How to Format a College Essay If It Has a Cover Letter Features

How to Format a College Essay If It Has a Cover Letter Features What the In-Crowd Won't Tell You About How to Format a College Essay If It Has a Cover Letter Lot many students belonging to different colleges want to take part in the training program and become benefitted. College workshop application letters are made by students who wish to be part of a particular academic workshop which will be run within the premises of the institution. A college admission application letter is utilized by means of a student who'd love to submit an application for an academic slot for a certain course provided by means of a school. This college student cover letter is a terrific illustration of how you're able to hook a hiring manager and get your fantasy internship. What to Expect From How to Format a College Essay If It Has a Cover Letter? If you're an individual who needs to be entirely confident in taking a determination, such actions are extremely important. The goal is to flesh out all your possible ideas so when you start writing, you know and understand where you're going with the topic. Great cover letter explains the most important reason for your desire to get a particular position. If you adhere to these 3 tips when writing your cover letter, you'll be receiving interview requests very quickly. The Secret to How to Format a College Essay If It Has a Cover Letter Doing some research on the telephone or by email may offer you a competitive benefit. The letter needs to be brief and thoroughly concentrated with information. If you should understand how to compose a letter of interest for employment, we advise you to read another guide on our site. Doing research will be able to help you figure out who is the most suitable person to obtain the letter. Your paper should have a title page with these products. Your cover letter ought to be three paragraphs and a maximum of a single page. 2 For example, the title page of this essay doesn't have a page number, but. Repeat your title on day one of your essay. Get your creative juices flowing by brainstorming all the potential ideas you can imagine to tackle your college essay question. To be sure you succeed in your program, make certain that your admission letters and essays are free from errors. An essay was defined in a number of means. If you're sending the exact same essay to a lot of schools, the cover letter is a chance to tailor the essay to the institution to which you're applying. For instance, you may discover a list of interesting subjects that is going to be in the desired undergraduate program. Don't panic as soon as your instructor tells you that you have to compose an analysis. Note the way the author manages to provide a personal evaluation of the court case without actually utilizing any personal pronouns a prudent alternative, even for a personal essay conclusion sample. Using How to Format a College Essay If It Has a Cover Letter You could use an elongated analogy, where each paragraph is an area of the analogy. If you would like to compose a fantastic letter of intent, you have to prepare for writing it. It can happen that you won't have the ability to create a superior letter of intent on the very first try. The letter of intent ought to be written utilizing an official tone. Most Noticeable How to Format a College Essay If It Has a Cover Letter Cover letters are an important element of a work application. You also have to be prepared to execute basic administrative tasks as warranted. So make certain to place your very best image forward. The essay format style doesn't have anything to do with the intricacy of your paper. The format dictates presentation components of your paper including spacing margins and the way the content is structured. Make certain you have chosen the most suitable format of the document. As a consequence, this quick paper ought to be paid a close attention to in respect to its format and in relate to the cover letter format. If you send a school-specific packet, you should supply your cover letter in the exact same package with the remainder of materials. Indeed, it's very discouraging not to find the maximum grade only for using the incorrect font or spacing in your essay cover page. Do not repeat the hundreds digit in a page range should it not change from the start to the close of the range. The rules for writing a superb essay are not any different. Irrespective of how you'll wind up submitting your essay, you should draft it into a word processor. The single most essential part of your essay preparation could possibly be simply making certain you truly understand the question or essay prompt. You ought to have a plan, an established structure, once you are writing an essay. One of the absolute most troublesome things in writing essays is making up a great title. The principal function of the college essay format is to assist the readers follow main ideas on the other side of the content without stumbling upon its structure. You should make the reader want to read whatever it's that you've written. Additional the readers expect the several topics being discussed to be new, distinctive and unusual.

Pioneers and Paradigms Sample Essay

Pioneers and Paradigms Sample EssayIf you are reading this then it is safe to assume that you have seen one of the many recently published sample essays available on the Internet. There are a number of reasons for the popularity of these samples; most notably that they can be used in lieu of that old classroom essay. After all, many students are starting to see that they do not have to suffer through writing a standard, boring essay all the time.The reason why it is so popular is because the sample essay is usually written by a professional who has already gone through a process like this before. These writers are already experienced in writing essay samples and they know exactly what they should include and what they should leave out. This makes it so much easier for the student to get through writing the essay. However, this does not mean that you cannot write your own essay or that the sample will not work.It is the fact that you can put what you learned from the material and make it relevant to what you learn about landmark achievements in the field of science. No matter how bad your paper is, with some self-criticism and some creative thinking you will still be able to pass.Of course, if you are able to relate what you learn to what you know of that particular period of time then you will most likely be able to use the idea in the future. Take this opportunity to use the information to create something good and informative.One thing that you will want to make sure that you do when choosing a writing sample is that you are aware of the guidelines of the sample. The guidelines that you should look for will not be an essay that was created for a test. The guidelines that you should look for will be the same as those of an actual writing sample.One of the first things that you will want to do when looking for a writing sample is to look for writing samples that have been written by people who are professionals. One of the best ways to determine whether or not a sample is professional or not is to look at how it ends. You will notice that the rules of grammar are relaxed on the sample to show how easy it is to write.In today's modern day computer age, many of the rules that we were taught in school have been disregarded. For example, in high school we learned that the rules of grammar mean that we should keep our sentences to one or two words. This does not mean that one should change a sentence into a three-word phrase, but rather that one should follow the rules.By following the rules of grammar, even when they seem unimportant, you will be able to maintain consistency when writing samples. By following the guidelines that are on the sample, you will find that it becomes easy to write and it will become a part of your academic history.

