventions to which the United States is a party. See generally, Note: American Courts and the U.N. High Commissioner for Refugees: A Need for Harmony in the Face of a Refugee Crisis, 131 Harv. L. Rev. 1399 (2018).
[18] See, e.g., United States v. McCandless, 18 F.2d 282 (E.D. Pa. 1927), stating, "The turning point of the cause is [whether] the Indians are included among the members of the alien nations whose admission to our country is controlled and regulated by the existing immigration laws. The answer, it seems to us, is a negative one. From the Indian viewpoint, he crosses no boundary line. For him this does not exist."
[19] Chae Chan Ping v. United States, 130 U.S. 581 (1889).
[20] Id. at 590.
[21] Id. at 592–99.
[22] Id. at 582.
[24] Exec. Order No. 13,780, 82 Fed. Reg. 13,209 (Mar. 9, 2017), expanded by Proclamation No. 9,645 (Sept. 24, 2017), suspending the entry into the United States of nationals of Iran, Libya, Somalia, Sudan, Syria, and Yemen.
[25] Trump v. Hawaii, 585 U.S. ___ , 138 S. Ct. 2392 (2018).
[26] Id. (Sotomayor, dissenting).
[27] Id., slip op. at 2–8.
[28] Id. slip op. at 34.
[29] Legal Assistance for Vietnamese Asylum Seekers v. Dep't of State Bureau of Consular Affairs, 45 F.3d 469 (D.C. Cir. 1995).
[30] Id. at 470–71.
[31] Id. at 472–73.
[32] Id. at 473.
[33] Id.
[34] Id.
[35] Cherokee Nation v. Georgia, 30 U.S. (5 Pet.) 1 (1831).
[36] Dep't of the Interior, Tribal Enrollment Process, www.doi.gov/tribes/enrollment (last visited Jan. 24, 2019).
[37] E.g., Miranda v. Jewell, No. 15-55245, ¶ 6 (9th Cir. Dec. 9, 2016), https://cdn.ca9.uscourts.gov/datastore/memoranda/2016/12/19/15-55245.pdf. See also 25 CFR §§62.2, 62.10.
[38] Cherokee Nation v. Nash, No. 13-01313 (D.D.C. Aug. 30, 2017), https://ecf.dcd.uscourts.gov/cgi-bin/show_public_doc?2013cv1313-248.
[39] Id. at 2.
[40] Id. at 34.
[41] Id. at 76–78.
[42] Id. at 77.
[43] Id. at 78.
[44] United Nations Declaration on the Rights of Indigenous Peoples, G.A. Res. 61/295, U.N. Doc. A/RES/61/295 (Sept. 13, 2007), art.46 I.L.M. 1013 (2007) [hereinafter U.N. DRIP].
[45] U.N. DRIP, art. 3.
[46] See Remarks at the White House Tribal Nations Conference, 2010 Daily Comp. Pres. Doc. 201001076 (Dec. 16, 2010), www.gpo.gov/fdsys/pkg/DCPD-201001076/pdf/DCPD-201001076.pdf. See also Dep't of State, Announcement of U.S. Support for the United Nations Declaration on the Rights of Indigenous Peoples (2010), https://2009-2017.state.gov/documents/organization/154782.pdf (offering review of U.S. position on the Declaration).
[47] U.N. DRIP, art. 43.
Taymoor Pilehvar
Taymoor Pilehvar
www.Pilehvar.com / IG: @pilehvarlaw
Taymoor M. Pilehvar is a U.S. immigration attorney out of Fort Lauderdale, Florida. He is a frequent volunteer for the Florida Immigrant Coalition and Americans for Immigrant Justice. Mr. Pilehvar serves as alumnus advisor to the Center for International Business and Human Rights at the University of Oklahoma College of Law, where he attained his J.D. and served as editor for the American Indian Law Review. Mr. Pilehvar has presented on business immigration strategies, corporate compliance, and other immigration matters. He is also a repeat invitee to an international law conference at the University of Manitoba as a panelist presenter and was chosen for publication in the textbook Nuclear Non-Proliferation in International Law (vol. IV) for his article on indigenous engagement in the uranium extraction industry.
Hon. Lory D. Rosenberg
Collaborator and Legal Mentor
Lory Rosenberg
Lory D. Rosenberg is the CEO of IDEAS Consultation and Coaching, a senior advisor and attorney at Immigrant Defenders Law Group, and a sought-after immigration lawyer, mentor, and certified professional and personal empowerment coach. Ms. Rosenberg provides cutting-edge legal analysis and strategies to resolve complex cases and appeals, and helps attorneys overcome business, personal, and financial blocks, manage stress and mindset challenges, and take action to reconnect with their vision of making a difference. A national speaker and trainer, Ms. Rosenberg is active in efforts to defend due process and humanize brutal immigration enforcement processes. She has served as an appellate judge on the Board of Immigration Appeals, is co-author of Immigration Law and Crimes, and was an adjunct professor at American University, Washington College of Law. Ms. Rosenberg has practiced immigration defense law for over 35 years as a director of the AIC Legal Action Center, director of the NLADA Defending Immigrants Partnership, counsel for immigrant and refugee clients in legal services and private practice, and founder of the Centro Presente asylum seekers' pro bono program. Ms. Rosenberg is the recipient of AILA's Arthur Helton Human Rights Award, and the Edith Lowenstein Award for Advancing the Practice of Immigration Law.


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