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Ed. note: This post was co-authored with David Frakt, an attorney and the chair of Law School Transparency’s National Advisory Council. This was originally published on Above the Law.
The United States Department of Education (ED) notified Charlotte School of Law on December 19, 2016, that its students would no longer be eligible for federal student loans. The decision, as with the American Bar Association’s decision to put CSL on probation a month earlier, surprised and alarmed CSL students. Since that time, students have reached out to law schools across the country to inquire about attending in the immediate or near future. With no other law schools in Charlotte, North Carolina, there are practical limitations on the choices CSL students face.
Several students report to us that, despite CSL’s assurances, information has been both limited and not particularly useful as they try to assess their options. Furthermore, these students report that administrators have been unavailable to answer questions. The school appears to have completely shut down for winter break from December 22 through January 3 despite the urgency of the situation that has developed in Charlotte. These administrators have likewise not been available to the press since the Education Department’s announcement in December.
It is not yet clear that the school will resume classes on January 9, as scheduled. And even if the school does resume operations next week, students still have an understandable desire to explore available options.
In theory, students have four options.
At this point, CSL students cannot make informed decisions because CSL has not been sufficiently transparent. As such, Law School Transparency has sent CSL a letter with an urgent request for information that will help CSL students make the choice that is best for their personal career ambitions.
Infilaw, which owns Charlotte School of Law and Florida Coastal School of Law, must be transparent about any pending or reasonably foreseeable ABA sanctions at Florida Coastal. As CSL develops its plan for CSL students to transfer to Coastal, they must ensure that CSL students are fully informed about Coastal’s compliance with ABA standards. Students need and deserve to know about the potential for similar problems to emerge at Coastal.
In November, the ABA placed CSL on probation because of its exploitative admissions and retention policies. Coastal’s admissions statistics are not meaningfully different than CSL’s. The majority of students at both schools face extreme risk of failing the bar exam. These two schools also have the highest attrition rates in the country. It’s possible that the ABA has already warned Coastal that it is out of compliance with the ABA standards, much in the way that the ABA warned CSL in February 2016. Indeed, Coastal’s dean announced the school’s intent to raise admissions standards this past fall. Infilaw should disclose any communications from the ABA that in any way indicate potential sanctions against Coastal, including fact-finding inquiries that the ABA will use to evaluate whether the school has sound admissions and retention policies and practices.
Infilaw should be transparent about communication with the U.S. Department of Education regarding Florida Coastal School of Law’s continued participation in the federal student loan program. The ED cited two independent reasons to deny CSL’s participation in the federal student loan program. First, the ED cited CSL’s non-compliance with the ABA standards. Second, the ED cited CSL’s “substantial misrepresentations regarding the nature of its academic program.” The ED based this finding, in part, on CSL’s failure to disclose until November 2016 that the ABA found the school non-compliant with the ABA standards in February 2016. If Coastal has received notice from the ABA about non-compliance, it has not disclosed it to date. That could provide a basis for the ED to take similar action against Coastal.
Coastal might be a reasonable alternative for some CSL students, but it is not fair or ethical or consistent with the school’s fiduciary duty to withhold this information from CSL students considering a transfer (or, for that matter, current Coastal students).
Infilaw should be transparent about its plans to facilitate transfers within the Infilaw System, including moving expense reimbursement, alternative class schedules, tuition discounts, and whatever else students need to ease the transfer after Infilaw and CSL withheld critical information for nine months. Even assuming that Coastal does not face any immediate issues from regulators, Infilaw and CSL should recognize that simply offering students the opportunity to attend another law school in the Infilaw system is not enough to discharge its legal and ethical obligations to students. This is especially true given Infilaw’s financial interest in moving students to one of its schools that has access to federal student loan dollars from one that does not.
Students who choose to relocate 400 miles from Charlotte to Jacksonville will incur substantial costs, including transportation costs, moving expenses, and early lease termination fees. Students who seek to join the bar can ill afford to have negative credit reports or collection actions taken against them for breaching a lease. It is essential that administrators promptly develop and communicate a fair, simple, and transparent approach for students to file for reimbursement.
Charlotte School of Law should clarify whether it will permit and facilitate students who seek to visit another law school this semester. At least a handful of current CSL students have inquired with other law schools about visiting this coming semester. As one law school in North Carolina told us, the obstacles to a visit are not with their school — they are prepared to promptly review and act upon any applications for a visit. Rather, the question is whether CSL will approve the visit, accept the credits towards CSL degree requirements, and waive degree requirements that cannot be met at the visiting school, such as the course on North Carolina distinctions.
