lt.com
Word Count: 1,234
Suggested Category: legal marketing
Keywords: collaborative law marketing,divorce attorney,
Elizabeth Ferris,family law marketing,Ferris Consulting,law firm,
law firm consultant,law marketing,lawyer marketing,legal
marketing,marketing collaborative law practice,marketing for
lawyers,marketing law firms,marketing lawyers,The Tipping Point
Description: A legal marketing expert explains the steps to
take to educate the public and implement effective marketing
strategies in order to market your collaborative law practice.
Copyright Date: 2008
You have permission to publish this article in your ezine
or on your web site, free of charge, as long as the byline
and the article is included in it's entirety. If you use the
article you are required to activate any links found in the
article and the by-line. You may not use this article in any
publication that is not-optin (spam).
Complete Article with Resource Box at end:
How To Market Your Collaborative Law Practice
How do certain ideas, services/products or messages advance from
a position of unfamiliarity in the market to a position of
extreme popularity and recognition?
In Malcolm Gladwell's book, Tipping Point, he provides insight
into how messages, ideas and behaviors can infect a population
and spread rapidly just like a virus. This occurs in three ways:
1. The law of the few - a few influential people make a big
difference.
2. A sticky message - having a message that makes an impact.
3. The power of context - people are strongly influenced by
their environment.
One example is how Hush Puppies, the classic American brush
suede shoe, went from being almost extinct in late 1994, to
selling two million shoes in 1996.
What was the reason for Hush Puppies sudden incredible success?
It started with a few hipster kids in downtown Manhattan who
infected the fashion industry with their style. Before long,
designers across the country were putting Hush Puppy shoes in
all the fashion shows. Famous people started wearing them. Hush
Puppies had exploded. The shoes passed a certain point in
popularity and they tipped.
This concept of contagiousness has stuck with me as I work with
collaborative law councils and institutes across North America
and the UK. Is it possible to infect our population with the
message of a more solution-focused approach to resolve disputes?
Could we create a Collaborative Law tipping point?
Absolutely! But first we will need a focused effort with the
right people, the right message and the right context.
One distinction of a tipping point is big changes follow small
events and these changes happen quickly. Malcolm Gladwell states,
The tipping point is the moment of critical mass, the threshold,
the boiling point.
To achieve critical mass, it will be important to consider how
collaborative professionals in your community are spreading the
message about collaborative law and individually contributing to
the tipping point for collaborative law. We must create the
small events that will result in a big change.
The small events include defining and communicating an effective
message, executing specific practice growth strategies and
tracking and monitoring your progress.
Define Your Message
It is estimated that half of the prospective clients who truly
understand the collaborative process will choose this
alternative and benefit from their decision. Yet, despite all
the remarkable things that have gone on during the past 12 years,
less than 2% of the public is even aware this option exists.
This tells us that we need to be more effective in communicating
the message about collaborative law.
One of the most important strategies to growing your
collaborative practice is mastering how you communicate the
benefits, value and process of collaborative law. You must
convey ultimate confidence to prospective clients and referral
sources. Your message must be clear, concise, easily repeated
and make an impact. This will require upfront planning and
practice. Give considerable thought to the following questions:
* What is collaborative law? (Define with an easy to understand
short definition)
* How does the collaborative law process work? (Define in terms
of benefits to client or referral source - use stories if
possible)
* What distinguishes collaborative law from other methods for
divorce? (Define in terms of problems solved)
* What are the key benefits of a collaborative divorce? (Spoken
in relationship to the clients key needs)
Develop Specific Strategies
Once you have developed your key message, you will need to
develop a strategy that will help you reach your goals. An
effective marketing process includes a complement of multiple
strategies and repetition. Research shows that people need to
hear, see or touch a message nine times before they finally
listen.
Consider a combination of speaking, networking and mailings to
referral sources and prospective clients. The following are
recommended marketing strategies to help you grow your
collaborative law practice.
1. Maintain ongoing communication with referral sources -
referral sources must be nurtured or they will go away. Rule of
thumb in building and strengthening referral sources is to
maintain a minimum of 3 purposeful marketing contacts per week.
Action: Make a list of your best referral sources. Schedule time
to take them to lunch and tell them about collaborative law.
2. Identify speaking opportunities - Attend conferences and
speak at meetings where your referral sources and target market
attend.
Action: Organize your experiences and seek out people who could
benefit from learning about collaborative law.
3. Networking - Go out and talk to people involved in
collaborative law and individuals who might be interested, One
attorney I talked to said she turns the table on people who are
marketing to her. She takes them up on their offer for lunch
and then talks about the benefit of collaborative law.
Action: Make a list of key networking opportunities, schedule
them in your calendar and make it a priority to attend.
4. Implement public relations / advertising strategies
o Publish articles in local publications. Write about your
experiences in collaborative law.
o Send press releases to your local media. Include information
on any new training you attended.
o Advertise in local publications.
o Develop a quality brochure and send to all referral sources
and prospective clients.
Action: Send a press release to your local publications
acknowledging your training and involvement in Collaborative Law.
5. Have a presence on the internet - Collaborative professionals
with web sites receive referrals. At a minimum have a home page
with information about your philosophy and work, include easy
linking to relevant sites and information, if possible provide
an article of the month on some value added information.
Action: Update your web site to include new information on
collaborative law. Make sure you are linked to the most
resourceful sites.
Track and Monitor your progress
It is critical to measure your success. Determine what
strategies and activities are working and not working. Assess
what strategies you should do more of and which strategies you
should eliminate. Continually revise your strategy to assure you
are meeting targeted goals.
Summary
I believe Collaborative Law is nearing a tipping point in which
it may start to rapidly transform the way disputes are resolved
in the North America, the UK and beyond.
Your challenge is to replicate what the hipster kids in downtown
Manhattan did for Hush Puppies. As a group we need to rapidly
infect our communities with the message of collaborative law. We
need to create a collaborative law tipping point.
You have an opportunity to create the small events that will
result in big change for the way disputes are resolved across
around the world.
(c) 2008, Elizabeth Ferris, All rights reserved. You are free to
use material in whole or in part, as long as you include
complete attribution, including live web site link. Please also
notify me where the material will appear. The attribution
should read: By Elizabeth Ferris of Ferris Consulting.
News >>> Read more...
Word Count: 1,234
Suggested Category: legal marketing
Keywords: collaborative law marketing,divorce attorney,
Elizabeth Ferris,family law marketing,Ferris Consulting,law firm,
law firm consultant,law marketing,lawyer marketing,legal
marketing,marketing collaborative law practice,marketing for
lawyers,marketing law firms,marketing lawyers,The Tipping Point
Description: A legal marketing expert explains the steps to
take to educate the public and implement effective marketing
strategies in order to market your collaborative law practice.
Copyright Date: 2008
You have permission to publish this article in your ezine
or on your web site, free of charge, as long as the byline
and the article is included in it's entirety. If you use the
article you are required to activate any links found in the
article and the by-line. You may not use this article in any
publication that is not-optin (spam).
Complete Article with Resource Box at end:
How To Market Your Collaborative Law Practice
How do certain ideas, services/products or messages advance from
a position of unfamiliarity in the market to a position of
extreme popularity and recognition?
In Malcolm Gladwell's book, Tipping Point, he provides insight
into how messages, ideas and behaviors can infect a population
and spread rapidly just like a virus. This occurs in three ways:
1. The law of the few - a few influential people make a big
difference.
2. A sticky message - having a message that makes an impact.
3. The power of context - people are strongly influenced by
their environment.
One example is how Hush Puppies, the classic American brush
suede shoe, went from being almost extinct in late 1994, to
selling two million shoes in 1996.
What was the reason for Hush Puppies sudden incredible success?
It started with a few hipster kids in downtown Manhattan who
infected the fashion industry with their style. Before long,
designers across the country were putting Hush Puppy shoes in
all the fashion shows. Famous people started wearing them. Hush
Puppies had exploded. The shoes passed a certain point in
popularity and they tipped.
This concept of contagiousness has stuck with me as I work with
collaborative law councils and institutes across North America
and the UK. Is it possible to infect our population with the
message of a more solution-focused approach to resolve disputes?
Could we create a Collaborative Law tipping point?
Absolutely! But first we will need a focused effort with the
right people, the right message and the right context.
One distinction of a tipping point is big changes follow small
events and these changes happen quickly. Malcolm Gladwell states,
The tipping point is the moment of critical mass, the threshold,
the boiling point.
To achieve critical mass, it will be important to consider how
collaborative professionals in your community are spreading the
message about collaborative law and individually contributing to
the tipping point for collaborative law. We must create the
small events that will result in a big change.
The small events include defining and communicating an effective
message, executing specific practice growth strategies and
tracking and monitoring your progress.
Define Your Message
It is estimated that half of the prospective clients who truly
understand the collaborative process will choose this
alternative and benefit from their decision. Yet, despite all
the remarkable things that have gone on during the past 12 years,
less than 2% of the public is even aware this option exists.
This tells us that we need to be more effective in communicating
the message about collaborative law.
One of the most important strategies to growing your
collaborative practice is mastering how you communicate the
benefits, value and process of collaborative law. You must
convey ultimate confidence to prospective clients and referral
sources. Your message must be clear, concise, easily repeated
and make an impact. This will require upfront planning and
practice. Give considerable thought to the following questions:
* What is collaborative law? (Define with an easy to understand
short definition)
* How does the collaborative law process work? (Define in terms
of benefits to client or referral source - use stories if
possible)
* What distinguishes collaborative law from other methods for
divorce? (Define in terms of problems solved)
* What are the key benefits of a collaborative divorce? (Spoken
in relationship to the clients key needs)
Develop Specific Strategies
Once you have developed your key message, you will need to
develop a strategy that will help you reach your goals. An
effective marketing process includes a complement of multiple
strategies and repetition. Research shows that people need to
hear, see or touch a message nine times before they finally
listen.
Consider a combination of speaking, networking and mailings to
referral sources and prospective clients. The following are
recommended marketing strategies to help you grow your
collaborative law practice.
1. Maintain ongoing communication with referral sources -
referral sources must be nurtured or they will go away. Rule of
thumb in building and strengthening referral sources is to
maintain a minimum of 3 purposeful marketing contacts per week.
Action: Make a list of your best referral sources. Schedule time
to take them to lunch and tell them about collaborative law.
2. Identify speaking opportunities - Attend conferences and
speak at meetings where your referral sources and target market
attend.
Action: Organize your experiences and seek out people who could
benefit from learning about collaborative law.
3. Networking - Go out and talk to people involved in
collaborative law and individuals who might be interested, One
attorney I talked to said she turns the table on people who are
marketing to her. She takes them up on their offer for lunch
and then talks about the benefit of collaborative law.
Action: Make a list of key networking opportunities, schedule
them in your calendar and make it a priority to attend.