The Foundation Of Power And Justice In International Law Essays

The Foundation Of Power And Justice In International Law Thucydides wrote The History of the Peloponnesian War believing that it was a good picture of the past and which (human nature being what it is) will, at some time or other and in much the same way, be repeated in the future. This paper will present a comparison between the time of Thucydides and how the International system has reflected certain aspects that are contained in the document. It will attempt to address the possibilities of oncoming systemic war, concepts of trust, and the earlier statement of Thucydides. Terms that are important to this argument are anarchy, security dilemma, and balance of powers. Anarchy is the system that world politics works under: with the presence of no prominent authority, any state can do what it chooses on the international stage. The notion of security dilemma rises out of the fear of other states building up their forces and becoming a larger threat to all of the other states. The tie between anarchy, security dilemma, and life in a sovereign state is the balance of powers; which aims at primarily to preserve peace and the status quo. Thucydides' balance of power involved two states: Athens and Sparta. After the Persian war, Athens had become a very powerful military state, and began to assimilate other states they had recently saved in the Persian War. Athens justified their actions by suggesting that, having won the war, their rights to become an empire were prevelent. They then built walls around their new territories and continued to increase their military power. This worried the Spartans because if Athens were to attack them it would be difficult to counter attack. Sparta, however, did not respond by building up their forces to maintain the balance. The Spartans acted slowly and tried to avoid the conflict. However, when the smaller states went to Sparta and pleaded for aid, the Spartans agreed, to defend against hostile Athenian actions. Sparta and its smaller allies soon engaged the Athenians and were eventually victorious over the Athenian threat of hegemony. The underling cause of Spartan engagement orig inated in the pleas of the fleeing allied city-states. They claimed that since Sparta was the only other major power that it was Sparta's duty to protect the smaller states. These states also created the fear in the Spartans that Athenians would develop enough power to create a hegemony, and that they all would lose their sovereignty. They stated that an Athenian attack was inevitable. The Spartans began to position troops to defend themselves, as it was better military strategy to stop Athenian forces before they gained any more power. This was considered an aggressive act by the Athenians and sparked the beginnings of the Athenian-Spartan conflict. In comparison, Europe of the 19th century involved five major powers England, France, Russia, Austria, and Prussia. These five powers through communication and shared interest created a system in which they managed to maintain stable international relations. The larger powers were responsible for maintaining the independence of the smaller states' sovereignty. This system, though there were many small wars over territory and maintaining the balance, managed to avoid any systemic wars for ninety years after the Napoleonic war. In this alliance, England had taken on the role of a balancer and joined any side necessary to maintain the balance. The European system ran on many concepts that allowed for its stability. Their system was designed to ensure that all independent states would survive, preserve the system, and that none would control the others. The nature of their trust allowed each state to maintain a balance of power where none had to worry about the rise of hegemony. War was inevitable on a small scale to maintain the balance and status quo; however, due to the nature of the structure, the groups interest superseded the need for any state to take over others. Thucydides was correct in his assumption that some of his understanding of human nature would last through into the future. The structure of the system in both examples are remarkably similar even after almost two thousands years they still have many of the same underling principles. In both systems,

The use of smartphones has become an inalienable p Essays

The use of smartphones has become an inalienable p Essays The use of smartphones has become an inalienable part of everyday life of people of almost all ages globally. 91% of the world population owns a mobile device. According to surveys, young people have the strongest need in mobile devices. 18-24 years old respondents reported they could not imagine their routine without smartphones as they take pivotal role in various processes: communication with friends and family, jobs, studies, reading news etc. On average, people spend 3 hours a day using mobile technologies. For majority of the people, smartphones are the most convenient way for communication because they make the process of communication faster and easier. Emailing is faster, and messaging is also effective. People cannot leave from their home without taking the smartphones with them. Staff needs smartphone for faster and easier communication at their workplace. One more thing is that smartphones keep your family and friends in contact. For example, the parents are also gifting the children with smartphones for many reasons. The major reason for these types of gifts is the concern about the safety of the children. Without smartphones, family and friends seem to lose their contact. The business people are now making use of the smart phones to advertise their products. It is amazing how the smart phones have helped in marketing and strategizing. Reaching to target customers is much easier. The education sector has also been positively affected by the use of the smart phones technology in the society. The students can access valuable educative information from the internet with the help of smart phones. Those in online learning can access all notes and materials and easily submit assignments from any part of the globe. Health information and healthy practices can be accessible with the use of the smart phone technology. The future looks very promising for the Smartphone. In just a few years, Smartphones have become very popular, and it is almost unheard of for someone to not own one. As major developers create new ways in which we can use our Smartphone, the opportunities our endless. I certainly believe the Smartphone will become more "human", as we can already see a preview of that in Apple iPhone's Siri.