The school has sent mixed messages to students about the possibility of visiting at another school. CSL should publish clear guidance on visits as soon as possible, and should do everything possible to facilitate visits for students who request them. We asked Traci Fleury, assistant dean of academic services, for clarification. She did not respond to our phone call.
Charlotte School of Law should devote more resources to student service and administrative offices. Completed applications, whether for a visit or a transfer, typically require a letter of good standing, an official transcript, and, for visits, a letter promising to accept credits from the visiting school. Students report to us that they are still waiting on one or more of these items from CSL. Dean Fleury indicated in an email to a student that a team of five people is working through transfer packets for students. But time is of the essence, and Infilaw schools have been accused of purposefully impeding transfers in the past. Thus the school needs to devote even more resources so that inattentiveness does not prevent students from making informed choices about their futures.
Charlotte School of Law should clarify why it indicated that the school will submit a “teach-out” plan to the ABA in March. A teach-out plan helps students find a reasonable opportunity to complete their program of study. The ABA accreditation rules require a teach-out plan for any school that loses access to the federal student loan program. However, Rule 34 also requires a teach-out if the school intends to cease operations. CSL has already informed students who had been planning to start this month that the “spring start” for which they had been admitted has been canceled. With deadlines for transfer and visits looming, and nearby schools preparing to begin classes as early as tomorrow, CSL should clarify whether the school plans to cease operations in the near future, or if it is even considering such a step, as this will obviously have an impact on the decisions that students make.
While we understand that the situation is fluid, and that the school’s plans may be contingent on a variety of factors that are outside of its control (such as regaining federal funding), CSL must not let uncertainty prevent timely release of information. If in doubt, CSL should err on the side of full disclosure and immediately release any information that could conceivably affect its students’ decisions.
This piece was originally published on Above the Law.
Welcome to Caveat Venditor, a new series that assesses claims made by law schools to separate truth from fiction. This week, we look at a threatening letter sent to a documentary film maker by Tom Clare, a lawyer for The Infilaw System.
InfiLaw owns three law schools — Arizona Summit, Charlotte School of Law, and Florida Coastal — and several legal education-related management companies. These are three of six total for-profit law schools approved by the ABA, although two of the other three are transitioning to non-profit status. InfiLaw also tried and failed to purchase Charleston School of Law after faculty, alumni, students, and the local legal community revolted.
Hat tip to Paul Campos for the full text of the letter:
I write on behalf of my client, The InfiLaw System (“InfiLaw”), regarding your inquiry into interviews with Florida Coastal School of Law officials for a documentary you are making. I write to caution you as you proceed with fact-finding and information gathering associated with your planned documentary.
Prior reporting on the issues you plan to address, including law school attrition rates and student success, has been plagued by gross misinformation, factual errors, and a general misuse and distortion of available data and analysis. This is especially true as they have been applied to InfiLaw schools such as Florida Coastal. Individuals, such as Paul Campos, have distorted facts and data and engaged in nefarious and inappropriate investigative tactics in order to accomplish a false agenda attacking law school admissions and career advancement policies. As such, I caution you to carefully assess any information and facts you gather from Mr. Campos and any other purported “authorities” on law school success metrics and the risks and rewards of attending law school in this day and age. InfiLaw and its affiliated schools will carefully analyze and assess any statements made about them and will not be afraid to pursue legal recourse to protect its reputation against any false and reckless statements.
In addition, InfiLaw requests that you notify me immediately upon any decisions to include any references to or subject matter about InfiLaw or any of its affiliate schools in your documentary, and provide InfiLaw the opportunity to review and comment on them prior to any public dissemination.
Have something you think our audience would like to hear about? Interested in writing one or more guest posts? Send an email to the cafe manager at firstname.lastname@example.org. We are interested in publishing posts from practitioners, students, faculty, and industry professionals.


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Land Flipping Investor Blueprint is Casual Fridays REI program for, guess what, land flipping. In case you’re wondering, this is quite similar to your usual flipping. But instead of houses, it’s land that you’re trying to buy and sell at a profit. Now you know what’s land flipping, the promise here is somewhat ambitious, yet so simple: Turn you from zero to real estate investor in less than three months. Read on for the rest of the Land Flipping Investor review.