4. Implement public relations / advertising strategies
o Publish articles in local publications. Write about your
experiences in collaborative law.
o Send press releases to your local media. Include information
on any new training you attended.
o Advertise in local publications.
o Develop a quality brochure and send to all referral sources
and prospective clients.
Action: Send a press release to your local publications
acknowledging your training and involvement in Collaborative Law.
5. Have a presence on the internet - Collaborative professionals
with web sites receive referrals. At a minimum have a home page
with information about your philosophy and work, include easy
linking to relevant sites and information, if possible provide
an article of the month on some value added information.
Action: Update your web site to include new information on
collaborative law. Make sure you are linked to the most
resourceful sites.
Track and Monitor your progress
It is critical to measure your success. Determine what
strategies and activities are working and not working. Assess
what strategies you should do more of and which strategies you
should eliminate. Continually revise your strategy to assure you
are meeting targeted goals.
Summary
I believe Collaborative Law is nearing a tipping point in which
it may start to rapidly transform the way disputes are resolved
in the North America, the UK and beyond.
Your challenge is to replicate what the hipster kids in downtown
Manhattan did for Hush Puppies. As a group we need to rapidly
infect our communities with the message of collaborative law. We
need to create a collaborative law tipping point.
You have an opportunity to create the small events that will
result in big change for the way disputes are resolved across
around the world.
(c) 2008, Elizabeth Ferris, All rights reserved. You are free to
use material in whole or in part, as long as you include
complete attribution, including live web site link. Please also
notify me where the material will appear. The attribution
should read: By Elizabeth Ferris of Ferris Consulting.
News >>> Read more...
- Mood:rollicking
- Music:Pink Floyd
By Valentino Sabuco
Universal Press Syndicate
Q: A close family friend and his wife died in an accident last year at
53. They didn't have a will or any estate planning and dealing with
their estate has been a mess. I don't want this to happen to my spouse
or family. What can we do to get our estate planning house in order
and keep it there?
-- A. M., Kentucky
A: Estate planning is a very important component of everyone's
financial planning, regardless of the size of the estate. It's the
only way to control what happens to your assets when you become
disabled or pass away.
You can't just talk about estate planning because verbal agreements
aren't legal. You'll need to have your attorney put it in writing.
Here's how to save time and money on legal fees to get your estate
planning house in order and keep it there over your lifetime.
WRITE DOWN YOUR PERSONAL GOALS -- Identify beneficiaries who you want
to inherit something when you die. Specify how much, what percentage
or which assets go to each person or charity. Take note of the special
needs of any beneficiary, such as a disability preventing work or an
inability to manage money, and identify backup beneficiaries in case
your first choices do not survive you.
If you don't have strong feelings about individuals, consider
selecting a favorite charity or to be your primary or
secondary beneficiary.
Also, consider the timing for distributions to designated recipients.
Some beneficiaries can handle a large, lump-sum distribution. Others,
such as children, benefit from distributions that are spread over time.
Identify guardians of the person to raise your minor children should
you and your spouse die or become incapacitated. Also select guardians
of the property to handle your children's inherited assets. Identify
backups, too.
Identify executor(s) and trustee(s) to carry out your wishes after
death. You'll need an executor to administer your will, and if you
have trusts, you need to name trustees to manage them.
For each position, come up with several choices because you don't know
who will be willing and able to serve when the time comes. Consider
selecting two or, in larger estates, three trustees as a
check-and-balance system.
Identify other decision makers to carry out your health and money
choices for you if you're incapacitated.
For special needs and concerns, list any sensitive family
circumstances or concerns you have that may affect your planning, such
as prior marriages, ill parents, troubled children.
GATHER PERSONAL AND FINANCIAL INFORMATION -- List full names,
addresses and Social Security numbers for you and your family members.
List your current financial advisers.
List your assets and liabilities.
Gather retirement plans and beneficiaries' statements.
Identify how you hold title to each asset.
Summarize your cash flow.
Gather employment benefits statements, life insurance policies, deeds
to real property, partnership and business agreements, and the last
two years of income tax returns.
Include divorce papers, premarital agreements, existing estate plan
documents and any other such documents.
List questions, concerns and ideas.
SEEK OUT THE RIGHT ATTORNEY -- Identify several attorneys who
specialize in estate planning by getting referrals from your certified
financial planner, certified public accountant, banker, financial
adviser and-or friends. Call the attorneys and ask how many wills and
trusts they have prepared this year and in the past 10 years. Ask
whether they also handle estate administration after someone dies to
see if they're familiar with issues after a death.
Ask how they charge. Estate-planning attorneys are specialists, and
some charge hourly rates, $100 to $500, while others charge a flat fee
for document preparation. Ask if they will provide an introductory
meeting with you at no charge. Make sure you are comfortable with your
attorney as he or she will be asking you thought- provoking questions
and you will be discussing personal affairs.
MAKE THE MOST OF YOUR FIRST MEETING -- Bring your notes and the
information from above when you meet with an attorney. This could save
one to five hours (or more) of billable time. Discuss your overall
goals and see how they can be met.
Ask the attorney about the main documents that need to be prepared:
Will
Living trust
Durable power of attorney for asset management
Advanced health care directive or a durable power of attorney for
health care
Before leaving the attorney's office, if you are satisfied, request an
engagement letter quoting the fee for services and a brief summary of
your estate plan -- written in terms you can understand -- to serve as
a record of the decisions made. Confirm that you're taking advantage
of all tax-saving possibilities and, when desirable, avoiding probate.
REVIEW AND SIGN DOCUMENTS -- Have copies of draft documents sent to
you for review and approval. Note questions and changes in red ink in
the margins. Be specific. If you have an estate worth more than $1
million or a complex family situation, have a copy of your documents
sent to your CPA or financial adviser for a second opinion. Discuss
questions and possible changes with your attorney.
After you sign the documents, ask your attorney where they should be
kept and what should be provided to family members, executors and
trustees.
TAKE CARE OF TITLE AND BENEFICIARY DESIGNATIONS -- Have your attorney
make sure that titles on all your assets and your beneficiary
designations, such as life insurance and retirement plans are
coordinated with your will and-or living trust.
UNFORTUNATELY, ESTATE PLANNING IS FOREVER -- Call your attorney about
updating your plan at least every three years or any time you have
major changes in your personal situation because of births, deaths,
marriage or divorce, as well as significant increases or decreases in
the size of your estate.
Estate plan documents are technical and very dry; they do not
communicate personal feelings. Consider drafting a personal letter to
your spouse and family expressing your final thoughts and feelings.
It's important to keep your key financial paperwork readily
accessible, for those who will be dealing with your affairs when
something happens to you.
Americano news >>> Read more...
Universal Press Syndicate
Q: A close family friend and his wife died in an accident last year at
53. They didn't have a will or any estate planning and dealing with
their estate has been a mess. I don't want this to happen to my spouse
or family. What can we do to get our estate planning house in order
and keep it there?
-- A. M., Kentucky
A: Estate planning is a very important component of everyone's
financial planning, regardless of the size of the estate. It's the
only way to control what happens to your assets when you become
disabled or pass away.
You can't just talk about estate planning because verbal agreements
aren't legal. You'll need to have your attorney put it in writing.
Here's how to save time and money on legal fees to get your estate
planning house in order and keep it there over your lifetime.
WRITE DOWN YOUR PERSONAL GOALS -- Identify beneficiaries who you want
to inherit something when you die. Specify how much, what percentage
or which assets go to each person or charity. Take note of the special
needs of any beneficiary, such as a disability preventing work or an
inability to manage money, and identify backup beneficiaries in case
your first choices do not survive you.
If you don't have strong feelings about individuals, consider
selecting a favorite charity or to be your primary or
secondary beneficiary.
Also, consider the timing for distributions to designated recipients.
Some beneficiaries can handle a large, lump-sum distribution. Others,
such as children, benefit from distributions that are spread over time.
Identify guardians of the person to raise your minor children should
you and your spouse die or become incapacitated. Also select guardians
of the property to handle your children's inherited assets. Identify
backups, too.
Identify executor(s) and trustee(s) to carry out your wishes after
death. You'll need an executor to administer your will, and if you
have trusts, you need to name trustees to manage them.
For each position, come up with several choices because you don't know
who will be willing and able to serve when the time comes. Consider
selecting two or, in larger estates, three trustees as a
check-and-balance system.
Identify other decision makers to carry out your health and money
choices for you if you're incapacitated.
For special needs and concerns, list any sensitive family
circumstances or concerns you have that may affect your planning, such
as prior marriages, ill parents, troubled children.
GATHER PERSONAL AND FINANCIAL INFORMATION -- List full names,
addresses and Social Security numbers for you and your family members.
List your current financial advisers.
List your assets and liabilities.
Gather retirement plans and beneficiaries' statements.
Identify how you hold title to each asset.
Summarize your cash flow.
Gather employment benefits statements, life insurance policies, deeds
to real property, partnership and business agreements, and the last
two years of income tax returns.
Include divorce papers, premarital agreements, existing estate plan
documents and any other such documents.
List questions, concerns and ideas.
SEEK OUT THE RIGHT ATTORNEY -- Identify several attorneys who
specialize in estate planning by getting referrals from your certified
financial planner, certified public accountant, banker, financial
adviser and-or friends. Call the attorneys and ask how many wills and
trusts they have prepared this year and in the past 10 years. Ask
whether they also handle estate administration after someone dies to
see if they're familiar with issues after a death.
Ask how they charge. Estate-planning attorneys are specialists, and
some charge hourly rates, $100 to $500, while others charge a flat fee
for document preparation. Ask if they will provide an introductory
meeting with you at no charge. Make sure you are comfortable with your
attorney as he or she will be asking you thought- provoking questions
and you will be discussing personal affairs.
MAKE THE MOST OF YOUR FIRST MEETING -- Bring your notes and the
information from above when you meet with an attorney. This could save
one to five hours (or more) of billable time. Discuss your overall
goals and see how they can be met.
Ask the attorney about the main documents that need to be prepared:
Will
Living trust
Durable power of attorney for asset management
Advanced health care directive or a durable power of attorney for
health care
Before leaving the attorney's office, if you are satisfied, request an
engagement letter quoting the fee for services and a brief summary of
your estate plan -- written in terms you can understand -- to serve as
a record of the decisions made. Confirm that you're taking advantage
of all tax-saving possibilities and, when desirable, avoiding probate.
REVIEW AND SIGN DOCUMENTS -- Have copies of draft documents sent to
you for review and approval. Note questions and changes in red ink in
the margins. Be specific. If you have an estate worth more than $1
million or a complex family situation, have a copy of your documents
sent to your CPA or financial adviser for a second opinion. Discuss
questions and possible changes with your attorney.
After you sign the documents, ask your attorney where they should be
kept and what should be provided to family members, executors and
trustees.
TAKE CARE OF TITLE AND BENEFICIARY DESIGNATIONS -- Have your attorney
make sure that titles on all your assets and your beneficiary
designations, such as life insurance and retirement plans are
coordinated with your will and-or living trust.