Gender Issue in Asia Performance Essay Example | Topics and Well Written Essays - 1750 words

Gender Issue in Asia Performance - Essay Example The Balinese traditional theatre is a highly ritualistic performance form with all kinds of beliefs, myths, traditions and spiritual experiences associated with it. This is why Artaud (1995) had observed that â€Å"our (Westerners’) purely verbal theatre [†¦] could learn a lesson in spirituality from Balinese theatre† (p.301). On the other hand, the Western theatre had largely been evolved out of the rural and folk traditions as early as from the beginning of twentieth century (Turner, 2011, p.68). Turner (2011) has discussed this phenomenon by saying, â€Å"developments from the twentieth century onwards in Western theatre practice have often demonstrated an eclecticism that has led to a pick and mix theatrical culture† (p.68). This is manifested in terms of intercultural influences on the Western dance and theatre traditions. Another aspect of Western performances has been the comparative gender-neutrality of it as a whole, when it comes to characterizatio n and casting, which can be attributed to a social structure that has accepted gender equality as its proclaimed ideal. A strong feminist theatre has also been present in the West as early as from 1960s onwards.But in an Asian country like Bali, it is the rituals and traditions that rule almost all the classical dance and theatre forms. And it has been as an extension of the patriarchal social tradition that women were not allowed to perform the traditional dance drama, Topeng, which is mostly about the â€Å"exploits of male heroes".... hen it comes to characterization and casting, which can be attributed to a social structure that has accepted gender equality as its proclaimed ideal. A strong feminist theatre has also been present in the West as early as from 1960s onwards (Code, 2003, p.471). But in an Asian country like Bali, it is the rituals and traditions that rule almost all the classical dance and theatre forms. And it has been as an extension of the patriarchal social tradition that women were not allowed to perform the traditional dance drama, Topeng, which is mostly about the â€Å"exploits of male heroes who are usually involved in a struggle for power† (Slattum, Schraub and Geertz, 2003, p.20). Gender-bending in Balinese theatre has been a topic of interest for many researchers and social observers (Palermo, 2009; Ballinger, 2005). Challenging the predominance of female impersonators in Balinese performing arts, women began to enter the traditional theatre realm in the beginning of the twentieth century but the number of women performers were very limited (Diamond, 2008, p.231). But by the end of twentieth century, the situation has changed to such an extent that: There were all-male arja (classical Balinese operetta) troupes and two women’s mask troupes. Today, there are all-women gamelan groups in every regency and a wave of women performers staging ‘unconventional’ theatre and dance (Ballinger, 2005). Even before the large scale entry of Balinese women performers into Balinese traditional theatre, there were many Western women who learned these dance forms like, Tiffany Strawson, Carmencita Palermo and Jane Turner (Theatre firefly, 2010/11; Palermo, 2009, Turner, 2011). Palermo (2009) has narrated her experience of becoming a Topeng performer and has said, â€Å"when I first began my

Dairy industry - canada's supply management system Essay

Dairy industry - canada's supply management system - Essay Example Petkantchin (2008) has mentioned that the â€Å"Canadian milk prices have been two to three times higher than world prices since 1986. This has no doubt contributed to a drop of nearly 15% in per capita milk consumption in Canada between 1986 and 2003† (Petkantchin). Canada is one of the biggest producers of dairy products. At the same time the prices of the dairy products are very high in Canada because of the quota system enforced by the government in the supply management of dairy products in Canada. The productivity gains are actually wasted because of the quota system. The creation of Canadian Dairy Commission in 1966 was greeted with immense pleasure by the dairy farmers; however their expectations went wrong since the government introduced the quota system to control the production of dairy products in Canada. The quota system controls the dairy products production in Canada even though Canada has huge potentials in developing the dairy sector. â€Å"One would argue that with the high capital that Canadian dairy farmers have to invest in quota, it makes it difficult for the next generation to farm. This is entirely correct† (Brander, p.12). The dairy farmers need to invest big amounts in order to keep the quota system in tact which is not a good sign for the future generation. Big expenditure or capital needed for dairy farming will force the next generation to look for other options. At the same time, the tight control over the supply management of dairy products resulted as a barrier to the entry of new players in the Canadian dairy market from external sources. It is quite possible that entrepreneurs from other countries may invest in Canada in the dairy sector because of globalization and liberalization policies adopted by Canada. But the tight control over the supply of dairy products in Canada prevents foreign investors from investing in the Canadian dairy sector. Supply management works well for conventional

Bilateral Investment Treaties: Breach of Treaty or Contract

Bilateral Investment Treaties: Breach of Treaty or Contract The face of international investment has changed radically thanks to the proliferation of BITs in the past decade. This has led to foreign investment disputes increasingly being resolved through dispute resolution procedure. But the increase in arbitration to resolve investment related disputes hasnt been successful in resolving some of the issues arising from BITs. Rather some of the recent decision in international investment has exposed some of the underlying problem between the theoretical aspect of the bit and the practical aspect[1]. One of the major issues creating a lot of controversy is related to interpreting that umbrella clause in different BITs[2] and the conflict between breach of treaty v breach of contract. This clause, found in most of the BITs requires that each contracting party must honour and observe all obligations that have been entered with the investor from the other contracting state. This clause basically helps