What’s more, you can do this all without any prior experience. As in zero. Their words, Adam Southey and Justin Sliva, not mine. Now, who are these guys, you might ask. Well, they’re the duo behind Casual Fridays REI. Catch ‘em as hosts on Casual Fridays REI’s podcast or as mentors if you eventually sign up for Land Flipping Investor Blueprint. Regarding signing up, should you?
Before I answer that, I think it’s worth noting their thoughts about traditional house investments. I mean, that’s one of their main talking points to sell land flipping as a business model, anyway. So, yeah, to them, traditional house investments are just a waste of time. How so?
Issa waste because it’s not as rewarding as you’d hope for something that requires a lotta time, money, and work. Finding and buying the perfect house is already draining, yet you still have to either deal with contractors and tenants for the rehab, or do all the work yourself. All the hard work for, what, a few thousands in profit, probably.
And you know what, the land industry is so much better in this regard, says them (of course, they would). In contrast to the time-consuming traditional house investments, you’ll be able to run the entire business from a laptop in just a few hours a week. No contractors, no tenants, no rehabs, no headaches. Best of all, the low competition here means you can easily find good deals within your budget.
With that said, Land Flipping Investor Blueprint is essentially your step-by-step guide to become successful in the land industry as a smart and savvy land flipping investor. Seven steps of becoming one where they’ll guide you from start to end. The said seven steps are as follows: Business incorporation, picking and pricing a county, finding and reaching the owners, due diligence, buying/closing on the property, marketing, and selling the property.
Specifically, signing up for this means lifetime access to forty video tutorials, list of handpicked vendors, and a private Facebook group. No mention of live coaching nor one-on-one calls, so I assume there’s none. Without it, how would they price the Land Flipping Investor Blueprint, then? Thought it’d be on the affordable side, but nope… Land Flipping Investor Blueprint would still cost you $2,000 regardless.
Now, here’s the deal. This might come as a surprise, but they’re actually completely honest with the advantages of land flipping. No cap when they imply that land flipping has low competition and low capital requirement (relative to traditional house investments). However, they’re all about flexing the benefits, the sh*t you’ll reap when all things went according to plan. How about the opposite, what if things go wrong?
This is where they go high with copium. They’re like, what’s the matter if you can’t flip the land, you still have a valuable piece of property (bought way under value, they say) that’ll only appreciate over the years. I should say, the talk on value is all moot when no one bothers to give you THAT value. You can hold, sure, but until when? Are you sure that land appreciation will beat inflation in the long run? I doubt it. And remember, the bills to pay don’t stop during the waiting.
In short, land flipping is not all flawless in reality. In fact, it even has NFT vibes written all over it. Obviously, NFT space is much worse, but both are full of frauds illegally inflating the value of their stuff (land for land flipping, digital receipts for NFTs) through market manipulation. Not everything is illegal, don’t get me wrong, but it’s the usual. It’s the norm.
Be scammed or be the scammer yourself, what’s your choice? Here’s to hoping that you pick none. Because you can (pick none) and you should, there’s no need to settle for less. In conclusion, I’m not down with land flipping as a business model, and in turn, I don’t recommend signing up for the Land Flipping Investor Blueprint.

domain: economics


text:
In any size or colour, sunflowers attract bees and other beneficial insects and produce nutritious seeds enjoyed by people and their feathered friends. Read on for six ways to make the most of the sunflowers in your garden.
Size and variety
If you think all sunflowers are 2-plus metre giants, think again!
- There are dozens of varieties to choose from, including branching bushes and dwarfs small enough to grow in containers.
- Most sunflowers are yellow, but there are also deep reds, creamy whites, and lovely mahoganies.
1. Start with seeds
Sunflowers are among the easiest annuals to sow from seed.
- Plant seeds in late spring after the soil has warmed.
- In midsummer, sow another packet for a beautiful fall show.
2. Don’t skimp on sun
If they run short of light, sunflowers will twist so their flowers face the sun.
- Use this trait to your advantage by choosing a site easily viewed from its south or west side, because sunflowers usually face those directions.
3. Plant a sunflower hedge
Branching sunflowers such as ‘Italian White’ produce dozens of blossoms on big, bushy plants.
- When grown 60 centimetresapart, they make a tall, dense hedge for the rear of a sunny flowerbed, and the blooms make great cut flowers, too.