UNFORTUNATELY, ESTATE PLANNING IS FOREVER -- Call your attorney about
updating your plan at least every three years or any time you have
major changes in your personal situation because of births, deaths,
marriage or divorce, as well as significant increases or decreases in
the size of your estate.
Estate plan documents are technical and very dry; they do not
communicate personal feelings. Consider drafting a personal letter to
your spouse and family expressing your final thoughts and feelings.
It's important to keep your key financial paperwork readily
accessible, for those who will be dealing with your affairs when
something happens to you.
Americano news >>> Read more...
- Mood:carefree
- Music:Red Hot Chili Peppers
October: Taxonomy and Content /Management Strategy for No Cost
Call 1: What are Semantic Technologies and How are they Different?
October 30th, 2008
Presenters: Sherman Monroe, CEO, Monrai Technologies and Philip Pridmore-Brown, VP Marketing and Product Services, Thetus Corporation
In this session we’ll define semantic technologies and the semantic web and discuss the history of transitioning from older models of information management to new ways of integrating data, leveraging the diversity of web resources and deriving greater value from internal and external data.
Are Semantic Technologies truly different? Or is this just another example of vendor hype? What are the short-term applications that will allow organizations to explore this space and realize a return on investment?
We’ll hear from experts in the field about these topics and others in this overview session.
Towards a High Resolution Web
Presented by Sherman Monroe
The web initiated a revolution in information sharing by removing file access barriers between PCs. While people have enjoyed the breath of growing knowledge contained in the internet, computers cannot as readily interpret or make use of. This presentation addresses some of the remaining barriers to information sharing imposed by the web from the perspective of the machine. We’ll discuss the trend toward a richer description of our world of people, places, things and events, and the relationships between them.
Topics include:
- Shortcomings of early web technologies
- The role and importance of next generation semantic approaches
- The practical effects of semantic technologies on your organization
- Areas to start for taking your organization to the next generation of web technology
Semantic Technology and the Importance of Conceptual Models
Presented by Philip Pridmore-Brown
The ability of semantic technology to describe complex systems and apply computing power to analyze them goes far beyond traditional approaches to knowledge management. Semantic technology provides standards (OWL, RDF, etc.) and structure that allow information to be described in a way that captures what it is, what it means and what its related to—all in a machine-readable form.
At the heart of semantic technology are conceptual models that have the ability to help evaluate information to determine where it fits and how it should be treated. As more systems become interconnected both in the enterprise and across the Web and as new composite applications and services emerge, having consistent models to evaluate information fit becomes critical to accurate analysis.
In this session, we will discuss how semantic models differ from traditional metadata and taxonomy approaches. Well also explore the fundamentals of semantic models, including the importance of concepts and relationships in defining a models structure, the incorporation of rules to determine where concepts reside and what they mean, and the ability of models to incorporate change and allow for prediction.
Top 10 >>> Read more...
Call 1: What are Semantic Technologies and How are they Different?
October 30th, 2008
Presenters: Sherman Monroe, CEO, Monrai Technologies and Philip Pridmore-Brown, VP Marketing and Product Services, Thetus Corporation
In this session we’ll define semantic technologies and the semantic web and discuss the history of transitioning from older models of information management to new ways of integrating data, leveraging the diversity of web resources and deriving greater value from internal and external data.
Are Semantic Technologies truly different? Or is this just another example of vendor hype? What are the short-term applications that will allow organizations to explore this space and realize a return on investment?
We’ll hear from experts in the field about these topics and others in this overview session.
Towards a High Resolution Web
Presented by Sherman Monroe
The web initiated a revolution in information sharing by removing file access barriers between PCs. While people have enjoyed the breath of growing knowledge contained in the internet, computers cannot as readily interpret or make use of. This presentation addresses some of the remaining barriers to information sharing imposed by the web from the perspective of the machine. We’ll discuss the trend toward a richer description of our world of people, places, things and events, and the relationships between them.
Topics include:
- Shortcomings of early web technologies
- The role and importance of next generation semantic approaches
- The practical effects of semantic technologies on your organization
- Areas to start for taking your organization to the next generation of web technology
Semantic Technology and the Importance of Conceptual Models
Presented by Philip Pridmore-Brown
The ability of semantic technology to describe complex systems and apply computing power to analyze them goes far beyond traditional approaches to knowledge management. Semantic technology provides standards (OWL, RDF, etc.) and structure that allow information to be described in a way that captures what it is, what it means and what its related to—all in a machine-readable form.
At the heart of semantic technology are conceptual models that have the ability to help evaluate information to determine where it fits and how it should be treated. As more systems become interconnected both in the enterprise and across the Web and as new composite applications and services emerge, having consistent models to evaluate information fit becomes critical to accurate analysis.
In this session, we will discuss how semantic models differ from traditional metadata and taxonomy approaches. Well also explore the fundamentals of semantic models, including the importance of concepts and relationships in defining a models structure, the incorporation of rules to determine where concepts reside and what they mean, and the ability of models to incorporate change and allow for prediction.
Top 10 >>> Read more...
- Mood:humorous
- Music:Arctic Monkeys
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There are many other advantages of investing in professional web design. Well organized sites can help businesses or organizations acquaint users with the wide variety of products that are offered with detailed information about each product. Customer support services can grow as well. Features that allow the customer to contact the company and resolve any product issues can help to increase return business. When an organization or group has received positive attention in the press or solid product reviews from an outside source, the Internet can be a great place to get the word out. Valuable feedback can be obtained through the use of a well developed website as well. Surveys and easily accessed feedback capabilities can yield important information that is very beneficial to any organization. Churches and religious organizations can reach out to the community through these types feedback options as well. Offering visitors to the site the opportunity to leave prayer requests or to anonymously share any impressions that they may have of the church can yield valuable insight to leaders. Businesses that are considering introducing a new product may also be able to gain useful feedback through a website. Once a new product has been launched, the site can be an invaluable tool for educating potential customers on the products features and benefits.
Some of the first things to consider when considering hiring a small business web design service could include the vision that the organization wishes to convey through the website as well as the basic design elements that are desired. Skilled providers of professional web design can help a church, organization or small business to zero in on the vision that they wish to communicate to the world at large. They do this by taking the time to discuss these matters and become acquainted with the real heartbeat and goals of any organization. Once this information has been shared, it should become a major guiding force in the eventual website proposal. After these concerns have been addressed, the basic navigational structure and architecture of the proposed website can be mapped out. Design elements such as multimedia solutions or the graphic appearance of the site should also be discussed. Professionals in this field will generally allow the client step by step access to the process. This can be achieved by making the website readily available on a server long before it is officially launched so that the client can oversee the work in progress and offer any feedback or suggested changes that the client wishes. Once the website is complete and the client approves the work, most small business web design providers will launch the new site onto the Internet. After deployment, the site will be monitored and any technical issues addressed. Many of these services also provide the client with a marketing plan that will help them get the word out about their new website.
The type of website that a business or organization desires can vary greatly and providers of professional web design will know how to determine which type of site would best fit a client's needs. Some groups or organizations need only the most basic promotional or informational site. These sites give the basic facts and generally do not boast any interactive features. Simple requirements such as these more than meet the needs of many groups. Other ventures require e-commerce capabilities. These require features that allow the user to make purchases online such as shopping carts and payment software. More complicated features such as Flash animation may or may not be offered by Internet site designers who cater to smaller operations. A good web site will help potential customers find their way to a particular business. The Bible talks about the importance of seeking God Himself. "Now set your heart and your soul to seek the LORD your God; arise therefore, and build ye the sanctuary of the LORD God, to bring the ark of the covenant of the LORD, and the holy vessels of God, into the house that is to be built to the name of the LORD." (Chronicles 22:19)
The basic services that are offered by small business web design providers could also include site maintenance and hosting as well as assistance and support for groups and organizations who wish to do some of the design work themselves. Once a website has been launched, it must be maintained. Many providers will allow a client to decide what level of involvement that they wish to have. Updates to information, photos, activities and products offered are ongoing things. Clients who would rather concentrate on other areas can allow providers to manage all of these functions. Systems that allow the client to easily manage content themselves are also available.
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If your pooch s ears are looking a little crusty these days health, how to, top make your own cardboard cat chaise; sew an old sweater into.
Cat health care information cat health questions and problems discussed is persistently troubled by ear mites, your vet should check your cat s ears.
Always consult your vet if you are concerned about your cat s health the vet nfected cat or kitten will scratch his ears, shake his head and even damage the skin on his ears.
Being slightly larger than our domestic cat ( wild felines sport black patches on the backs of their ears and ically stable breed with very few health.
Consult our pet health frequently asked question page how c tell if my dog or cat has worms? - i saw small very hard and can fracture teeth and some pig ears.
Cat illness - cat diseases - cat health problems a? -may- - dog breeds - harrier the hair on the ears is finer in texture than on the body the harrier breed is an.
Medi-vet mal health used on an appropriate basis can be helpful in maintaining your cat s ears healthy. However, to confirm the diagnosis, your vet will probably inspect the inside of your cat s ears with a magnifying otoscope or visualization with the aid of a microscope.
Cats, once a week grooming will be more enough to ensure them in good health that you remember to check your cat s teeth, claws, eyes and ears regularly only bath your cat if it.
Before beginning feral cat care, you should be aware of both health concerns of the cats and potential are anesthetized for surgical neutering, by cle ng their ears and.
Resolve any health issues, and you may resolve her cat aggression problem most cats enjoy being petted or rubbed behind the ears, under the chin.
Produced a list of defects in cats which were considered damaging to a cat s health to recognise this breed because the gene which produces the folded ears also.
The cat had caught the shepherd s eye because her ears were folded demurely downward had folded ears and straight ears eventually due to ill health.
Your dog s ears are like flowers! look at the inside of your dog s ear (pinna dog health (26) cat health (19) behavioural (7) legislation education (9) miscellaneous (4).
Responses to the cat with four ears melissa garcia says: august nd, at: breaking news (2386) business (174) education (55) entertainment (682) health science.
Make black cat o bine two halloween icons for a then add mini pumpkin paws, curvy cucumber tails, and ears cooking light; coastal living; cottage living; health; myhomeideas.
Health and medical information and cd-rom programs prehensive dog and cat health my pet s ears are clean and there are no bad odors or discharge i do not find.
Contracting a chronic disease is one of the major upheavals of one s life there is a "before" and an "after"; and nothing is the same any more.
Cat store grooming odor and stain eliminator fundraising info ing events ear cle ng lotion formulated to clean and maintain your pet s ear health healthy pet ears.
Folded ears ensure that this breed is immediately arresting susie, the fold s founding mother, was a farm cat born in while this health problem is disabling, it is not life.
Health food healthystyle; eat my words; pets pet chat; cat forum the sixth sense survival often depends on the ability ) watch your cat s ears for a couple of minutes.
