Strickland v. Washington Supreme Court Case, Arguments, Impact

In Strickland v. Washington (1986) the U.S. Supreme Court designed standards for determining when an attorney’s assistance has been so ineffective that it creates a violation of the Sixth Amendment. Fast Facts: Strickland v. Washington Case Argued: January 10, 1984Decision Issued: May 14, 1984Petitioner: Charles E. Strickland, Superintendent, Florida State PrisonRespondent: David Leroy WashingtonKey Questions: Is there a standard for courts to use when evaluating claims of ineffective counsel?Majority Decision: Justices Burger, Brennan, White, Blackmun, Powell, Rehnquist Stevens, O’ConnorDissenting: Justice Thurgood MarshallRuling: David Washingtons attorney provided effective assistance, in accordance with Sixth Amendment requirements. In order to prove ineffective assistance, a defendant must show that his or her attorney’s performance was deficient and that the deficiency prejudiced the defense so much that it changed the outcome of the legal proceeding. Facts of the Case David Washington participated in a 10-day crime spree that included three stabbings, burglary, assault, kidnapping, torture, attempted extortion, and theft. He was indicted for three counts of first-degree murder and multiple counts of kidnapping and robbery in the state of Florida. Washington confessed to two murders against his counsel’s advice. He waived his right to a jury trial and plead guilty to all charges against him, including three counts of murder in which he could receive capital punishment. At his plea hearing, Washington told the judge he had committed the burglaries, which escalated to more serious crimes, while under extreme financial stress. He said he had no prior record. The judge told Washington he had a great deal of respect for people who are willing to admit responsibility. At the sentencing hearing, Washington’s attorney chose not to present any character witnesses. He did not order a psychiatric evaluation of his client. The judge sentenced Washington to death, finding no mitigating circumstances to decide otherwise. Washington eventually filed a writ of habeas corpus in a Florida federal district court. The U.S. Court of Appeals for the Fifth Circuit reversed, remanding the case down to district court to determine whether or not a â€Å"totality of the circumstances† suggested Washington’s counsel had been ineffective. The Supreme Court granted certiorari. Arguments Washington argued that his counsel failed to conduct a proper investigation leading up to the sentencing hearing. This left his attorney unable to offer evidence during the hearing, damaging Washingtons overall defense. In oral arguments, the attorney before the Supreme Court argued that any standard for deciding whether counsel has been â€Å"reasonably competent† should take into account whether or not counsels failure to offer adequate assistance harmed the defense. The state of Florida argued that the Court should consider the overall fairness of the trial and whether or not the attorney acted out of prejudice. While Washington’s attorney may not have done everything perfectly, he did what he believed was in the best interest of his client, the state argued. Additionally, the actions of Washington’s attorney did not alter the fundamental fairness of the sentencing proceeding; even if the attorney had acted differently, the outcome would have been similar. Constitutional Issues How can a court determine when an attorney has been so ineffective in providing advice that a defendants Sixth Amendment right to counsel was violated? Majority Opinion Justice Sandra Day O’Connor delivered the 8-1 decision.  The Sixth Amendment right to counsel exists to ensure a fair trial, Justice OConnor wrote. Having an attorney physically present is not enough to satisfy the Sixth Amendment; the attorney must offer effective assistance to their client. If the defendants counsel fails to offer adequate legal assistance, it jeopardizes the defendants Sixth Amendment right to counsel and a fair trial. Justice OConnor, on behalf of the majority, developed a standard for determining whether an attorney’s conduct â€Å"fell below an objective standard of reasonableness.† The defendant must prove: Counsel’s performance was deficient. The attorney’s errors were so serious that they prevented the attorney from fulfilling their duty under the Sixth Amendment.Counsel’s deficient performance prejudiced the defense. The attorney’s actions harmed the defense so badly that it altered the outcome of the trial, depriving the defendant of their right to a fair trial. Justice OConnor wrote: The defendant must show that there is a reasonable probability that, but for counsels unprofessional errors, the result of the proceeding would have been different. A reasonable probability is a probability sufficient to undermine confidence in the outcome. After detailing the standard itself, Justice OConnor turned to Washingtons case. Washingtons attorney strategically chose to focus on his clients sense of remorse because he knew the judge might be sympathetic to it. In light of the seriousness of the crimes, Justice OConnor concluded that there was no proof additional evidence would have changed the outcome of the sentencing