the investor to raise a contractual claim unde r the domestic law to a treaty claim under the BITs. According to Jarrod Wong the application of such clause results in the international arbitration tribunal constituted under the BIT (the BIT tribunal) to take jurisdiction over breach-of-contract claims since the umbrella clause raises the breach of contract to a treaty level breach which automatically gives jurisdiction to the tribunal[3]. To put it in the simplest way, it means that the investor can now ask the international investment tribunal to redress the breach of the investment contact by elevating it to the status of breach of the investment treat by way of international arbitration. Vivendi[4], SGS v. Pakistan[5], and SGS v. Philippines[6] are the three cases decided by International Centre for Settlement of Investment Disputes (ICSID) tribunal that have fuelled the controversy relating to umbrella clause[7] and additionally have discussed the relationship between a breach of contract and breach of treaty.   The above cases have shown how international arbitrators are inconsistent in their approach towards interpreting the umbrella clause in the governing BITs. This has led to a conflict on how the two-principal aspect of international investment practice work in consonance with each other. The two-principal aspect constitute of investment contract which is validated by the hosts states domestic law and the international investment agreement which are mostly the BITs[8]. If this underlying uncertainty isnt resolved soon, then the growth and favourability of international investment stands threatened.[9] Since overlaps between contract and treaty claims ar e expected to arise with increased frequency in the interim period (as a result of the ever-increasing scope of BIT coverage)[10]. This essay will first analyse the relationship between a contractual claim and treaty claim when both arise from same set of facts (a single action of the host state giving rise to the breach). The analysis will be done by discussing how different tribunal have assisted in developing this jurisprudence as it stands today and if there are any fault and changes required in the jurisprudence. The second part of the essay will deal the umbrella clause jurisprudence by focusing and dissecting the decision and reasoning of the tribunal in the SGS decision that have shaped the concept as it is today. At the end the conclusion will involve the analysis and recommendation relating to the jurisprudence discussed below and will also provide an analysis of the decisions that will be referred to. The parties in an investment transaction receive their substantive and procedural rights from the combination of different norm starting from the investment contract itself that is entered between the foreign investor and the local government which gives rise to private right and obligation. Then there is the domestic law of the host state that govern and protects the substantial rights and obligation of the party. These domestic laws fill in the normative gaps that arise in the contract, those domestic laws are mostly in the form of tax laws, environmental law et al. Domestic laws create substantive and procedural right and obligation in addition to those undertaken through the contract. Finally, Bilateral Investment Treaties (BITs) and Multilateral Investment Treaties (MITs) also govern many international foreign investments that required the host state to adhere to obligation by a fixed set of international law. A combination of the above norms provides for a suitable investment e nvironment for the foreign investor protecting and guaranteeing a return on the investment made.[11] The above set of norm give rise to different rights and there is claim under all the three set of norm and at time those claims can arise from a single set of facts. All the three norms work simultaneously to protect and observe all the right and obligation of the parties. As all the norm work together at times both contractual and treat claims can come from a single set of facts, that fact being the act of the government which can breach the investment contract and the investment treaty at the same time. The question that arises here is that if single set of facts gives rise to both treaty and contractual claims then will the tribunal have jurisdiction or will the court have jurisdiction over the dispute? This jurisprudence stands clarified that the tribunal will have jurisdiction over the treaty claims and the local court or arbitrator will have jurisdiction over contractual claims by international tribunal time and again, the most recent being the famous SGS decisions and it was first dealt with by the Lanco v Argentina[12] Tribunal. This ICSID jurisprudence established in Lanco[13] was based on the forum selection clause contained in the concession agreement which was in favour of domestic courts in Argentina. Argentina argued that because of the clause the tribunal has no jurisdiction over treaty claims as the consent in the contract by way of the forum selection clause over rides the general consent given in the BIT for ICSID arbitration. The tribunal however rejected the argument stating that United States-Argentina BIT allows the investor to submit the dispute to ICSID for treaty based claims and the consent is an expressed consent and cannot in any case be overridden by the consent given in the contract.[14] The Annulment Committee in the Vivendi case affirmed the Vivindi Tribunals decision on the issue relating to forum selection clause which was in line with the Lanco decision. The tribunal basically stated that the ICSID tribunal will never be deprived of jurisdiction over a treaty claim, including the case of treaty claims arising out of the contract even when there is a forum selection clause in the contract.[15] The tribunal in the Vivindi[16] case stated that in no way the forum selection clause would be: deemed to prevent the investor from proceeding under the ICSID Convention against the Argentine Republic on a claim charging the Argentine Republic with a violation of the Argentine-French BIT.