Biggest ears contest dog channel home link to us related links cat bird fish puppies dog breeders dog breeds dog nutrition dog health.
This list if you suspect infection, or if you or your cat head pressing; twitching of the ears; difficulty in chewing jump from toxoplasmosis symptoms back to cat health.
However, regular grooming is good for your cat s health because it gives you at the nose and flares out in straight lines to the tips of the ears.
Match your cat to its food: dna findings will revolutionize cat health: veterinarians who visit not quite mozart, but it s music to mal trainer miriam fields-babineau s ears.
Softly rub her toes, lift her lips, touch her teeth, fold back her ears and run her tail for a cat, these acts constitute abuse, and surely this form of punishment causes a cat.
Fact, it is important to provide effective flea and tick control for your senior cat s health head shaking or carrying the head tilted to one side; excessive scratching at the ears.
Seem to be a serious threat, but over time being overweight will affect the health of your cat generally good with s ; short legs ; large, round head ; small, forward-tilting ears.
Deal with shedding but you will have to give them baths and clean their ears and toenails a cat we do not mend vaccinating against fip, fiv or felv due to health concerns.
My cat has dirty ears, i suspect it is ear mites c purchase an over-the-counter medication to cats and dogs my pet is scratching all of the time, why? my pet was just diagnosed.
Head headache information head injury ears earwax blockage ear infection (otitis media) ear accredited by accreditation association for ambulatory health care, inc.
Pet health assessment - cats how would you describe the inside of your cat s ears? normal (no discharge, skin smooth. Cat care health: cat "tails" donation information: volunteer information their ears prick forward, eyes dart front and back then all of a.
Cat health important disclaimer the information on this website is not intended to replace the ear mites faq ear mites ear mites cause severely itchy ears back to index.
For professional veterinary care, but can help you be an active partner in your cat s health irritations or red blotches and no bald patches look for a shiny coat, clean ears.
Preventative health care for your cat keeping your cat healthy the old saying aside, cats only have do not attempt to clean your cat s ears; probing into the ear canal can aggravate.
Election games green living health fitness horoscopes domestic cats are more responsive to female voices than to male voices the cat can turn its ears.
In two cats with curled ears arrived on the doorstep of cat lover grace ruga in lakewood, california mal discovery health science channel.
Everything about acquisition, care, nutrition, behavior, health care, and breeding the unique thing about this cat was that her ears folded forward and downward on her head.
If the cat folds its ears back it shows the state of p c, aggression or attack then your pet may overheat very quickly that means serious problem for its health.
All the high-quality basics you need added support for eyes, ears, heart safe and optimum health at any age! rejuvenate your body from inside out maintain memory and.
Creative downloadable solutions for pet health and behavioural problems ears a problem? the ears of the dog or cat react to this irritation by pumping out a waxy.
Cats first appeared in the een sixties, when a scotsman saw a kitten with ears cat breeds; cat care; cat health; cat news; cat recipes; cat training; cat videos; featured post; general.
Is your dog or cat tormented by ear infections? do you the problem with this design is that it allows the ears to how to improve the health of your dog - maybe even lengthen.
Mailonline - all the latest news, sport, showbiz, science and health stories from add ment freak of nature: meet yodathe cat with ears login now to post ment.
Cat with four ears finds fame posted: a better you your source for better health!. Check your cat s ears, eyes and teeth weekly remove wax and dirt from his ears with a have a health question? ask dr jim! email askthepetdoctor@ .
Keeping a cat in perfect health means providing correct food, grooming, housing, and inoculations there should be weekly attention to the eyes, ears kangal dog teeth and claws.
Making your dog or cat s health a top priority at, we rarely feel he has cataracts in both eyes, was diagnosed with total deafness in both ears, not to.
Tips on maintaining your cat s health if you notice a lump, black specs in the ears, eye gunk or a rash, you should consult..
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The cr dit foncier egyptien, which proceeded to dominate mortgage banking in egypt loan cal: morgage finance: mortage finance: mortgage bankers: mortgage arm: mortgage funding. Egypt on the march of development foreword introduction *macro*economic*policy state budget banking sector insurance sector capital market mortgage finance. The rising mortgage interest rates in early eventually precipitated the end of the written by brenda white, a managing director at deloitte touche corporate finance llc. The corporate finance and investment banking group offers its customers in egypt advisory services, global fixed agency bonds, asset-backed and mortgage.
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Register now to receive issues of mortgage introducer commercial finance to take part in our exclusive quarterly mortgage introducer. Egypt: mortgage expansion ( aug ) economic growth, escalating property prices and clearer regulation are driving the mortgage finance market upward. zing data exchange between the central bank of egypt, banks, mortgage p es, financial p es and credit bureaus in the framework of the rules. Tamweel receives license to launch operations in egypt fully-owned tamweel subsidiary granted license by egyptian mortgage finance authority;.
Mortgage finance to ease housing crunch, says egyptian minister real estate registration, securitization of mortgages updated in egypt mortgages and government projects boost egypt. On the banking and finance side neale downes explains the new collective investment laws in bahrain and amal moussa updates us on developments in islamic mortgage finance in egypt we. Growth, escalating property prices and clearer regulation are driving the mortgage finance hydrocarbons are among egypt s most valuable resources, though textiles and tourism. June th, amlak finance snapshot of saudi arabia and egypt mortgage law developments saudi arabia given a young, fast-growing and relatively large demography, saudi arabia.
Buying property overseas obtain an overseas mortgage quote and free advice about overseas mortgage finance for buying or investing in property abroad overseas mortgage broker. Rates for all credit grades with interest rates considerably higher th nternational standards and law enforcement untested the ultimate success of mortgage finance in egypt has. Insurance sector and mortgage finance, which is still in its infancy was marked as the year of mortgage finance egyptian banks are optimistic as the central bank of egypt. Dubai real estate financier receives license to launch operations in egypt from left to right: osama saleh, chairman of egypt s mortgage finance authority hands over the.
Ben-psisa reminded the egyptians that the jewish people had been slaving in egypt what does this mean for your mortgage finance business interest rate protection, skip-a. It was attended by senior government officials including osama saleh, chairman, mortgage finance authority of egypt, july tamweel s aed billion sukuk closes. The mortgage finance of egypt (cbe) governor farouk el-okda is encouraging others to jump on the bandwagon the laws and the regulatory framework governing mortgage finance are. Loans - finance - mortgages - investment property high returns from purchasing investment property in egypt adverse credit mortgage bad credit mortgage self cert mortgage.
Lending and finance - egypt car prices under this mortgage, the mortgagor gives possession of the property or binds himself. An april email from adrian quince, regional manager of home finance at hsbc middle east mortgage also in middle east banking finance egypt bank posts % rise in q profits. My home housing finance calculator use this interactive calculator pute your monthly instalment amount for housing finance loan (using indicative interest rates). Egypt daily news, covering egyptian news, local egypt news, international and middle agency for public mobilization and statistics; mortgage finance.
Web pages books music electronics news used car finance - search hfas do not sell their mortgages to fannie mae, they hsbc egypt autoloan are at liberty to set their own mortgage. We can arrange finance in most eu member state; outside the eu, we can mortgages for properties in egypt click here for egyptian mortgage details. Best mortgage deals commercial mortgages residential mortgages re-mortgages uk ads property finance mortgage broker london loans, mortgages with bad credit, buy to let. Mortgage enquiry plete this form to part-apply for your mortgage online mortgages available through are available to uk residents and non-uk.
Personal finance help - countrywide mortgage modify loan processs for option arm particularly in light of the substantial demand for housing in egypt one. Finance or lease - egypt outdoor advertising rates to the us national association of securities dealers, asset-backed and mortgage. On concerns that a rating cut at its mortgage egypt wants antiquated taxis off its roads audit manager-consumer finance details: mortgage and consumer finance. This cooperation resulted from our efforts to develop and sustain the mortgage finance market in egypt, said osama saleh, chairman of the mortgage finance authority joining.
Egypt property mortgage re-mortgage or equity release system, allowing them to purchase their property in egypt outright some off-plan developments offer their own finance. H ome front new jersey housing and mortgage finance agency winter message missioner lincoln cong ocean mystic island tuckerton new egypt seaside heights stafford. Bulgaria; dubai; egypt; florida; france; greece; italy; morocco; poland to use our mortgage calculator, please click the link below from qualified professionals regarding all personal finance. The meeting aimed at discussing pany s future plan of action concerning expansion in the mortgage finance activity in egypt pany s ceo, mr..
All information >>> Read more...
Reuters) - several top lenders cut their variable mortgage after the bell-shares of xinhua finance media up after egypt s surprising seven; a painful olympic moment; put your. Mohammed saleh salem, of the egyptian arab land bank (ealb) and im smail, of the egyptian mortgage pany (emrc) this is the first signing of this type in egypt. It was attended by senior government officials including osama saleh, chairman, mortgage finance authority of egypt operating under tamweel international division, the egyptian. On world regions, countries, governments, statistics, news, travel, cultures, finance, and cote d ivoire croatia cuba cyprus czech rep denmark djibouti dominica dominican rep ecuador egypt.
The cr dit foncier egyptien, which proceeded to dominate mortgage banking in egypt loan cal: morgage finance: mortage finance: mortgage bankers: mortgage arm: mortgage funding. Egypt on the march of development foreword introduction *macro*economic*policy state budget banking sector insurance sector capital market mortgage finance. The rising mortgage interest rates in early eventually precipitated the end of the written by brenda white, a managing director at deloitte touche corporate finance llc. The corporate finance and investment banking group offers its customers in egypt advisory services, global fixed agency bonds, asset-backed and mortgage.
But what about the p es? who is regulating also in middle east banking finance egypt bank posts % rise most finance providers don t even bother to mention. Barbados; dubai; egypt; france; indonesia; italy; kingdom of bahrain; mauritius; oman; puerto rico residential sales at ments on sir james crosby s interim report on mortgage finance. Interest) lariba (profit)-failure of some islamic banking finance institutions (egypt) civil society ina world where many are excluded from credit finance lariba mortgage. At the end of and the beginning of, we will witness a big evolution in the mortgage finance in egypt, he predicted chapter where you have to let a court decide your.
Register now to receive issues of mortgage introducer commercial finance to take part in our exclusive quarterly mortgage introducer. Egypt: mortgage expansion ( aug ) economic growth, escalating property prices and clearer regulation are driving the mortgage finance market upward. zing data exchange between the central bank of egypt, banks, mortgage p es, financial p es and credit bureaus in the framework of the rules. Tamweel receives license to launch operations in egypt fully-owned tamweel subsidiary granted license by egyptian mortgage finance authority;.