hearing. Here is a double failure, she wrote, noting that Washington could not succeed under either component of the Courts standard. Dissenting Opinion Justice Thurgood Marshall dissented. He argued that the majoritys standard was too malleable and could have no grip at all or allow excessive variation. Justice Marshall pointed out the fact that terms like reasonable were not defined in the opinion, creating uncertainty. He also argued that the Court had discounted the importance of mitigating evidence like character witnesses at sentencing hearings. Washingtons attorney had not given his client effective assistance and he deserved a second sentencing hearing, Justice Marshall wrote. Justice William J. Brennan dissented, in part, because he believed Washington’s death sentence violated the Eighth Amendment protection against cruel and unusual punishment. Impact Washington was executed in July 1984, two months after the Supreme Court handed down its decision. He had exhausted all avenues of appeal. The Strickland standard was a compromise which sought to create a middle ground between more extreme and more relaxed state and federal standards for ineffectiveness claims. Two decades after the decision, Justice O’Connor called for the Strickland standard to be revisited. She noted that the standards did not account for outside factors, such as partisan judges and lack of legal aid that could contribute to ineffective counsel under the Sixth Amendment.  The Strickland standard was applied as recently as 2010 in Padilla v. Kentucky. Sources Strickland v. Washington, 466 U.S. 668 (1984).Kastenberg, Joshua. â€Å"Nearly Thirty Years: The Burger Court, Strickland v. Washington, and the Parameters of the Right to Counsel.†Ã‚  The Journal of Appellate Practice and Process, vol. 14, no. 2, 2013, pp. 215–265., https://papers.ssrn.com/sol3/papers.cfm?abstract_id3100510.White, Lisa. â€Å"Strickland v. Washington: Justice OConnor Revisits Landmark Legislation.†Ã‚  Strickland v. Washington (January-February 2008) - Library of Congress Information Bulletin, https://www.loc.gov/loc/lcib/08012/oconnor.html.

Why Marine Life Is So Diverse in the Gulf of Maine

The Gulf of Maine is one of the most important marine habitats in the world and home to a wealth of marine life, from giant blue whales to microscopic plankton. Overview The Gulf of Maine is a semi-enclosed sea that covers 36,000 square miles of ocean and runs along 7,500 miles of coastline, from  Nova Scotia,  Canada,  to  Cape Cod,  Massachusetts. The Gulf is bordered by three New England states  (Massachusetts, New Hampshire, and Maine) and two Canadian provinces (New Brunswick and Nova Scotia). Water depths in the Gulf of Maine range from zero feet to several hundred feet. The deepest spot is 1,200 feet and is found in Georges Basin. The Gulf of Maine has many dramatic underwater features, which were carved out by glaciers  10,000 to 20,000 years ago. History The Gulf of Maine was once dry land covered by the Laurentide Ice Sheet, which advanced from Canada and covered much of New England and the Gulf of Maine about 20,000 years ago. At that time, the sea level was about 300 to 400 feet below its current level. The weight of the ice sheet depressed the Earths crust, and as the glacier retreated, the area that is now the Gulf of Maine filled in with seawater. Types of Habitat The Gulf of Maine is home to a variety of different habitats. They include: Sandy banks (such as Stellwagen Bank and Georges Bank)Rocky ledges (such as Jeffreys Ledge)Deep  channels (such as the Northeast Channel and Great South Channel)Deep basins with water depths over 600 feet (such as the Jordan, Wilkinson and Georges Basins)Coastal areas near the shore, whose bottoms are composed of rocks, boulders, gravel, and sand Tides The Gulf of Maine has some of the greatest tide ranges in the world. In the southern Gulf of Maine, including the area around Cape Cod, the range between high tide and low tide may be as low as four feet. But the Bay of Fundy, which borders the northern Gulf of Maine, has the highest tides in the world. Here, the range between low and high tide can be as great as 50 feet. Marine Life The Gulf of Maine supports over 3,000 species of marine life. They include: About 20 species of whales and dolphinsFish, including Atlantic cod, bluefin tuna, ocean sunfish, basking sharks, thresher sharks, mako sharks haddock, and flounderMarine invertebrates such as lobsters, crabs, sea stars, brittle stars, scallops, oysters, and musselsMarine algae, such as kelp, sea lettuce, wrack, and Irish mossPlankton, which provide food for many larger marine species that live in the Gulf of Maine Scientists believe the Gulf is probably home to many more unidentified species, including small worms and microscopic bacteria. Information about individual marine species is available from the states Department of Marine Resources. Human Activity The Gulf of Maine is an important area, both historically and today, for commercial and recreational fishing. It is also popular for recreational activities such as boating, wildlife watching (such as whale watching), and scuba diving (although the waters can be chilly). Threats to the Gulf of Maine include  overfishing, habitat loss, and coastal development.