[17] The forum selection clause was again a point of contention between the parties in both the SGS dispute and the tribunals decisions was in line with the prior jurisprudence. While discussing the SGS decisions one important point that is mostly not noted is that in both the disputes the tribunal asserted jurisdiction over the treaty claim which arose directly from the investment agreement. This cemented the ICSID jurisprudence that was established in earlier cases, both treaty claims and contractual claims can arise from the same set of facts. It can also be stated that, notwithstanding any forum selection clause, in a matter of treaty violation an international tribunal will always have jurisdiction over the treaty based claim. The tribunal in SGS v Pakistan cited the Vivindi annulment decision where the committee stated: [W] here the fundamental basis of the claim is a treaty laying down an independent standard by which the conduct of the parties is to be judged, the existence of an exclusive jurisdiction clause in a contract between the claimant and the respondent state cannot operate as a bar to the application of the treaty standard. At most, it might be relevant-as municipal law will often be relevant-in assessing whether there has been a breach of the treaty.[18] The tribunal also particularly stated that it will deal with the violation related to the treaty only and there will be no jurisdictional overlap with the PSI arbitrator as the PSI arbitrator will be dealing with contractual violation even though both the dispute arise from the same set of facts.[19] It must also be noted that the tribunal in SGS v Philippines also had to deal with similar type of forum selection clause and its decision was again in line with earlier jurisprudence. The SGS tribunals were consistent in their decision on forum selection clause in an underlying contract and also followed the jurisprudence that was established. The effect is that once treaty based claims are found and framed then the treaty based tribunal have the power to adjudicate them and no other forum selection clause can abridge that right. This authority will in no condition be abdicated on the reason that they claim are linked or arise from claims related to contracts. No forum selection clause in an underlying contract or a parallel proceeding relating to the claims can rob or stop the treaty based tribunal from deciding the treaty based claim as clear differentiation can be established between treaty based claims and contractual claims even if they arise from the same set of facts. We saw that there is a clear differentiation between a tribunal asserting jurisdiction on treaty claims when the dispute arises from the same set of fact related to an underlying investment contract. But the umbrella clause aims to do just the opposite by equating contract breaches with treaty breaches. SGS v Pakistan was the first case to deal with the umbrella clause in its practical aspect back in 2003 and then this question was again dealt with by SGS v Philippines. While trying to deal with the question of umbrella clause the SGS decisions left us with conflicting and confusing interpretation of the umbrella clause. The confusion can be attributed to how the SGS decisions lie on the opposite end of the spectrum, while SGS v. Pakistan determined that the BIT tribunal does not have any jurisdiction over contractual claims on the ground (that umbrella clause is very wide in its scope and there was no intention to cover contractual dispute), conversely SGS v. Philippines held that a BIT tribunal in fact has such jurisdiction (as the umbrella clause is to be applied as it is) but still held that it should not exercise this jurisdiction where the investment agreement contains an exclusive forum selection clause designating a specific but different forum from BIT tribunal for resolving disputes arising under the contract. The United Nations Centre on Transnational Corporations has stated that the presence of an umbrella clause in a treaty: makes the respect of such contracts [between the host State and the investor] an obligation under the treaty. Thus, the breach of such a contract by the host State would engage its responsibility under the agreement and-unless direct dispute settlement procedures come into play-entitle the home State to exercise diplomatic protection of the investor.[20] The inclusion of umbrella clause has widened the definition of a arbitrable dispute and over the time tribunal have found and concluded that jurisdiction of a tribunal is no more restricted to claims of violation of substantive provision of BIT.[21] It may be noted that the clauses in BITs are not yet tested as they have been drafted keeping in mind the future requirement for an favourable investment and they are put to test only when any dispute arises and they are placed before an arbitral tribunal. Two of the recent decision relates to the interpretation of the umbrella clause discussed below shows what challenges can the umbrella clause being with them. The SGS Reasonings The SGS decision are the two most recent and important decision on umbrella clause. While SGS v Pakistan took a very restrictive approach in interpreting the clause over contractual claims, SGS v Philippines made a broad interpretation of the umbrella clause by covering both treaty claims and contractual claims. SGS v Pakistan was faced with an umbrella clause, which according to the tribunal was very broad in its scope. The tribunal went on to state that the clause is so broad that it cant be construed to cover contractual claims (compromissory clause article 9 of BIT only intended to cover treaty claims not contractual claims)[22].   The tribunal also found that the umbrella clause in article 11 of the BIT did not transfer SGS contractual claims in to BIT claim. The tribunal stated that a straight forward reading and literal interpretation of the clause encompasses the contractual claims, but the tribunal was concerned that it will convert every contractual claim into a breach of BIT claim and would open a floodgate of cases.[23] The tribunal was very explicit in stating that they dont intent the clause to be so wide in its scope and assumed that the parties also never intended to do so. Giving effect to the clause would be exceeding what the contracting parties intended and the tri bunal is willing to accept.[24] So eventually the tribunal took jurisdiction over treaty claim only and allowed to PSI arbitrator to resolve the contractual disputes. SGS v Philippines was faced with the decision of the earlier SGS v Pakistan tribunal which came before some months only. The tribunal felt that the SGS v Pakistan tribunal didnt give the full and proper effect to the umbrella clause stating that the clause doesnt change the applicable   law on the contract from Philippines law to international.