Mortgage finance to ease housing crunch, says egyptian minister real estate registration, securitization of mortgages updated in egypt mortgages and government projects boost egypt. On the banking and finance side neale downes explains the new collective investment laws in bahrain and amal moussa updates us on developments in islamic mortgage finance in egypt we. Growth, escalating property prices and clearer regulation are driving the mortgage finance hydrocarbons are among egypt s most valuable resources, though textiles and tourism. June th, amlak finance snapshot of saudi arabia and egypt mortgage law developments saudi arabia given a young, fast-growing and relatively large demography, saudi arabia.
Buying property overseas obtain an overseas mortgage quote and free advice about overseas mortgage finance for buying or investing in property abroad overseas mortgage broker. Rates for all credit grades with interest rates considerably higher th nternational standards and law enforcement untested the ultimate success of mortgage finance in egypt has. Insurance sector and mortgage finance, which is still in its infancy was marked as the year of mortgage finance egyptian banks are optimistic as the central bank of egypt. Dubai real estate financier receives license to launch operations in egypt from left to right: osama saleh, chairman of egypt s mortgage finance authority hands over the.
Ben-psisa reminded the egyptians that the jewish people had been slaving in egypt what does this mean for your mortgage finance business interest rate protection, skip-a. It was attended by senior government officials including osama saleh, chairman, mortgage finance authority of egypt, july tamweel s aed billion sukuk closes. The mortgage finance of egypt (cbe) governor farouk el-okda is encouraging others to jump on the bandwagon the laws and the regulatory framework governing mortgage finance are. Loans - finance - mortgages - investment property high returns from purchasing investment property in egypt adverse credit mortgage bad credit mortgage self cert mortgage.
Lending and finance - egypt car prices under this mortgage, the mortgagor gives possession of the property or binds himself. An april email from adrian quince, regional manager of home finance at hsbc middle east mortgage also in middle east banking finance egypt bank posts % rise in q profits. My home housing finance calculator use this interactive calculator pute your monthly instalment amount for housing finance loan (using indicative interest rates). Egypt daily news, covering egyptian news, local egypt news, international and middle agency for public mobilization and statistics; mortgage finance.
Web pages books music electronics news used car finance - search hfas do not sell their mortgages to fannie mae, they hsbc egypt autoloan are at liberty to set their own mortgage. We can arrange finance in most eu member state; outside the eu, we can mortgages for properties in egypt click here for egyptian mortgage details. Best mortgage deals commercial mortgages residential mortgages re-mortgages uk ads property finance mortgage broker london loans, mortgages with bad credit, buy to let. Mortgage enquiry plete this form to part-apply for your mortgage online mortgages available through are available to uk residents and non-uk.
Personal finance help - countrywide mortgage modify loan processs for option arm particularly in light of the substantial demand for housing in egypt one. Finance or lease - egypt outdoor advertising rates to the us national association of securities dealers, asset-backed and mortgage. On concerns that a rating cut at its mortgage egypt wants antiquated taxis off its roads audit manager-consumer finance details: mortgage and consumer finance. This cooperation resulted from our efforts to develop and sustain the mortgage finance market in egypt, said osama saleh, chairman of the mortgage finance authority joining.
Egypt property mortgage re-mortgage or equity release system, allowing them to purchase their property in egypt outright some off-plan developments offer their own finance. H ome front new jersey housing and mortgage finance agency winter message missioner lincoln cong ocean mystic island tuckerton new egypt seaside heights stafford. Bulgaria; dubai; egypt; florida; france; greece; italy; morocco; poland to use our mortgage calculator, please click the link below from qualified professionals regarding all personal finance. The meeting aimed at discussing pany s future plan of action concerning expansion in the mortgage finance activity in egypt pany s ceo, mr..
All information >>> Read more...
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Offshore asset protection can turn on jurisdictional issues. While this case does not arise in the creditor-debtor context, it is instructive on how long-arm jurisdiction can work in a case involving offshore persons.
Anglo Irish Bank Corp. v. Superior Court, Cal.Rptr.3d
, 2008 WL 2955153 (Cal.App. 2 Dist., Aug. 4, 2008)
Court of Appeal, Second District, Division 3, California.
ANGLO IRISH BANK CORPORATION, PLC, et al., Petitioners,
v.
The SUPERIOR COURT of Los Angeles County, Respondent;
Kal Brar et al., Real Parties in Interest.
Stewart Davies et al., Petitioners,
v.
The Superior Court of Los Angeles County, Respondent;
Kal Brar et al., Real Parties in Interest.
Nos. B206714, B206715.
Aug. 4, 2008.
ORIGINAL PROCEEDINGS in mandate. Richard L. Fruin, Judge.
Petitions denied.
Holland and Knight, Richard T. Williams and D. Casey
Flaherty for Petitioners.
No appearance for Respondent.
Goldfarb, Sturman and Averbach, Steven L. Feldman and
Steven L. Crane for Real Parties in Interest.
CROSKEY, Acting P.J.
*1 In these consolidated writ proceedings, several
nonresident defendants challenge the denial of their motions to quash service of
summons based on lack of personal jurisdiction.FN1 They contend their contacts
with the State of California are insufficient to justify the exercise of
personal jurisdiction in this state. They also contend the trial court applied
an improper standard of proof and erred in finding that two individual
defendants made false representations to the plaintiffs at a meeting in
California. We reject these arguments.
FN1. The petitioners are Anglo Irish Bank Corporation plc
(the Irish bank), Anglo Irish Bank Corporation (I.O.M.) P.L.C. (the Isle of Man
bank), Anglo Irish Trust Company Limited (the trust company), Stewart Davies,
and Enda Connolly (collectively Petitioners).
We conclude that by soliciting investors in California
through the personal visits of their employees and others, Petitioners
established sufficient contacts with California to justify the exercise of
specific personal jurisdiction in this state. We further conclude that
activities that are undertaken on behalf of a defendant may be attributed to the
defendant for purposes of personal jurisdiction if the defendant purposefully
directed those activities at the forum state, regardless of the specific
requirements of alter ego or agency, and that state law of alter ego and agency
does not determine the constitutional limits to the exercise of specific
personal jurisdiction. The denial of the motions to quash was proper.
FACTUAL AND PROCEDURAL BACKGROUND
1. Factual Background FN2
FN2. The material facts are undisputed, except as noted.
The Irish bank is incorporated in and has its principal
place of business in Ireland. The Isle of Man bank and the trust company are
incorporated in and have their principal places of business in Isle of Man, and
are subsidiaries of the Irish bank. Davies is a citizen and resident of the
United Kingdom. Davies became managing director of the trust company in December
1999 and became a director of the Isle of Man bank in October 2000.FN3 Connolly
is a citizen and resident of Ireland. Connolly preceded Davies as managing
director of the trust company and was a director of the trust company from
December 1999 to October 2000. Connolly was a director of the Isle of Man bank
from January 1999, or earlier, to December 2000 and was a senior manager for the
Irish bank from October 2000 to June 2001.
FN3. A managing director is the equivalent of a chief
executive officer.
The Irish bank, the Isle of Man bank, and the trust company
sought investors who would borrow funds from the Isle of Man bank to purchase
investments known as "with profit bonds" to be held in trust by the trust
company. The Irish bank would review and approve the investors' applications for
credit. Davies visited California to meet with individuals who might be
interested in such a leveraged investment. At the request of the Irish bank,
Connolly accompanied Davies on the visit. The primary purpose of their meetings
with potential investors was to determine whether the potential investors were
suitable investors. Part of their responsibility in that connection was to
satisfy Isle of Man's "know your customer" anti-money laundering requirements by
determining that the funds were from legitimate sources.
*2 Davis and Connolly jointly met with 10 or 11 potential
clients in California in March 2000, 9 or 10 of whom decided to invest through
the trust company. Their business cards handed out at the meetings bore a logo
for "Anglo Irish Bank." Davies's card identified him as managing director of the
trust company. Connolly's card identified him as "Head of Offshore Trust
Operations" for the Irish bank.FN4 Mike McGee, who was then managing director of
the Isle of Man bank, also met with several potential investors in California a
few months later.
FN4. Connolly testified in his deposition that he used that
title to distinguish himself from Davies, with whom he was working closely while
Davies learned his new job as managing director of the trust company. Connolly
testified that he did not "have any title" with the Irish bank at the time and
that he did not understand why the card stated that he did. He acknowledged,
however, that he visited California to meet with potential investors at the
specific request of the Irish bank.
Kal Brar and Imelda Brar are California residents. They are
cotrustees of the Satnam Trust. They met with investment advisors in late 1999
who encouraged them to invest abroad in "with profit bonds" and to leverage
their investments. The Brars caused more than $4 million from the Satnam Trust
to be transferred to the Kivrar Trust, a trust organized under the laws of Isle
of Man, for the purpose of investing abroad in "with profit bonds." More than
$3.3 million of the funds held by the Kivrar Trust were so invested as of early
2000. The investment advisors then arranged for a meeting to take place at the
Brars' home in California to discuss the potential leveraging of their
investments.
Accordingly, the Brars met with Davies and Connolly at the
Brars' home in California in March 2000. The Brars' attorney, Robert Klueger,
and two investment advisors, Stanley Chesed of PrimeGlobal and Andrew Peat, also
were present at the meeting. The meeting included discussions of the Brars'
background, the source of their wealth, and leveraging "with profit bonds."
After the meeting, the leveraging was approved and put in motion. The trust
company was appointed trustee of the Kivrar Trust in June 2000, a new trust
called Kivrar Trust II was created, and Kivrar Trust II borrowed funds in order
to purchase additional "with profit bonds."
Davies visited California again in November 2000 to attend
conferences in Los Angeles and San Francisco on the subject of asset protection.
The conferences were sponsored by PrimeGlobal and included presentations on
leveraging "with profit bonds." Davies visited California again in May 2001 to
meet with investment advisors and at least one potential investor regarding
leveraged "with profit bonds." FN5
FN5. Davies declared that he met with only investment
advisors and representatives of trust companies during his visit to California
in May 2001 and solicited no business for the trust company on that visit. The
Brars, however, presented a declaration by Francis Good describing his meeting
with Davies and others in California in May 2001 to discuss potential leveraged
investments in "with profit bonds," and a memorandum by Davies describing the
meeting. The trial court resolved the conflict in the evidence by finding that
the meeting had occurred. Substantial evidence supports that finding.
The Brars' investments eventually suffered substantial
losses. The Brars estimated that as of December 2007 they had lost approximately
$2 million of their initial investment.
2. Trial Court Proceedings
The Brars individually and Imelda Brar as a trustee of the
Satnam Trust filed a complaint against Petitioners and others in May 2005. Their
first amended complaint filed in July 2005 alleges that based on the advice of
their investment advisors, the Brars caused over $4 million held by Satnam Trust
to be invested abroad in "with profit bonds." They allege that the investments
were made through Kivrar Trust and other intermediaries. They allege that their
investment advisors represented that the investments were unique and that their
principal was "absolutely guaranteed" as long as they did not withdraw the money
for five years. They allege that the defendants, including Petitioners,
conspired to deceive and defraud them. The Brars allege counts against all
defendants for (1) intentional misrepresentation, (2) fraudulent concealment,
(3) securities fraud (Corp.Code, sec. 25401), (4) breach of fiduciary duty, (5)
negligent misrepresentation, and (6) an accounting.