Man, Gandhi, Pope Francis, And Nelson Mandela - 808 Words

The littlest bit of inspiration can entice people to cause a lot of change. 3 men, Gandhi, Pope Francis, and Nelson Mandela were the people that provided the Inspiration. Although Gandhi, Pope Francis, and Nelson Mandela all enticed change in different ways, they all demonstrated patience, persistence, and courage . Nelson Mandela enicted change in his persistent and Courageous ways, he formed armed resistances, spent time in prison, and led protests. According to Biography.com Editors â€Å"In 1961, Nelson Mandela co-founded and became the first leader of Umkhonto we Sizwe (â€Å"Spear of the Nation†)† (Nelson Mandela). By Nelson forming this resistance against the government it showed the lengths he was willing to go for his cause and showed the†¦show more content†¦I prefer a Church which is bruised, hurting, and dirty because it has been out on the streets, rather than a Church which is unhealthy from being confined and from clinging to its own security, Po pe Francis’ willingness to openly call out and go against the church proves his courage in his battle for human rights. The Biography.com Editors also stated in the article â€Å"Pope Francis† , â€Å"It was not long after assuming the papacy that Pope Francis began offering more nuanced views and interpretations on key social issues about which the church holds more doctrinal views on. Thus resulting in many death threats coming in to the Pope.† This shows the courage and Persistence the Pope has in his mission for he still speaks his views as he receives death threats regularly. Lastly, Gandhi changed how we see Human rights movement with his virtues of patience, peace, and courage. In the article â€Å"Mahatma Gandhi† on Biography.com the text states, â€Å"Revered the world over for his nonviolent philosophy of passive resistance, Mohandas Karamchand Gandhi was known to his many followers as Mahatma, or â€Å"the great-souled one† As you can see Gandhi was worshipped worldwide for his peaceful and persistent ways of protesting, which proves his dedication to the cause of human rights. AnotherShow MoreRelatedThe 1982 movie Gandhi, starring Ben Kingsley and Candice Bergen had both strengths and weaknesses.2500 Words   |  10 PagesThe 1982 movie Gandhi, starring Ben Kingsley and Candice Bergen had both strengths and weaknesses. One of the movies weaknesses was that it left a lot of gaps. It is understandable why they had to leave a lot of gaps. The movie was supposed to depict the whole life of Gandhi. If they had of put every detail of Gand hi’s life, every year of every sentence he spent in jail, the movie would be way longer than three plus hours. I just think that they could have better picked and chosen which parts toRead MoreOne Significant Change That Has Occurred in the World Between 1900 and 2005. Explain the Impact This Change Has Made on Our Lives and Why It Is an Important Change.163893 Words   |  656 Pagesprimarily by opportunities for economic advancement—including the massive movement of rural agriculturalists to rapidly growing urban areas—but also the often-neglected displacements of populations that resulted from the wars, revolutions, and natural and man-made disasters of the twentieth century. Howard Spodek’s essay charts the development of the urban areas that have been the destination for the great majority of both international and domestic immigrants in the modern era, and that in 2005 became

Gestational Diabetes Mellitus ( Gdm ) - 1683 Words

Gestational diabetes mellitus (GDM) is a type of diabetes that occurs during pregnancy and caused by insulin resistance in the body. Risk factors of GDM include maternal age, ethnicity, family history, BMI, and deficiency of vitamin D. To be diagnosed with GDM, a woman must go through two screenings tests called the glucose challenge test and glucose tolerance test with high blood glucose results. Proper management such as a healthy diet, physical activity, and medications are needed to prevent complications for the mom and newborn. Complications include fetal macrosomia, preterm labor, hypoglycemia, and a high risk for developing type 2 diabetes mellitus (T2DM) in the future. It is exceptionally necessary for healthcare professionals to educate their patients to prevent an increase in the number of cases of GDM and to further prepare the patients on what to expect if they are diagnosed with GDM in the future and to avoid any negative emotions. Keywords: GDM, gestational diabetes mellitus, nursing, pregnancy Effects Gestational Diabetes Has on Women and Newborns Gestational diabetes mellitus (GDM) is a type of diabetes that only occurs during pregnancy and usually goes away after the delivery of the baby (Shin et al., 2013). GDM is diagnosed when the results of the screening tests done during 24-28 weeks gestations show high blood glucose levels (Wang et al., 2012) due to insulin resistance (Senti, Thiele, Anderson, 2012). Insulin is a hormone producedShow MoreRelatedGestational