[25] The applicable law remains the domestic law only, the umbrella clause makes sure that the host state honours the obligation it has undertaken under the contract in effect, the clause help to secure the performance of the contract obligation by the host state in relation to international investment protection law.[26] Surprisingly after giving a broad interpretation to the clause the tribunal suspended the proceedings asking the claimant to get the judgement from the domestic court first and then come back to the tribunal if the claimant finds that the judgment is unsatisfactory or the host state doesnt comply with the judgment. The tribunal felt that they have jurisdiction over the dispute, but it is not yet admissible as there is another forum selection clause closer to the contract and if that fail then the tribunal can take jurisdiction.[27] Basically, speaking the tribunal stated that they have jurisdiction over the matter but it will become admission when the forum selection clause doesnt provide justice it will be admissible as it will get elevated to treat violation under the doctrine of denial of justice under international law.[28] Its clear by now that both tribunals decided not to decide on the contractual claim. As Thomas W Walde states, this happened because both the tribunal feared that it will open a floodgate. The SGS v Pakistan was much sincere and clearly vocal about the fear whereas the SGS v Philippines tribunal wrapped it in a more technical consideration.[29] In the end, we can see that both the SGS decision have left the concept of Umbrella clause on a very uneven ground by reaching at two different conclusions. In my opinion an umbrella clause provides much more confidence than a forum selection clause. The reason umbrella clause is preferred because it provides for the disputes to be resolved by a neutral tribunal as both the parties have equal say in the selection and appointment of the tribunals. whereas the forum selection clause requires that the dispute be resolved by a domestic court where the host state has an interest. This doesnt help to instil any confidence of the foreign investor in the domestic forum.[30] The SGS v Pakistan tribunal didnt take into consideration the entire jurisprudence of international law, had it vested far enough it would have realised that the jurisprudence states that contracts of aliens with a government are protected under international law, but only if there are not merely commercial, but have an e lement of governmental powers and prerogative.[31] The intention and aim of investment treaty are not to cover and protect normal commercial functions but rather the action of the government which may seem business like but are sovereign in nature. Had the tribunal delved and concentrated on this core aspect of international investment law it would have realised that the PSI contract involves the power of government (matter related to custom and revenue are the sovereign function of government and PSI agreement was a contract relating to the sovereign action of the Pakistan government) and it would have been able to assert jurisdiction without opening any floodgates. In my opinion when there is an umbrella clause, the parties should go ahead to give effect to the clause, however wide it is. The jurisprudence behind the umbrella clause is to give it a broad interpretation by literally reading it the way it is written. Further, if the argument given in the decision are carried to the extreme, it would invalidate not just the umbrella clause, but all BIT provisions. Conversely the host state should be the one to take the first step to allow the umbrella to take effect and raise the contract claim to treaty claim. Although this step would benefit both the parties, but the host state stands to gain from this action rather than loosing anything. My analogy is based on the assumptions that such an action would be beneficial to the host state, as it will be seen as a positive and pro-investment stance by other investors. The host state stand to benefit by way of a more hospitable, more attractive environment for foreign investment by the adoption of the BIT provisions such as clause like umbrella clause (also forum section clause). Another issue that arises is, reengaging with the clause of the BIT after the investment and that too after a claim has arisen, creates uncertainty in the global marketplace and this may will result in investor losing confidence in the host effecting loss of investment opportunity. In my conclusion, I complete agree with what Jarrod wong states, the language, history and purpose of umbrella clause dictates one reasonable interpretation that it applies to investment contracts without any exception and hence it should be enforced in case of any dispute in accordance with the partys agreement.[32] Moreover, a foreign investor enters an investment agreement with the host by drawing confidence from the BIT and its clauses should be applied as it is until and unless it is blatantly against any concept of international law. Some recent cases have tried to deal with the interpretation of the umbrella clause. while some went for the decision went for Broad, Unconditional Plain Meaning of the clause like SGS v. Paraguay[33] and EDF v. Argentina[34]. Those cases stuck to the concept that there should be a plain meaning buy some of them went for conditional plan meaning but none of the tribunal went ahead to clarify the confusion created by the SGS decision. We are slowly seeing a trend in the practice but far from reaching a conclusive finality. So, the present requirement is for ICSID to clarify on the umbrella issue that has cropped up because of the SGS decisions and the interpretation of the clause should be broad and literal as the jurisprudence related to the umbrella clause suggests. [1] Yuval Shany, Contract Claims Vs. Treaty Claims: Mapping Conflicts Between Icsid Decisions On Multisourced Investment Claims, The American Journal of International Law, American Society of International LawVol. 