4. Sunflowers as trellises
Grow sunflowers as living trellises for pole beans.
- Use a tall, single-stemmed variety and let it grow at least 30 centimetres tall before planting pole bean seeds at its base.
5. Keep the birds away
Keep summer birds from eating seeds you want to save for winter.
- After the petals shrivel, slip a cut piece of old pantyhose over the ripening seed head.
- Allow at least three weeks of ripening time before gathering and storing your homegrown birdseed.
6. Reuse flower parts later
Save the stalks for next year.
- After sunflowers finish blooming, lop off the stalks near the soil line, trim off any branches, and store your “sunflower poles” in a dry place until spring.
- Use them to make a natural-looking teepee trellis for scarlet runner beans or morning glories.

domain: agronomy


text:
By the late 1980s, two decades after the riots tore through Washington, D.C., the condition of the city was bleak. Crime, fueled by the crack epidemic, had skyrocketed. People referred to Washington as the “murder capital.” The city’s economic base had not recovered from the loss of so many businesses that had been destroyed or otherwise left the city. On many main streets, block after block still lay in ruins. It was a sad and depressing sight.
The Jewish community in Washington was a shell of its former self. Most of it was gone to the suburbs. There were a couple of lonely outposts trying to weather the storm, such as Tifereth Israel Congregation in Upper Northwest and Kesher Israel in Georgetown. But for the most part, the Jewish community had withered away.
And then, quite unexpectedly, things began to change. Little by little, the city began to pick itself up and move forward. And the Jewish community moved forward as well; a rebirth took place, giving us a city and a Jewish community that would have been unthinkable 30 years ago.
The first thing that began the change was the opening of the Washington Convention Center in the early 1980s. It would house many different events, but more importantly, it gave people reason to go downtown. Then, in the late 1990s, three events occurred that really got things moving. The first was the completion of the subway system. Now there would be access to all areas of the city, and people could move into any area and have public transportation readily available. And people began to move back into the city, Jews among them.
That led to the second great event: the re-opening of the DC Jewish Community Center, a rebirth in its exact former location. Now there was a cultural Jewish center right in the heart of the city.
The third great event was triggered by a man who was one of the greatest figures not only in the city’s history, but in the Jewish community as well: Abe Pollin. A native Washingtonian, Pollin was for many years one of the city’s leading developers. It was his other great passion, however, that led to the renewal of the city he loved.
Pollin was the owner of two of the city’s sports franchises, the Washington Bullets basketball team and the Washington Capitals hockey team. They had been playing in the Capital Centre, which he had built in Landover, Maryland. Most sports franchises had left the cities in that era and were playing in the suburbs. Pollin saw the trends and felt that a downtown arena, and the growth that could come with it, was the future for the city he loved. He turned down offers from Baltimore and other places to move his teams and have someone else pay for a new arena.
In 1998, he moved into the new arena he built and paid for. The area had been a wasteland. By 5 p.m., when the government closed down, all the life disappeared. The opening of the arena changed everything. Developers saw the potential and new construction exploded. And more importantly, it spread to the areas that were decimated in the riots. Whole areas were rebuilt into thriving neighborhoods. The city’s population began to grow as people returned, and the Jewish community grew as well in all aspects.
By the early 2000s, two events occurred that really showed the completeness of the transformation, as two landmarks of Washington Jewish history were returned to the community. The Jewish Primary Day School bought the old building of the Hebrew Academy and returned it to use as a Jewish school, and the old Adas Israel, which had long been a church and was in danger of being used as nightclub or being demolished, was purchased by Abe Pollin, Douglas Jemal, and Shelton Zuckerman, all major pillars of the Jewish community, and was born again as the Sixth & I historic synagogue.
To quote an old Yiddish expression, dos reydeleh dreit zich, the wheel turns. The past 50 years have seen great changes and surely, there are more to come.
Fifty years later, we have taken a look back and told the story. I hope you have enjoyed it.