Diabetes Mellitus ( Gdm ) Essay2044 Words   |  9 Pages2016 Gestational Diabetes Mellitus INTRODUCTION Gestational Diabetes Mellitus (GDM) is defined as a glucose intolerance that has been diagnosed during pregnancy.1 GDM affects anywhere between 1% to 14% of pregnancies and is on the rise due to the global obesity epidemic.1 Such a large range is due to the differences in screening technique and diagnostic criteria. Those who have a higher risk include women who are obese, have a previous history of GDM, have a family member with type 2 diabetes, areRead MoreGestational Diabetes Mellitus ( Gdm )2927 Words   |  12 PagesGestational Diabetes Mellitus (GDM) is defined as glucose intolerance that occurs during pregnancy [1]. GDM is a widespread condition in Indian women during pregnancy affecting nearly 21 percent of all pregnancies [2, 3] nationwide. Prevalence of GDM in India differs from region to region, with 3.8% in Kashmir [4], 16.55% in Tamil Nadu [5], 7.7% in Maharashtra, 7.1% in Haryana [6], 19% in National Capital Region [3]. Epidemiological studies have confirmed the associ ation of GDM with increased feto-maternalRead MoreEssay on Gestational Diabetes Mellitus (GDM)2085 Words   |  9 PagesGestational diabetes mellitus (GDM) is an intolerance of glucose documented for the first time during pregnancy. It is usually a short-term type of diabetes and the most common health problem with pregnant women. GBM is caused by the way the hormones in pregnancy affect the mother. GDM accounts for 5-7% of all pregnancies (American Diabetes Association, 2010). During pregnancy the placenta develops and becomes the main bond between the mother and the baby. It is used to make sure the baby hasRead MoreGestational Diabetes Mellitus (GDM) Essay1850 Words   |  8 PagesThe prevalence of Gestational Diabetes mellitus (GDM) is growing worldwide. 1-14% of women in pregnancy is affected by DM 1. Due to increased incidence and proposed lower ¬ing of the thresholds for diagnosis the health care cost of GDM can be expected to rise proportionately. The discussion of whether a benefit exists to the treatment of GDM assumes greater importance now than in the past. Even though it has long been known that women with preexisting type 1 and type 2 diabetes are at increasedRead MoreIntroduction. Gestational Diabetes Mellitus (Gdm)By Definition1257 Words   |  6 PagesIntroduction Gestational Diabetes Mellitus (GDM) by definition is a carbohydrate intolerance that is developed or recognized for the first time during pregnancy (Chen, Chuang, Fang, Kuo, Lee, Li, Lin, NIen,Wu, 2017). With a drastic increase of GDM in recent years, attention and concern has been brought to the topic. GDM is linked to poor pregnancy outcomes including but not limited to; hypertension, macrosomia, maternal depression, neonatal hypoglycemia and stillbirth (Jagiello Chertok, 2015)Read MoreA Research Study On Gestational Diabetes Mellitus ( Gdm ) Essay1590 Words   |  7 Pagesâ€Å"Follow-Up of Gestational Mellitus in an Urban Safety Net Hospital† Gestational diabetes mellitus (GDM) is a form of high blood sugar that affects pregnant women. It is called GDM in women who have never had high blood glucose readings until pregnancy. This type of diabetes usually develops around the 24th or 25th week of gestation. GDM occurs when the body is not able to make enough insulin or use the insulin that is made for its increased needs during pregnancy. GDM not only causes complicationsRead MoreNutrition Research Analysis1101 Words   |  5 Pages1. Cho, J., Choi, Y., Kim, A., Kim, H., Lee, J., Lim, S., Oh, J., Yoo, H., Yoon,K. Nutritional Intake of Pregnant Woman with Gestational Diabetes or Type 2 Diabetes Mellitus. Clinical Nutrition Research 2013; 2: 81-90. Article from a Korean peer-reviewed journal examined the nutritional intake of 125 women diagnosed with gestational diabetes or type 2 diabetes mellitus for over two years. The woman had not been provided nutritional education on how to manage their blood glucose or proper diet duringRead MoreThe Effects Of Gestational Diabetes1016 Words   |  5 PagesOne of the most common metabolic disorders during pregnancy is gestational diabetes mellitus (GDM) and its occurrence continues to increase (8). The 2004 analysis by the Center for Disease Control and Prevention states that cases of GDM are at 9.2%. The American Diabetes Association defines GDM as a condition where glucose levels are higher than normal either at the start or during pregnancy (1). The definition is used whether insulin or only diet modification is used for treatment and even if theRead MoreDiabetes Mellitus : A Type Of Diabetes1369 Words   |  6 PagesIntroduction Gestational Diabetes Mellitus is a type of diabetes that was first discovered during pregnancy. According to Canadian Diabetes Association (2015), three to twenty percent of women develop Gestational Diabetes Mellitus (GDM). GDM is a result of increased insulin resistance or glucose intolerance. Incidence of GDM varies by age, body weight, and ethnicity. Canadian Diabetes Association (2015) mentioned that individuals who are at greater risk include women over 35 years of age, womenRead MoreGestational Diabetes Mellitus : An Overview1241 Words   |  5 Pages Gestational Diabetes Mellitus Isaac Anzaldua Norma Beardwood (Roper), MBA, M. Ed., RDN, LD, LPC, CEDS DIET 4252 September 21, 2015 â€Æ' Gestational Diabetes Mellitus Introduction Diabetes Mellitus is a disease; which occurs through the insufficiency of insulin being produced or its actions are not being utilized. This occurrence leads to hyperglycemia; an issue in which the amount of glucose in the blood is relatively high. Gestational Diabetes Mellitus falls under the category of DM. GDM also