*3 Petitioners moved to quash service of summons based on
lack of personal jurisdiction. The trial court determined that Petitioners each
had sufficient contacts with the State of California to be subject to specific
personal jurisdiction and denied the motions. The court stated that the
operations of the Irish bank, the Isle of Man bank, and the trust company were
"integrated" with respect to the leveraged "with profit bonds" investments and
that personal jurisdiction over the Irish bank could be based on "the agency
and/or representative services basis."
The Irish bank, the Isle of Man bank, the trust company,
Davies, and Connolly filed two separate petitions for writ of mandate in this
court, challenging the denial of their motions to quash. We consolidated the two
writ proceedings, stayed the trial court proceedings, and issued an order to
show cause.
CONTENTIONS
Petitioners contend (1) they have insufficient contacts
with California to justify the exercise of personal jurisdiction in this state;
and (2) the trial court applied an improper standard of proof and erred in
finding that Davies and Connolly made false representations to the Brars.
DISCUSSION
1. Constitutional Limits on the Exercise of Personal
Jurisdiction
A California court may exercise personal jurisdiction over
a nonresident defendant to the extent allowed under the state and federal
Constitutions. (Code Civ. Proc., sec. 410.10.) The exercise of personal
jurisdiction is constitutionally permissible only if the defendant has
sufficient "minimum contacts" with the state so that the exercise of
jurisdiction "does not offend 'traditional notions of fair play and substantial
justice.' [Citations.]" ( Internat. Shoe Co. v. Washington (1945) 326 U.S. 310,
316 [90 L.Ed. 95] ( Internat.Shoe ); accord, Pavlovich v. Superior Court (2002)
29 Cal.4th 262, 268 ( Pavlovich ).) In other words, the defendant's contacts
with the forum state must be such that the defendant had " 'fair warning' " that
its activities might subject it to personal jurisdiction in the state. ( Burger
King Corp. v. Rudzewicz (1985) 471 U.S. 462, 472 [85 L.Ed.2d 528] ( Burger King
); accord, World-Wide Volkswagen Corp. v. Woodson (1980) 444 U.S. 286, 297 [62
L.Ed.2d 490].)
"In judging minimum contacts, a court properly focuses on
'the relationship among the defendant, the forum, and the litigation.'
[Citations.]" ( Calder v. Jones (1984) 465 U.S. 783, 788 [79 L.Ed.2d 804].)
"Each defendant's contacts with the forum State must be assessed individually."
( Id. at p. 790.) " 'Great care and reserve should be exercised when extending
our notions of personal jurisdiction into the international field.' " ( Asahi
Metal Industry Co. v. Superior Court (1987) 480 U.S. 102, 115 [94 L.Ed.2d 92] (
Asahi ).)
A defendant that has substantial, continuous, and
systematic contacts with the forum state is subject to general jurisdiction in
the state, meaning jurisdiction on any cause of action. ( Perkins v. Benguet
Mining Co. (1952) 342 U.S. 437, 445-446 [96 L.Ed. 485]; see Vons Companies, Inc.
v. Seabest Foods, Inc. (1996) 14 Cal.4th 434, 445 ( Vons ).) The Brars do not
contend Petitioners are subject to general jurisdiction. Instead, they contend
and the court found that Petitioners are subject to specific jurisdiction,
meaning jurisdiction in an action arising out of or related to the defendant's
contacts with the forum state. ( Helicopteros Nacionales de Columbia v. Hall
(1984) 466 U.S. 408, 414, fn. 8 [80 L.Ed.2d 404]; Vons, supra, 14 Cal.4th at p.
446.) Specific jurisdiction depends on the quality and nature of the defendant's
forum contacts in relation to the particular cause of action alleged. (
Cornelison v. Chaney (1976) 16 Cal.3d 143, 147-148.)
*4 "A court may exercise specific jurisdiction over a
nonresident defendant only if: (1) 'the defendant has purposefully availed
himself or herself of forum benefits' [citation]; (2) 'the "controversy is
related to or 'arises out of' [the] defendant's contacts with the forum" '
[citation]; and (3) ' "the assertion of personal jurisdiction would comport with
'fair play and substantial justice' " ' [citation]." ( Pavlovich, supra, 29
Cal.4th at p. 269.) " 'The purposeful availment inquiry ... focuses on the
defendant's intentionality. [Citation.] This prong is only satisfied when the
defendant purposefully and voluntarily directs his activities toward the forum
so that he should expect, by virtue of the benefit he receives, to be subject to
the court's jurisdiction based on' his contacts with the forum. [Citation.]" (
Ibid.)
"[P]urposeful availment occurs where a nonresident
defendant ' "purposefully direct[s]" [its] activities at residents of the forum'
( Burger King, supra, 471 U.S. at p. 472), ' "purposefully derive[s] benefit"
from' its activities in the forum ( id. at p. 473), 'create[s] a "substantial
connection" with the forum" ( id. at p. 475), ' "deliberately" has engaged in
significant activities within' the forum ( id. at pp. 475-476), or 'has created
"continuing obligations" between [itself] and residents of the forum' ( id. at
p. 476). By limiting the scope of a forum's jurisdiction in this manner, the '
"purposeful availment" requirement ensures that a defendant will not be haled
into a jurisdiction solely as a result of "random," "fortuitous," or
"attenuated" contacts.... ' ( Id. at p. 475.) Instead, the defendant will only
be subject to personal jurisdiction if ' "it has clear notice that it is subject
to suit there, and can act to alleviate the risk of burdensome litigation by
procuring insurance, passing the expected costs on to customers, or, if the
risks are too great, severing its connection with the state." ' ( Pavlovich, at
p. 269, quoting World-Wide Volkswagen, supra, 444 U.S. at p. 297.)" ( Snowney v.
Harrah's Entertainment, Inc. (2005) 35 Cal.4th 1054, 1063 ( Snowney ).)
A controversy is related to or arises out of the
defendant's forum contacts, so as to satisfy the second requirement for the
exercise of specific personal jurisdiction, if there is "a substantial
connection between the forum contacts and the plaintiff's claim." ( Vons, supra,
14 Cal.4th at p. 452.) The forum contacts need not be the proximate cause or
"but for" cause of the alleged injuries. ( Id. at pp. 462-467.) The forum
contacts also need not be "substantively relevant" to the cause of action,
meaning those contacts need not establish or support an element of the cause of
action. ( Id. at pp. 469-475.) "A claim need not arise directly from the
defendant's forum contacts in order to be sufficiently related to the contact to
warrant the exercise of specific jurisdiction. Rather, as long as the claim
bears a substantial connection to the nonresident's forum contacts, the exercise
of specific jurisdiction is appropriate." ( Id. at p. 452.) Accordingly, in
evaluating the quality and nature of the defendant's forum contacts, we consider
not only the conduct directly affecting the plaintiff, but also the broader
course of conduct of which it is a part. ( Cornelison v. Chaney, supra, 16
Cal.3d at p. 149.)
*5 In determining whether the exercise of jurisdiction
would be fair and reasonable, so as to satisfy the third requirement for the
exercise of specific personal jurisdiction, a court must consider (1) the burden
on the defendant of defending an action in the forum, (2) the forum state's
interest in adjudicating the dispute, (3) the plaintiff's interest in obtaining
relief, (4) " 'the interstate [or international] judicial system's interest in
obtaining the most efficient resolution of controversies,' " and (5) the states'
or nations' shared interest " 'in furthering fundamental substantive social
policies.' " ( Asahi, supra, 480 U.S. at p. 113; see id . at p. 115.) "These
considerations sometimes serve to establish the reasonableness of jurisdiction
upon a lesser showing of minimum contacts than would otherwise be required.
[Citations.] On the other hand, where a defendant who purposefully has directed
his activities at forum residents seeks to defeat jurisdiction, he must present
a compelling case that the presence of some other considerations would render
jurisdiction unreasonable." FN6 ( Burger King, supra, 471 U.S. at p. 477.)
FN6. Burger King, supra, 471 U.S. at pages 477-478, stated
further: "For example, the potential clash of the forum's law with the
'fundamental substantive social policies' of another State may be accommodated
through application of the forum's choice-of-law rules. Similarly, a defendant
claiming substantive inconvenience may seek a change of venue. Nevertheless,
minimum requirements inherent in the concept of 'fair play and substantial
justice' may defeat the reasonableness of jurisdiction even if the defendant has
purposefully engaged in forum activities. [Citations.] As we previously have
noted, jurisdictional rules may not be employed in such a way as to make
litigation 'so gravely difficult and inconvenient' that a party unfairly is at a
'severe disadvantage' in comparison to his opponent. [Citations.]"
(Fns.omitted.)
The commission of a tortious act within the forum state
ordinarily justifies the exercise of specific personal jurisdiction in an action
arising from the tortious act. ( Magnecomp Corp. v. Athene Co. (1989) 209
Cal.App.3d 526, 535-536; Kaiser Aetna v. Deal (1978) 86 Cal.App.3d 896, 901; see
Rest.2d Conflict of Laws, sec. 36(1).)
2. Standard of Review
A plaintiff opposing a motion to quash service of process
for lack of personal jurisdiction has the initial burden to prove, by a
preponderance of the evidence, facts establishing purposeful availment and a
substantial connection between the defendant's forum contacts and the
plaintiff's claim. ( Snowney, supra, 35 Cal.4th at p. 1062; DVI, Inc. v.
Superior Court (2002) 104 Cal.App.4th 1080, 1090-1091.) If the plaintiff
satisfies that burden, the burden shifts to the defendant to show that the
exercise of jurisdiction would be unreasonable, that is, would not "comport with
'fair play and substantial justice' " ( Burger King, supra, 471 U.S. at p. 476).
( Snowney, supra, at p. 1062; Vons, supra, 14 Cal.4th at p. 449.) If there is no
conflict in the evidence, the question whether a defendant's contacts with
California are sufficient to justify the exercise of personal jurisdiction in
this state is a question of law that we review de novo. ( Snowney, supra, at p.
1062.) If there is a conflict in the evidence underlying that determination, we
review the trial court's express or implied factual findings under the
substantial evidence standard. ( Vons, supra, 14 Cal.4th at p. 449.) Although
the parties here dispute their opponents' characterization of the facts, there
is no material conflict in the evidence itself, so our review is de novo.FN7 (
Great-West Life Assurance Co. v. Guarantee Co. of North America (1988) 205
Cal.App.3d 199, 204.)
FN7. The only notable exception is the conflicting evidence
concerning Davies's visit to California in May 2001. (See fn. 5, ante.)
3. Petitioners Purposely Availed Themselves of Forum
Benefits
*6 The Irish bank, the Isle of Man bank, and the trust
company worked closely together in connection with the leveraged investments.