99, No. 4 (Oct., 2005), pp. 835-851 [2] Jarrod Wong, Umbrella Clauses in Bilateral Investment Treaties: Of Breaches of Contract, Treaty Violations, and the Divide between Developing and Developed Countries in Foreign Investment Disputes, 14 Geo. Mason L. Rev. 135 (2006). [3] ibid [4] Compania de Aquas del Aconquija, S.A. v. Argentina, Decision on Annulment, ICSID No. ARB/97/3, 41 ILM 1135, 1154 (2002). [5] SGS Societe Generale de Surveillance S.A. v. Pakistan, Decision on Jurisdiction, ICSID No. ARB/01/13 (Aug. 6, 2003), 18 ICSID REV. 301 (2003), 42 ILM 1290 (2003) [6] SGS Societe Generale de Surveillance S.A. v. Philippines, Decision on Jurisdiction, ICSID No. ARB/02/6 (Jan. 29, 2004) [7] Shany, (n1) [8] ibid [9] Cf Kalypso Nicolaidis Joyce L. Tong, Diversity or Cacophony? The Continuing Debate over New Sources of International Law, 25 MICH.J. INTL L. 1349, 1351 (2004) [10] Shany, (n1) [11] Ibid., pp. 835-851 [12] Lanco International Inc. v. the Argentine Republic (hereinafter Lanco), ICSID Case No. ARB/97/6, Preliminary Decision: Jurisdiction of the Arbitral Tribunal, 8 December 1998, 40 I.L.M. 457, 2001 [13] Ibid. [14] ibid., at para. 31. [15] Compania de Aguas del Aconquija S.A. and Vivendi Universal v. Argentine Republic (ICSID Case No. ARB/97/3, Decision on Annulment of 3 July 2002, 41 I.L.M. 1135, 2002, at para. 50. [16] ibid [17] ibid., at para. 54 [18] ibid., at para. 140 [19] SGS v Pakistan (n 5) at para 186 187 [20] United Nations Centre on Transnational Corporations, Bilateral Investment Treaties, UNCTC, 1988, at 39. [21] Christoph Schreuer, Travelling the BIT Route: of waiting periods, umbrella clause and Fork in the road, 5 J.W.I.T 2, 231 (2004) [22] ibid [23] Stanimir a alexandrov, Breaches of Contract and Breaches of Treaty: The Jurisdiction of Treaty-based Arbitration Tribunals to Decide Breach of Contract Claims in SGs v Pakistan and SGs v Philippines [2004] 5 J. World Investment Trade 55 [24] Emmanuel Gaillard, Investment Treaty Arbitration and Jurisdiction Over Contract Claims- the SGS Cases Considered in International Investment Law and Arbitration: Leading cases from the ICSID, NAFTA, Bilateral Treaties and Customary International Law, Tod Weiler Editor (2005).257, 2004, at 271-272 [25] alexandrov, (n 23) [26] SGS v Philippine (n 6) at para 126 [27] Stephen Schwebel, International Protection of Contractual Agreements (1959) A.S.I.L. Proc. 273 [28] ibid [29] Thomas W. Wà ¤lde, The Umbrella (or Sanctity of Contract/Pacta sunt Servanda) Clause in Investment Arbitration: A Comment on Original Intentions and Recent [2004] 1(4) TDM   1 [30] Wong, (n 2) [31] Schwebel, (n 24) [32] Wong, (n 2) [33] Socià ©tà © Gà ©nà ©rale de Surveillance S.A. v. Republic of the Philippines, ICSID Case No. ARB/02/6 [34] EDF International S.A., SAUR International S.A. and Leon Participaciones Argentinas S.A. v. Argentine Republic, ICSID Case No. ARB/03/23 Cocaine Addiction: History, Effects and Symptoms Cocaine Addiction: History, Effects and Symptoms Cocaine Addiction An Overview of Cocaine Addiction What is Cocaine? Cocaine is a stimulant drug that produces a greater effect of ‘high’ than other drugs such as methamphetamine. It comes in a form of white powder or crystal form with a bitter numbing taste. In general, the powder form is mixed with other materials such as talcum powder, icing sugar, cornstarch or other drugs such as amphetamine or procaine. Cocaine is derived from coca leaves, then processed into cocaine hydrochloride to produce the base of the drug which is develop into two forms recognized as crack and freebase. White crack typically comes in the shape of crystals varies in color from creamy or white to a transparent color with a yellow or pink tinge whereas freebase is the white crystalline powder form. Cocaine generally snorted through the nasal tissues hence absorbed into the bloodstream. Some people also rub the drug at their gums and swallowing it. Ways of ingesting it depends on the preference of the users, some want a rapid high sensation would inject it or inh ale it as a vapor or smoke. Cocaine is widely known by many names that includes pepsi, coke, crack, Charlie, base, sugar block and rock. Brief History Cocaine was once misclassified as a narcotic drug that depresses the nervous system. It is a powerful stimulant and indigenous natives chewed the coca leaves for boosts of energy. The natives believed it was given by the God and reserves the coca’s pleasure for royalties and high priests. In overtime, the coca leaves were spread to the common people. In 1860, the secret of the coca leaves caught the attention of a pharmaceutical company located in Germany. In the facility, the ancient coca leaf collided with modern chemistry and the drug’s active ingredients are isolated from coca’s chemical properties by chemist, Albert Niemann. After the chemical isolation, a crystal substance is formed and it was named Cocaine which derives from â€Å"coca† and the alkaloid suffix â€Å"-ine†. Niemann stripped the leaves of its mono rating substances and unknowingly created the world’s most addictive drug. How it is used? There are four common ways of ingesting cocaine which are oral, intravenous, intranasal and inhalation. In other street terms it is called chewing, injecting or mainlining, snorting and smoking. Intravenous use is a method of using a hypodermic needle to inject cocaine directly into the bloodstream causing instant intense effect to the user. Whereas intranasal administration is the process of snorting powdered cocaine through the external opening of the nose. Smoking cocaine requires breathing in the smoke or vapor of a burning cocaine into the lungs where the effects are sucked up into the bloodstream to create instantaneous euphoric high as such injecting cocaine. Users should be aware that there are absolute no safe way of using cocaine as the listed methods of using the drug result in absorption of toxic amounts of cocaine, cerebrovascular emergencies, acute cardiovascular and seizures that can to sudden death. Effects on the brain Cocaine activates norepinephrine, dopamine and serotonin, chemicals that stimulates movements, excitement and feelings of pleasure. Normally, when you get excited, startle, and frighten the brain makes you react in order to get out from harm’s way. Cocaine works in the similar way in the brain automatically without you needing it to occur. This addictive drug is a powerful central nervous system stimulant that stimulates the growth of neurotransmitter dopamine in the brain which is responsible to regulate movement and pleasure. Generally, dopamine is freed by neurons in response to potential rewards and reprocess back into the cell that freed it and eventually shutting off signals in linked with neurons. Cocaine stops the dopamine from being reused thus leading to excessive number of dopamine to develop in the synapse. This process causes amplification of the dopamine signals and eventually disrupts standard brain communication. The overflow of dopamine is the main cause of cr eating the cocaine’s euphoric high. Constant heavy usage of the cocaine can cause permanent long-term modification of the brain’s reward system and also other systems