A Single Tear Free Essays

Paintings can have all sorts of meanings. Usually, painters use these pieces of art to express themselves on things they cannot normally do. Sometimes, it can also be a product of imagination. We will write a custom essay sample on A Single Tear or any similar topic only for you Order Now At times, they want to visualize a series of events into one artwork. These paintings turn out to be abstracts but along the lines and colors used, there is still a hidden meaning enclosed in them. This what makes paintings interesting and mysterious. The lithograph represents the typical Indian leader amidst struggles and tests of life. No matter how strong and determined a leader is, he still has his weak moments and the snow and wind symbolize the stumbling blocks. But no matter how difficult it may seem to be, the leader is always a leader and he must not let his fears bring him down. The Indian Chief showed his strength by leading his people in their exodus. Even if he is uncertain of what is about to come, he kept his people together and hand in hand, they are to face the challenges. Just by his name alone, I think Mr. Echohawk is an Indian himself. If not, he probably has strong affiliations with Native Americans. This Indian Chief which he portrayed intensely could be his ancestors. Maybe he learned of their story about the hard times undergone by the American Indians not so long ago. And since he was not there and could not be there, he imagined what might have taken place through this painting. Since it is difficult or impossible to describe through paintings the feelings of this Indian Chief, he used a single tear to speak for his emotions. The single tear that streamed from this warrior’s face signifies leadership. It does not mean that a good leader would not feel apprehensions anymore. Further, it does not mean it would make the Indian Chief less of a man if a tear drops from his face. Like a normal human A Single Tear  Ã‚  Ã‚  Ã‚   2 being and any other leader, he feels scared too. But this Indian Chief is driven by willpower and fortitude to deliver his people to safety. The leader also felt fear but his responsibility to his people vanquished these feelings of doubt and insecurity to what the future holds. The single tear reveals the imperfection of the human race regardless of our color and tribe. By imperfection, it means that each person despite of his stature and position becomes fragile sometimes. The Indian Chief in the painting is experiencing vulnerability but he must live up to his dignity and sense of worth. As to his case, what urged him not to give up is for the sake of his people who look up to him being the person in command. If he surrenders, then his people would lose hope. His courage marks the fate of the American Indians. The single tear also denotes faith and hope. Faith in that after the storm, the sun will shine for the Indian Chief and his people. Faith that the snow and wind is only temporary and it will end somehow. Hope is a positive outlook from which they get their strength to surpass all these trials and hardships. Hope that a brighter life is in store for the native community. History tells us that the Native Americans have a rich past which upholds both their ups and downs. They acknowledged their victories and defeats and learned from these experiences which made them a stronger community despite chauvinism and discrimination from the whites. What is important for them is their unity and pride as a race of principled people.   Finally, I really view this painting by Mr. Echohawk as an emotional one. It portrays a mixture of passion and sentiment. I wish my readers can see this painting for themselves. Rest assured that anybody can definitely empathize with me. Just like any struggling race, the American Indians are trying their best to save their bloodline in the midst of globalization and modernity. This trait is the one I truly appreciate. How to cite A Single Tear, Papers

Competitive Strategy for Cost Advantage -myassignmenthelp.com