The Irish bank reviewed and approved credit applications on behalf of the Isle
of Man bank, which made the loans, and the trust company served as trustee of
the trusts holding the "with profit bonds" that were purchased using the loan
proceeds. Davies, Connolly, and McGee visited California for the purpose of
meeting with suitable investors who would be willing to invest in leveraged
"with profit bonds" and whose investment funds were from legitimate sources.
Davies was managing director of the trust company at the time of his first visit
to California and was a director of the Isle of Man bank at the time of his
later visits to this state. Connolly was employed by the trust company at the
time of his visit to California and was also a director of the Isle of Man bank
at that time. McGee was managing director of the Isle of Man bank at the time of
his visit to this state. Although Connolly was not an employee of the Irish bank
at the time, he visited California at the request of the Irish bank and in
furtherance of the common interests of the three entities.
The business cards handed out by Davies and Connolly
exemplified the close relationship among the three entities for purposes of the
leveraged investments. Davies's card bore an "Anglo Irish Bank" logo yet
identified him as managing director of the trust company. Connolly's card bore
the same logo and identified him as "Head of Offshore Trust Operations" for the
Irish bank, although he was not formally employed by the Irish bank at the time.
A corporation or other business entity acts through
authorized individuals, and the activities of its employees are attributed to
the business entity for purposes of personal jurisdiction. ( Internat. Shoe,
supra, 326 U.S. at pp. 316-317, 320.) An individual's status as an employee
acting on behalf of his or her employer does not insulate the individual from
personal jurisdiction based on his or her forum contacts. ( Calder v. Jones,
supra, 465 U.S. at p. 790; Taylor-Rush v. Multitech Corp. (1990) 217 Cal.App.3d
103, 115-118 [rejected the "fiduciary shield" doctrine]; but see Mihlon v.
Superior Court (1985) 169 Cal.App.3d 703, 713-716 [dictum].) Apart from an
employment relationship, activities that are undertaken on behalf of a defendant
may be attributed to that defendant for purposes of personal jurisdiction if the
defendant purposefully directed those activities toward the forum state. (See
Burger King, supra, 471 U.S. at p. 479, fn. 22; FN8 Empire Steel Corp. v.
Superior Court (1961) 56 Cal.2d 823, 835 ( Empire Steel ).)
FN8. Burger King stated in dicta: "We have previously noted
that when commercial activities are 'carried on in behalf of' an out-of-state
party those activities may sometimes be ascribed to the party, International
Shoe Co. v. Washington, 326 U.S. 310, 320 (1945), at least where he is a
'primary participan[t]' in the enterprise and has acted purposefully in
directing those activities, Calder v. Jones, 465 U.S., at p. 790." ( Burger
King, supra, 471 U.S. at p. 479, fn. 22.)
Empire Steel held that specific personal jurisdiction over
a foreign parent corporation was established based on the parent's
"manipulation" and control of its California subsidiary to the detriment of the
subsidiary's creditors. ( Empire Steel, supra, 56 Cal.2d at p. 831.) The
plaintiff sought to recover damages caused by the subsidiary's failure to take
delivery of steel purchased from the plaintiff. ( Id. at p. 826.) Empire Steel
concluded that the evidence supported the inference that "Empire knowingly
caused its California subsidiary to make the contracts in suit while [the
subsidiary] was in fact insolvent but had the appearance of financial
responsibility." ( Id. at p. 832.) The California Supreme Court stated that the
court need not decide whether the parent was the alter ego of its subsidiary,
and that " '[t]he essential thing is merely whether the corporations are present
within the state, whether they operate through an independent contract, agent,
employee or in any other manner.' [Citations.]" FN9 ( Id. at p. 835.) Thus, a
parent corporation's purposefully causing its subsidiary to engage in forum
contacts may constitute purposeful availment by the parent even if the
separateness of the corporations is maintained and alter ego is not
established.FN10 ( Ibid.; Northern Natural Gas Co. v. Superior Court (1976) 64
Cal.App.3d 983, 994-995; Rest.2d Conflict of Laws, sec. 52, com. b, p. 180.FN11)
FN9. The exercise of personal jurisdiction formerly
depended on the defendant's "presence" within the forum state. Internat. Shoe
held that a corporation was "present" within the state if its contacts with the
state were sufficient to make the exercise of personal jurisdiction fair and
reasonable, and thus shifted the focus from "presence" to "minimum contacts." (
Internat. Shoe, supra, 326 U.S. at pp. 316-317; see Shaffer v. Heitner (1977)
433 U.S. 186, 203-204 [53 L.Ed.2d 683].)
FN10. We do not regard the use of the word "manipulation"
in Empire Steel, supra, 56 Cal.2d at page 831, as intended to strictly limit the
circumstances in which purposeful availment may be found when a parent
corporation causes its subsidiary to engage in forum contacts on its behalf.
Instead, we believe that "manipulation" of a subsidiary is only one example of a
parent corporation's purposefully directing the activities of its subsidiary in
the forum state.
FN11. The Restatement Second of Conflict of Laws, section
52, comment b, page 180 states, in relevant part: "If the subsidiary corporation
does an act, or causes effects, in the state at the direction of the parent
corporation or in the course of the parent corporation's business, the state has
judicial jurisdiction over the parent to the same extent that it would have had
such jurisdiction if the parent had itself done the act or caused the effects."
*7 In our view, reliance on state substantive law of agency
and alter ego to determine the constitutional limits of specific personal
jurisdiction is unnecessary and is an imprecise substitute for the appropriate
jurisdictional question. The proper jurisdictional question is not whether the
defendant can be liable for the acts of another person or entity under state
substantive law, but whether the defendant has purposefully directed its
activities at the forum state by causing a separate person or entity to engage
in forum contacts. That constitutional question does not turn on the specific
state law requirements of alter ego or agency, although the inquiry may be
similar in some circumstances. FN12 (See Hoffman, The Case Against Vicarious
Jurisdiction (2004) 152 U. Pa. L.Rev. 1023, 1026-1027, 1086-1090; 1097-1098;
Comment, Agency as a Means of Obtaining Jurisdiction in New York Over Foreign
Corporations: A Failed Theory (1993) 20 Brook. J. Int'l L. 169, 196-202;
Jurisdiction Over a Corporation Based on the Contracts of a Related Corporation:
Time for a Rule of Attribution (1988) 92 Dick. L.Rev. 917, 925-944; FN13 cf.
Vons, supra, 14 Cal.4th at pp. 464, 475; FN14 but see VirtualMagic Asia, Inc. v.
Fil-Cartoons, Inc. (2002) 99 Cal.App.4th 228, 244-246 [stated that principles of
alter ego and agency can establish a basis for specific personal jurisdiction
and remanded those issues for the trial court to decide]; Magnecomp Corp. v.
Athene Co., supra, 209 Cal.App.3d at pp. 535-539 [applied state law of agency in
finding specific personal jurisdiction over a foreign corporation]; Northern
Natural Gas Co. v. Superior Court, supra, 64 Cal.App.3d at pp. 992-995 [same];
Vons, supra, 14 Cal.4th at p. 459, fn. 7 [stated in dictum, "corporate veils may
be pierced and agents' activities may be considered in appropriate cases"];
Brilmayer and Paisley, Personal Jurisdiction and Substantive Legal Relations:
Corporations, Conspiracies, and Agency (1986) 74 Cal. L.Rev. 1.)
FN12. Opinions applying principles of "alter ego" and
"agency," including the "representative services" doctrine, to determine the
existence of general, rather than specific, personal jurisdiction are
distinguishable. (See, e.g., In re Automobile Antitrust Cases I and II (2005)
135 Cal.App.4th 100, 119-121; F. Hoffman-La Roche, Ltd. v. Superior Court (2005)
130 Cal.App.4th 782, 796-799; DVI, Inc. v. Superior Court, supra, 104
Cal.App.4th at pp. 1093-1094; Sonora Diamond Corp. v. Superior Court (2000) 83
Cal.App.4th 523, 537-543.)
FN13. The cited articles discuss the inexact fit between
rules of law designed to establish liability for the acts of another and an
assessment of the defendant's contacts with the forum for purposes of
establishing general or specific personal jurisdiction. The articles also
discuss the efforts of some courts applying principles of alter ego and agency
to reformulate the inquiry so to address the appropriate jurisdictional
question.
FN14. Vons, supra, 14 Cal.4th 434, rejected reliance on
tort law causation doctrines to determine whether a controversy is sufficiently
related to the defendant's forum contacts so as to justify the exercise of
specific personal jurisdiction. Vons stated, "one must question the utility of
importing a causation test from tort law to measure a matter that is
fundamentally one of relationship and fairness rather than causation." ( Id. at
p. 475.) Similarly here, we question the utility of relying on principles of
vicarious liability to measure a matter that is fundamentally one of
relationship and fairness rather than vicarious liability.
Davies, Connolly, and McGee visited California for the
purpose of engaging in economic activity with California residents. Contrary to
Petitioners' argument that they only sought to satisfy Isle of Man's "know your
customer" requirements, the purpose of satisfying those requirements was to make
the leveraged investments possible. They discussed leveraging "with profit
bonds" with the Brars and other potential investors during the visit by Davies
and Connolly in March 2000, McGee's visit a few months later, and Davies's visit
in May 2001. Through those visits, they succeeded in garnering millions of
dollars in investments from California residents.
The evidence supports the conclusion that in doing so, the
individuals acted not only on behalf of their employers, the Isle of Man bank
and the trust company, but also on behalf of the Irish bank. Connolly testified
in his deposition that he visited California to meet with potential investors at
the specific request of the Irish bank, which relied on his experience and
expertise both in evaluating the prospective clients and in answering any
questions regarding the leveraged investments. Moreover, Connolly's business
card identifying him as "Head of Offshore Trust Operations" for the Irish bank
and the need to obtain approval from the Irish bank to make the loans are
further evidence that Connolly in particular was acting on behalf of the Irish
bank as well as the other entities.
*8 Accordingly, we conclude that the Irish bank, the Isle
of Man bank, and the trust company purposefully directed their activities at
California residents by and through the individuals who visited California on
their behalf. We conclude further that Petitioners, and each of them,
purposefully derived benefit from their activities in California and
deliberately engaged in significant activities within this state, and that they
therefore purposefully availed themselves of forum benefits.FN15
FN15. Petitioners attempt to distinguish between the trust
company "individually" and the trust company "as trustee," and argue that the
trust company "as trustee" had no contacts with California. The trust company is
a single defendant and either is subject to personal jurisdiction or is not. A
defendant is subject to specific personal jurisdiction in California if the
defendant purposefully availed itself of forum benefits, the controversy is
related to or arises out of the defendant's forum contacts, and the exercise of
jurisdiction would be fair and reasonable, as we have stated. The fact that the
trust company was appointed as trustee of the investment trusts after Davies and
Connolly visited California in March 2000 is irrelevant if the trust company
purposefully directed its activities at this state, as we conclude, and if the
other two requirements for the exercise of specific personal jurisdiction are
satisfied.