NEXT TIME: ALL CAPS
By Larry Shor

domain: sociology


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Topic by Topic
Grupo Clarín. Independent from the government, not from you.• Independent from the Government
• Independent from Companies
• Independent from Business Interests
• Demanding Audiences, Contents of Excellence
• Unfounded Claims
• Blockade of Printing Facilities
• Public Denunciations and Intimidations
• Street Banners and Pasquinades
• Intimidating Operations
• Penalties and Direct Measures
Audiovisual Communication Services Law• A Law Suited to the National Government
• What We Should Know
• Preserving Freedom of Speech
• Main Risks and Dangers
Papel Prensa• The Company
• The Background: Step by step
• Non-compliance by the National Government
• The Escalation to Control Newsprint
• What We Should Know
Cablevisión - Fibertel• Attack against Fibertel
• An Attack that Affected Users
• Refutation of the Arguments against Fibertel
• Attempt to Revoke Fibertel's and Cablevisión's Licenses
No. There is legitimate competition in all media market segments. There are no regulatory barriers preventing new players from entry and no anti-competitive concentration practices have been proven either.
In fact, Argentina has the broadest media offering in Latin America and one of the most diverse at an international level:
- In the printed media segment, there are 17 national paid newspapers featuring general information. Clarín is one of them.
- In the broadcast TV segment, there are 6 signals in the AMBA region (comprised by the City of Buenos Aires and its surrounding areas). Grupo Clarín is the licensee of Canal 13. It owns 4 out of 44 broadcast signals at a national level.
- Currently, the only Digital TV platform is the state-owned TDA. The presence of pro-government voices is overwhelming in more than its 30 signals. Several businessmen close to the government managed to introduce their signals there, without undergoing any prior competitive bidding process.
- There are 550 radio stations in the AMBA region and 5,000 nationwide (these are legal radio stations, but they total over 12,000 if we add the illegal ones). Grupo Clarín has two licenses in the AMBA region and 8 licenses at the national level.
- There are five national signals in the news signal segment. Grupo Clarín owns TN.
- Options abound in the Internet segment. Everybody is allowed to distribute content. Clarín.com ranks No 10 in Argentina’s most visited site ranking, which is headed by global sites.
- There are more than 700 operators in the Paid Television segment, with Cablevisión being the major player with a 47% market share. Cablevisión competes with other options, both in cable and satellite services. Its market share is similar to or lower than the main cable operators' in several countries: France (65 %), Spain (57 %), Germany (52 %), United Kingdom (59 %), Chile (67 %), Peru (82 %), Venezuela (50 %), Brazil (46 %), Colombia (46 %) and Mexico (46 %).
Broadcasting regulations included very specific guidelines similar to those effective in the developed countries (4 licenses within each geographical area, or 24 at a national level). The Antitrust Law also provides control mechanisms over mergers and anti-competitive practices. Grupo Clarín has always abided by the law; unlike other competitors that owned more radio stations than allowed in the same area and even managed to have two broadcast TV signals in the City of Buenos Aires, or otherwise accumulated licenses at a national level surpassing the permitted threshold. In these cases there was no political intent to have these controls enforced. All of this does not eliminate the need for a profound and serious discussion on the broadcasting law reform, in the light of the changes media and technologies have undergone, as well as the international regulatory trends, the reality and the size of the local market.
Even though the alleged intent was to increase the number of providers, the actual one was to eliminate some of them. In fact, enacting these new rules was not required to enlarge the media offering. This could have been achieved by conducting competitive bids for TV signals in the provinces (only 7 cities in the country have more than one broadcast TV signal) or radio stations (in spite of the fact that the spectrum is almost saturated). In fact, these new rules were neither required for Cable TV (which licenses do not use the spectrum and are not limited) nor for opening the door to NGOs (which had been authorized to be licensees since 2005). But they were indeed required to achieve the actual goal, i.e., dismantling certain media outlets, such as Grupo Clarín’s. The new law does not enable more options than the former one, but leads several current media outlets to be out of the law.
Not at all. In 2005, Néstor Kirchner issued a decree suspending the calculation of broadcasting license terms for 10 years, in reply to a request from the then holder of Canal 9 license in the City of Buenos Aires, who was undergoing reorganization proceedings. América 2 was also interested in the extension as it was going through a similar situation. It is worth mentioning that, pursuant to Law 22,285, undergoing reorganization proceedings was grounds for having the license revoked.
Because it revives the spirit of the original law passed in 1980, which prohibited the printing media to hold radio and TV licenses, basically because the military government sought to control the information reported by media outlets (Clarín being one of them).