Question: Discuss about theCompetitive Strategy for Cost Advantage. Answer: Microsoft-Introduction Microsoft is currently the largest software maker globally and has been posting consistent profits yearly. It commands 90% of the Operating System for desktops around the world. It posted revenues of more than $78 billion with a profit margin of 28% (Statista 2017). Its consistency in innovation over a period of 39 years is testimony of a culture of organizational excellence that is founded on an ethical business model. Having a concise CSR approach as a responsible corporate citizen, the company operates sustainably with social and environment considerations at its core. The business model rests on licensing of its software to businesses through enterprise agreement contracts. Practical source of excellence Cost advantage- Cost advantage can be defined as the cost of production for a firm that is lower than its competitor and therefore gives it an advantage. Microsoft enjoys an advantage of cost for its desktop operating software which is used globally (Damodaran 2012). The volumes produced help to push down the cost of production making it difficult for new entrants to compete. Economies of learning translate into improved organizational dexterity and coordination for its global operations. Maximum capacity utilization as a driver of advantages of cost push down the costs associated with installing and closing capacity for the company. Differentiation advantage- This can be defined as the creation of services or goods that are superior than that of the competitor and therefore avails the advantage of being different. Microsoft has managed to maintain an advantage over its competitors with its Office Suite that offers unmatched services. Users of different operating systems such as Mac and Linux still use Microsoft Office as a separate application (Satell 2013).Its ease of use and versatility for both home and office applications makes it different from other similar software. CAGE distance framework- This framework is founded on Cultural, Political, Geographic and Economic differences between nations that impact business entities. Microsoft has been able to overcome the distance of differences by offering products with universal appeal that cuts across cultures, land boundaries and economies. The Microsoft Office Suite has universal application for home and office use despite the above differences (Microsoft Corporation 2017). Another product is the Xbo that crosses boundaries of economics such as bilateral and multilateral arrangements. Business Model Innovation- The company has adopted a new business model based on innovating a new approach. Microsoft has relied on its licensing model of its products to generate revenue over the years. This is changing with a new model that is known as freemium ( Microsoft Corporation Industry Profile 2015). This model moves beyond free trials to a tier on free offering for some of its products. Once the pool of users has grown, revenue will be generated by increased engagement that will be volume based. This transition to a new business model is to ensure that revenues and profit in the long-term are maintained. This transition will ensure market relevance in the face of changing market dynamics in the technology sector. Introduction-Nike Nike is the leading sports footwear and apparel globally with a market share of 22%. Income revenue for 2016 stood at $32 billion which was due to growth in every geographical market (Nike 2017). The brand has been in operation for more than forty years and has been leading through innovation in the sports apparel industry. Through sustainable manufacturing that empowers local communities where it operates, Nike has shown leadership as a corporate citizen. Environmental stewardship has resulted in factory scrap being reused to manufacture premium apparel and footwear. Strong brand recognition has also contributed to the success of Nike with its distinctive logo and use of brand ambassadors to drive growth. Practical cause of excellence Strategic Marketing- Strategic marketing is the way a firm leverage on its core strengths in order to differentiate itself from its competitors. Nike uses two distinct forms of marketing that contributes to its strategic approach. The firm focuses on the high end in its market position and pricing strategy that is buttressed by products which are unique to offer a better value proposition for the customer. Nike (2015) states that the company competes competitively through its direct-to-consumer strategy that rests on the pillars of innovation, speed and direct connection with the end consumer. Business model innovation- the firm has consistently modeled its business with strong brand recognition that uses brand ambassadors. Starting with Michael Jordan, the company has become synonymous with leading sports stars and this helps to reinforce the positioning of being associated with success and industry leader (Matt Dom et al. 2016). The firm has also partnered with other strategic partners such as Apple to innovate new sports technologies that are wearables such as the Apple Watch Nike+ (Apple 2016). Nike leverages on the social and marketing capital of Apple to drive growth in