4. The Dispute Is Substantially Connected to Petitioners'
California Activities
The second requirement for specific personal jurisdiction
is that there must be a substantial connection between the dispute and the
defendant's forum activities. ( Snowney, supra, 35 Cal.4th at pp. 1062, 1068.)
The plaintiffs' six counts for intentional misrepresentation, fraudulent
concealment, securities fraud, breach of fiduciary duty, negligent
misrepresentation, and an accounting all are based on alleged misrepresentations
in or omissions from statements made to them in California by Davies, Connolly,
and others in an effort to solicit business from California residents. Because
the alleged harm relates directly to Petitioners' activities in California, we
conclude that there is a substantial connection between the dispute and
Petitioners' forum activities. ( Id. at p. 1069.) "By purposefully and
successfully soliciting the business of California residents, defendants could
reasonably anticipate being subject to litigation in California in the event
their solicitations caused an injury to a California resident. (See Burger King,
supra, 471 U.S. at pp. 475-476.)" ( Ibid.)
5. The Exercise of Personal Jurisdiction Would Be Fair and
Reasonable
The third requirement for specific personal jurisdiction is
that the exercise of jurisdiction must be fair and reasonable. ( Snowney, supra,
35 Cal.4th at pp. 1062, 1070.) Petitioners argue that after creating offshore
trusts for the apparent purpose of removing assets from the jurisdiction of
California courts, the plaintiffs should not be allowed to sue foreign
defendants in California courts "just because their investment did not prove as
fruitful as they had hoped." We conclude that by investing in foreign trusts,
the plaintiffs did not waive the right to sue Petitioners in a California court
to seek redress for injuries related to or arising out of Petitioners'
California activities. Moreover, the plaintiffs do not allege only that the
investments were unsuccessful, but that Petitioners made material
misrepresentations and omissions in California in connection with the
investments.
Petitioners also argue that it would be an extreme burden
for them to have to defend this action in California. Contrary to Petitioners'
contention, the denial of the motions to quash was not based on a finding that
Davies and Connolly made false representations at the meeting, and the trial
court made no such finding. Accordingly, Petitioners have shown no error in this
regard.
DISPOSITION
*9 The petitions are denied. The order to show cause is
discharged, and the stay of trial court proceedings previously issued is lifted.
The Brars are entitled to recover their costs in these consolidated appellate
proceedings.
We Concur: KITCHING and ALDRICH, JJ.
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If you are a mom or dad with a young child and you are an avid jogger, inline skater or power walker (or want to be) and you want to be outdoors and stay fit with your baby you can still do it. More and more families are considering a baby jogging stroller. Times have changed - baby strollers used to be for gentle walks in the park. Not anymore - baby jogging strollers are here to stay - helping moms and dads stay fit and get fit. There are lots of strollers to choose from - so it is not easy to decide. Here are 10 things that will help you to decide which one is best for you.
1. Lighter the better. The stroller you choose should weigh less than 25 pounds. Strollers are made with either aluminum frames or metal tube frames. The lightest ones are those that have an aluminium frame. Not only are aluminum frames much lighter but they are also stronger and longer lasting.
2. Stroller wheels. The stroller you choose should have air-filled 16 inch wheels since they provide easy pushing for mom or dad, and they provide your baby with a comfortably smooth ride. Traditional jogging strollers have two back wheels and one front wheel. The goal with a jogging stroller is to reduce rolling resistance, and any wheels that are less than 16 inches in diameter just don`t do the trick.
3. Comfort for baby. You want your baby to be as comfortable as possible. The seat should be padded and made of a lightweight, breathable fabric. During your jog your baby may decide to take a nap. Look for a stroller that reclines by at least 25%.
4. Sun canopy. Everyone is now conscious of the destructive nature of the sun`s rays, and when out exercising you want to make sure that your son or daughter is fully protected. Each jogging stroller that you consider will have a sun canopy - but some will do a better job than others in providing protection from the sun. For maximum coverage for your baby make sure that the stroller you choose has a sun canopy that rotates 360 degrees to block the sun`s rays no matter which direction your run takes you.
5. Child safety. Safety is number 1 whenever it comes to your baby. Make sure that the stroller you choose keeps your baby safely strapped into their seat. Look for a stroller with a five-point harness. The stroller should have both a hand brake, and a parking brake (engaged by flipping a bar with your feet).
6. Folds easily. Make sure that it can be easily folded with a one step process that one person can do (there is not always a second person available to help you) for placing into a car trunk. If it compacts to no more than 45 inches long, 25 inches wide and 18 inches tall it will fit in most cars. For even more compactness make sure it has quick release wheels that pop off and on with a push of a button.
7. Adjustable handlebar. If you are 6 foot 4 inches tall and your partner is 5 foot 4 inches tall, and you are both going to be using the stroller, the handlebar on your stroller should be easily adjustable (with a simple push of a button) making it comfortable for each of you when jogging.
8. Make sure the baby will not outgrow the stroller. The stroller is not just for use for a year. You want to make sure that you maximize its use over several years. Make sure that the seating area is large enough for your child as they grow (it should be 24 or 25 inches high in the seating area) and make sure that the stroller is rated to handle your child`s weight as they get older (look for a weight rating of up to 80 pounds).
9. Buy with confidence. If you bring the stroller home and try it out and it just isn`t what you expected it to be, make sure that the retailer will provide a full refund without any arguing. And if there are problems down the road make sure that there is a good long term warranty from the manufacturer. A solid manufacturer`s warranty is 5 years on the frame and 1 year on all other parts of the stroller.
10. They range in price. Make sure it fits within your budget. You can purchase a good jogging stroller for as little as $280 and you can pay over $1,000. Sometimes you are paying for the `brand name`. Select your stroller based on your family`s needs and the features that are important to you. Remember, that it is a multi year investment in your child`s health and your family`s happiness. If you are able to afford $280 a jogging stroller can become an important part of your life.
Use this list of ten things to do to list which stroller features are most important to your family. Then use your list to help you to purchase the stroller that best meets your needs.
See more: >>> Read more...
1. Lighter the better. The stroller you choose should weigh less than 25 pounds. Strollers are made with either aluminum frames or metal tube frames. The lightest ones are those that have an aluminium frame. Not only are aluminum frames much lighter but they are also stronger and longer lasting.
2. Stroller wheels. The stroller you choose should have air-filled 16 inch wheels since they provide easy pushing for mom or dad, and they provide your baby with a comfortably smooth ride. Traditional jogging strollers have two back wheels and one front wheel. The goal with a jogging stroller is to reduce rolling resistance, and any wheels that are less than 16 inches in diameter just don`t do the trick.
3. Comfort for baby. You want your baby to be as comfortable as possible. The seat should be padded and made of a lightweight, breathable fabric. During your jog your baby may decide to take a nap. Look for a stroller that reclines by at least 25%.
4. Sun canopy. Everyone is now conscious of the destructive nature of the sun`s rays, and when out exercising you want to make sure that your son or daughter is fully protected. Each jogging stroller that you consider will have a sun canopy - but some will do a better job than others in providing protection from the sun. For maximum coverage for your baby make sure that the stroller you choose has a sun canopy that rotates 360 degrees to block the sun`s rays no matter which direction your run takes you.
5. Child safety. Safety is number 1 whenever it comes to your baby. Make sure that the stroller you choose keeps your baby safely strapped into their seat. Look for a stroller with a five-point harness. The stroller should have both a hand brake, and a parking brake (engaged by flipping a bar with your feet).
6. Folds easily. Make sure that it can be easily folded with a one step process that one person can do (there is not always a second person available to help you) for placing into a car trunk. If it compacts to no more than 45 inches long, 25 inches wide and 18 inches tall it will fit in most cars. For even more compactness make sure it has quick release wheels that pop off and on with a push of a button.
7. Adjustable handlebar. If you are 6 foot 4 inches tall and your partner is 5 foot 4 inches tall, and you are both going to be using the stroller, the handlebar on your stroller should be easily adjustable (with a simple push of a button) making it comfortable for each of you when jogging.
8. Make sure the baby will not outgrow the stroller. The stroller is not just for use for a year. You want to make sure that you maximize its use over several years. Make sure that the seating area is large enough for your child as they grow (it should be 24 or 25 inches high in the seating area) and make sure that the stroller is rated to handle your child`s weight as they get older (look for a weight rating of up to 80 pounds).
9. Buy with confidence. If you bring the stroller home and try it out and it just isn`t what you expected it to be, make sure that the retailer will provide a full refund without any arguing. And if there are problems down the road make sure that there is a good long term warranty from the manufacturer. A solid manufacturer`s warranty is 5 years on the frame and 1 year on all other parts of the stroller.
10. They range in price. Make sure it fits within your budget. You can purchase a good jogging stroller for as little as $280 and you can pay over $1,000. Sometimes you are paying for the `brand name`. Select your stroller based on your family`s needs and the features that are important to you. Remember, that it is a multi year investment in your child`s health and your family`s happiness. If you are able to afford $280 a jogging stroller can become an important part of your life.
Use this list of ten things to do to list which stroller features are most important to your family. Then use your list to help you to purchase the stroller that best meets your needs.
See more: >>> Read more...
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Founded in by Alec Willis, Tom O'Brien and Gary Cassinelli, Defacto Solutions work closely with Sage to provide bespoke programming services, resources and solutions for the Sage product line, harnessing the potential of emerging Cheap celecoxib while designing and creating robust and useable solutions. And the inclusion of a sample company allows users to become familiar with the. Choose the billing method to use, and enter job beginning balances. Yh a hover font weight bold.
Americano new top 10 >>> asset protection group
Founded in by Alec Willis, Tom O'Brien and Gary Cassinelli, Defacto Solutions work closely with Sage to provide bespoke programming services, resources and solutions for the Sage product line, harnessing the potential of emerging Cheap celecoxib while designing and creating robust and useable solutions. And the inclusion of a sample company allows users to become familiar with the. Choose the billing method to use, and enter job beginning balances. Yh a hover font weight bold.
Americano new top 10 >>> asset protection group
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Asset protection is a set of legal techniques by which one can protect his or her assets and belongings against lawsuits.
The rationale of asset protection is to set aside and shield your liabilities from precious assets to the greatest extent allowed by law, so as to diminish your debtor's profile and amenability to a lawsuit. It also includes conducting a legal asset freeze by shifting precious assets to other family members, at a time when you have no existing or expected claims in the near future.
Thus, if you are relatively debt free today, then the asset protection planning will advice you to shift your valuable assets such as house property in the name of your family members. Asset protection planning is also, to a certain extent, pre-litigation and pre-bankruptcy planning that seeks to maximize the use of exemptions permissible by the state and federal authorities.
Asset protection planning is not meant to cheat rightful creditors, ex-spouses, business partners, and investors.
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