of the brain. Effects on the lungs Smoking cocaine is the main contribution to the majority lung and breathing complications. Users smoke crack, freebase or paste by using water pipes, glass pipes or cigarettes, heated using matches or butane lighters. Residue from the cocaine contaminants, matches, tars and additives as such marijuana usually causes chronic coughing, bronchitis, and coughing black phlegm thus leading to multiple chest pain and shortness of breath. The practice of breath holding and deep inhalation technique maximizes the volume of cocaine inhaled and the absorption and can cause collapsing of the lung. At times, users often express sharp pains in the chest area due to deep breathing, neck pain, painful swallowing and buildup of air under the skin located at the neck area called subcutaneous emphysema, which has a feature of crackling touch sensation similar to Rice Krispies cereal. In addition, smoking cocaine can also cause pulmonary edema, a condition of the lung being filled with fluids that can c ause severe shortness in breath, respiratory failure and later death. Effects on the heart Cocaine stimulates the sympathetic nervous system that is mainly responsible for the fight response function which is controlled mostly by epinephrine or adrenaline. Increased of heart rates, high blood pressure and narrowing of blood vessels are the effects of using cocaine. Other type of cardiovascular complications that are caused by cocaine include rapid heart rate and abnormal heart rhythms known as cardiomyopathy. Cardiomyopathy is a disease that weakens the walls of the aorta and causes aortic dissection and rupture of the heart muscle. Repeated use of cocaine can also cause narrowing in the arteries of the heart that can lead to the decrease of blood flow in the heart organ thus causing symptoms of angina, where heart muscles are deprived of oxygen-rich blood that usually cause death of heart tissues and heart attack. In addition, cocaine is also responsible for subsequent narrowing and accelerated hardening of the coronary arteries of the heart which results in heart attacks and cardiac deaths among users from the age of 19 to 44 years of age. Signs of Cocaine Abuse Addiction Cocaine is a drug that is highly addictive and interferes how the brain processes chemicals responsible for the feelings of pleasure. Users who are addicted to cocaine will lose control over the usage of the drug. Strong urges of need for the drug emerge from time to time although most users know the consequences after taking it. Here are some signs of cocaine addiction: Mood Swings The drug cocaine causes addicts to â€Å"crash† when they decide to quit. The term crash refers to moments where the addict’s mood swings changes rapidly from high to distress which causes addicts to continue taking it in order to feel normal. Excess of using the drug may lead to addiction. Withdrawal symptoms Addicts who are addicted to cocaine may show withdrawal symptoms of the drug. Withdrawal symptoms may include hunger, depression, suicidal thoughts, intense cravings, extended sleep or restless sleep, irritability and exhaustion. Abusing cocaine will seem the easy way out to not experience any withdrawal symptoms thus bringing the addict back to relapsing the drug. Change in Behavior If an addict abuses cocaine, their behavior will dramatically change after using the drug. The addict may seem happy or excited and acts more confidently to display an enthusiastic sense of well-being. Addicts also may appear talkative than usual, sexually excited, energy levels increased and loss of food appetite. Eye Changes The most obvious signs of abusing cocaine is the addict’s eyes. The pupil of their eyes are dilated and overly sensitive to light. The pupil is the black part in the eye and usually will constrict when there is light shone into it and get bigger when the presence of light is gone. Cocaine causes the addict’s pupils to dilate or get bigger than its usual size. Nasal Effect Other signs of cocaine addiction include nasal effects. Cocaine addicts usually have runny noses and nose bleed after prolonged use of the drug. Cocaine is heavily snorted through the nasal passages resulting narrowing in blood vessels which can cause blood pressure to increase and decrease in blood flow to the nasal cavity tissues. Without the right amount of blood supply to the nasal cavity tissues, the normal function of the nose may undergo massive damages such as loss of sense of smell and overall health may also be affected. Family members and loved ones should also be on the look-out for traces of white colored powder around the addict’s nose as an indication of cocaine abuse. Skin Effect Another sign of cocaine abuse is scratching of the skin. Cocaine users typically experience irritating crawling feelings under the skin. This crawling feeling is known as ‘snow bugs’ or ‘cocaine bugs’. Addicts describe the feeling of cocaine bugs as burning, itching, biting and creeping. Some addicts will tend to always scratch their skin until it bleeds to ease the irritation. Keep an eye for small bleeding wounds and formation of scabs on your loved ones to identify the abuse of cocaine. Over-Heating Regular cocaine addicts will always find themselves sweating excessively due to dramatic increase of the body temperature. Addicts may also hallucinate and feel agitated, confused and paranoid easily. Family members should notice behaviors of their loved ones such as constant pulling off their clothes or tries to cool down the body with cold showers, wandering the streets without reasons and violent behaviors as signs of cocaine addiction. Treating Cocaine Addiction Without proper treatment, cocaine addiction and abuse can lead to destructive injuries and irreversible harm. In due course, similar to other substance addiction it will cause overdose, accidents, chronic health issues and death. At Solace Sabah, we offer the latest drug recovery program that incorporates cutting edge psychotherapies, modern medicines, committed aftercare, family integration and customized treatment plans. Every client will be provided with thorough and effective care for even the worst possible case of drug addiction. If you find your loved one is relying highly on cocaine and powerless to stop using the drug, treatment and immediate intervention are their best option for a chance to live a healthy life again. Contact us today at Solace Sabah to gain an understanding on how our in-depth addiction treatment program can help your loved ones to start the recovery journey.