sports wearables. Value chain- Value chain can be defined as the processes that are used by a firm in order to add value to its products or service. The firm leverages its core strengths in its primary and secondary activities of manufacturing. It exercises strong control over its global channels of distribution in order not to dilute brand recognition and premiums. In its secondary activity of procurement, it maintains relations which are progressive and sustainable with its manufacturers. The innovative Flyknit technology ensures that wastage in the designing stage reduces wastage by 60% which translates to savings on cost of production (Nike 2015). The firm ensures sustainability by engaging manufacturing contractors who are compliant with labour and environmental industry best practices. CAGE framework- Nike uses a strategy that seeks to maintain brand premium in every market where it operates. While factoring in the economic distance between the different markets, the firm sets prices that reflect the incomes of its target audience in each geographic market. The prices offered are still well above average in order to maintain the premium attached to the brand. This ensures that there is growth of revenue despite the different markets differing in incomes. It is also a key growth factor for emerging markets such as China which are forecast to be the major revenue driver in the future. Conclusion Competitive strategy is important in positioning companies and firms to market leadership and dominance. Success which is sustainable is also as the result of embracing competitive strategies in a business entity. Advantages in cost, value addition in supply chain are some of the approaches that can be employed. Positioning on brand recognition and leveraging the CAGE framework all contribute in achieving competitive advantages in the industry of operation. Microsoft and Nike have used the above strategies in achieving success in their respective industries. References Apple, 2016, Apple Nike launch the perfect running partner, Apple watch Nike+, viewed 18 August, https://www.apple.com/newsroom/2016/09/apple-nike-launch-apple-watch-nike/ Damodaran, A, 2012,Investment valuation: tools and techniques for determining the value of any asset, New Jersey: Wiley. Mat Dom, SS, Ramli, Hb, Audrey Lim Li, C, Tan Tze, F 2016, 'DETERMINANTS OF THE EFFECTIVENESS OF CELEBRITY ENDORSEMENT IN ADVERTISEMENT', Journal of Developing Areas, vol. 50, no. 5, pp. 525-535. 'Microsoft Corporation Industry Profile', 2015, Microsoft Corporation: Change in Direction Under Satya Nadella, pp. 1-31. 'Microsoft Corporation', 2017, pp. 1-51. Nike, 2015, Nike, Inc announces new consumer direct offense: a faster pipeline to serve consumers personally, at scale, viewed 18 August 2017, https://news.nike.com/news/nike-consumer-direct-offense Nike, 2017, Nike, Inc reports fiscal 2017 fourth quarter and full year results, viewed 18 August 2017, https://news.nike.com/news/nike-inc-reports-fiscal-2017-fourth-quarter-and-full-year-results Satell, G, 2013, The secret of Microsofts success (and some lessons for Apple), Forbes, viewed 18 August 2017, https://www.forbes.com/sites/gregsatell/2013/04/15/the-secret-of-microsofts-success-and-some-lessons-for-apple/#3e2489f21587 Statista, 2017, Microsoft statistics and facts, viewed 18 August 2017, https://www.statista.com/topics/823/microsoft/

Technology of Instant Messaging and it contributes to society

Question: Discuss about the Technology of Instant Messaging. Answer: Technology of Instant Messaging and it contributes to society In the last few decades, there have been significant changes in the technological aspects of the society. Instant messaging refers to the communication technology which is used to use text to communicate between two or more number of people. It uses the internet or any other form of network to establish this kind of communication. It is also known as IM chat and it occurs in real time. Initially, it was mainly text based but with the passage of time, now the users can share files, send a message to many people, invite a contact to a particular conversation, add video and voices, etc. It helps people to keep in touch with each other. Computer-based communication like IM is friendly medium for autistic patients to expand their networking since they get enough time to communicate their messages with a user at their own pace. Such channels do not adopt extra signals like body language that needs further possessing. Autism spectrum disorder (ASD) and children with autism. Autistic spectrum disorder refers to the neuron-developmental disorder which has characteristics like complexity in having social interaction and communication. The children who suffer from ASD generally have symptoms including learning disability, epilepsy, dyspraxia, obsessive compulsive disorder, etc(Lord et al., 2013). It is vital to check the early signs of autism in children so that appropriate treatment can be provided to them. Almost 1% of world population suffers from autism. People suffering from ASD are subject to discrimination, social stigma, etc. (Lauritsen, 2013). People suffering from ASD are unable to exploit technology since it is not user-friendly for them. But due to innovation in technological aspects, more friendly and useful applications can be developed which will help the patients to express their emotions in an easier manner. Introduction about Picture Exchange Communication System (PECS) and how it helps the children with autism. The concept of PECS is the specific formulation which provides an augmentative as well as alternative communication. This kind of communication is used to deliver words to the children and further, it helps the children to communicate. Thus by the process of augmentative and alternative communication, the PECS was such designed that it can be used by the autistic children. As a result, the children can be able to communicate in a proper manner and treat the delay of speech development of the children (Boesch et al., 2013). Basically, when the concept of PECS is applied to the child at that time the child has been provided with a number of pictures of various things that they see in their day to day life like their favorite foods or toys. In that case when children think of having or using those things then they will make the indication to their person who is communicating with them. This communication partner is either a parent or any therapist or caregiver or any other child. Thereafter the communication partner handovers the child with what he or she has demanded and further this exchange process reinforce the communication (Boesch et al., 2013). Thereafter starts the training of various attributes and the language expansion in the personality of the autistic children. In this part, the children basically learn regarding the expansion of the sentences with the addition of proper adjectives, verbs as well as the prepositions. It is then addressed by the addition of more two phases to the process. So the fifth phase consists of the children learning the process of how to answer the questions properly by knowing the exact thing what they want. Again in the sixth phase, the children will get to know how they can comment in response to answer the questions asked to them (Landa Hanley, 2016). Apart from that the crucial part which should be known about the process of PECS is not place specific rather the treatment process through PECS can be started anywhere depending upon the capability of the children. The reason behind it some children are visual thinkers. By this manner, many alternate ways are being provided to the child to i nitiate the communication in the autistic children. PECS inside instant messaging App Picture Exchange Communication System (PECS) refers to a system that assists the people to communicate who suffer from speech inability. The application of picture cards for communication makes it easier for the children suffering from the inability to communicate conveniently. The PECS can be incorporated into the instant messaging applications with the ability to record a voice speaking the symbol. This functionality would allow the teacher or the parents to either record the objects or make use of the default language by using another language. Hence, it would allow the application to be flexible for the use of the children suffering from inability with any language (Landa Hanley, 2016). The advantage of using PECS in instant messaging applications would provide a clear screen of choices with many categories to develop communication by helping ASD people in the formulation of sentences and conveying their messages to the loved ones. The incorporation of PECS into the instant messaging applications would also be provided with wide sections in order to facilitate the selection of phrasing the sentences and picture. The adoption of PECS by instant messaging applications would require stability in the internet access for facilitating a good and effective user interface. Fast internet connection and the technology would help the children and people suffering from ASD to be able to communicate, gain knowledge and be exposed to the real world like the rest of the people in the world do. This would be a vital initiative to make life better and technologically enhanced in this age of development so that they also move forward in their lives. The reason for me to choose the subject is to gain insights into the development of technology regarding PECS and providing suggestions to incorporate PECS into instant messaging applications which would help the people suffering from the ASD in moving ahead in life with technology. References Boesch, M. C., Wendt, O., Subramanian, A., Hsu, N. (2013). 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(2013).Evaluating picture exchange and the iPad as a speech generating device to teach communication to young children with autism.Journal of Developmental and Physical Disabilities, 25(6), 637-649.