Now, the law passed by the Kirchner administration does not allow to hold broadcast and cable television licenses in the same area (something unprecedented worldwide) or almost absurdly restricts broadcast channels and cable television systems from producing signals. It seeks to go against the current multimedia concept worldwide, which increasingly nourishes from the interaction between content production and distribution. The major global producers are affiliated to cable systems and broadcast channels.
Joint ownership of broadcast TV and cable systems is a worldwide trend: Fox and DirecTV (USA), Globo and Net (Brazil), Televisa and Cablevision (Mexico), Sky and Channel Four (United Kingdom), Cuatro and Sogecable (Spain).
A recent example of this trend is Comcast’s (the main cable television system in the US, with 23.9 M subscribers) acquisition of a majority interest in NBC Universal, holder of one of the four major American broadcast television networks.
No. In fact, it affects them to a larger extent than the law in place during the de facto government. Now, pursuant to Section 48, the possibility of granting a broadcasting license to a printing media outlet will be considered by the Enforcement Authority which may, at its sole discretion (as there are no objective guidelines, but general provisions) decide whether to authorize it or not.
Yes, it is a two-way road. On the one hand, broadcast TV licensees are only allowed to have a single broadcasting signal. Artear, for instance, could only have Canal 13 Satelital, or TN, or Magazine, or Metro, or Volver, or Quiero. For a broadcast channel, the possibility of reaching other parts of the country through the cable TV system is a natural synergy, so they are likely to choose this alternative. If this was the case, the other signals would infringe the law.
This first restriction would apply if, when having to choose between Canal 13 or Cablevisión (in Buenos Aires), the Company was to opt for Canal 13 license.
However, the outcome would not be any better if the company was to keep Cablevisión license. According to the law, “the providers of cable television services (for instance, Cablevisión, Supercanal or Telecentro) may not registered owners of signals, other than the signal generated on their own”. In other words, these operators may only have their “own channel” in each market where they hold a license. This channel is, in turn, subject to specific requirements in terms of local content and, therefore, deviates from the "national signal" idea on which TN has been conceived.
Ese canal tiene exigencias específicas de contenidos locales, con lo cual se aleja del concepto de “señal nacional”, tal como está concebida TN.
No. For instance, the cable TV market and the broadcast TV market do not compete against each other. For this reason, the restriction on simultaneous licenses does not exist worldwide. It does not make sense from the point of view of competition, diversity and economic dimension. Broadcast channels are content producers par excellence. On the contrary, cable systems are distributors of content from different sources. At the most, other countries impose a limit to the broadcasting of a cable TV operator's own signals (in the US, for instance, that limit is 40% of the programming grid). However, only one is allowed here: The “local channel”.
Broadcast channels are also subject to a maximum limit on signal production, which is also unprecedented.
In the US, most signals are produced by broadcast channels (ABC, CBS, FOX, NBC) and cable TV operators (Time Warner, DirecTV). ABC produces ABC News, History Channel, A&E, ESPN or Disney Channel; CBS produces CBS News or The Movie Channel; NBC produces MSNBC, Bravo, USA Network or Discovery; and FOX produces Fox News, Fox Sports, Fox Movies or National Geographic, among many others. Time Warner produces HBO, Cinemax, CNN, Cartoon Network, TNT and several others.
Paradoxically, large foreign groups, such as, Time Warner or FOX, will have 43 or 26 channels in the programming grid of an Argentine cable TV operator; while Argentine groups will only be allowed to have one.
Both issues have serious technological, regulatory and strategic defects. The cable television system does not use the radio electric spectrum; therefore, it should not be subject to public licenses, let alone with a limited term. The limit of 24 licenses is even more arbitrary, and is worsened by the fact that the government has discretion over the geographical scope. It would be the same as if telephone companies, mobile phone companies or DirectTV were only allowed to render services in 24 locations.
In addition to plainly contradicting the recent approval of Cablevisión-Multicanal merger, the limit of 35% of subscribers nationwide is discriminatory in the light of the fact that telephone companies may reach the 100% of the households. It has been proven that in locations where two networks coexist (telephone and cable) costs are lower and broadband speeds are higher. By imposing a limit on cable operators, the same limit is also being imposed on potential cable modem subscribers and, therefore, telephone companies, which nowadays handle more than 70% of Internet access, are being granted a privilege and increased concentration power.
Internationally, limits to cable TV subscribers barely exist. In the US, there used to be a 30% threshold that was imposed due to the large size of the country, where operators have more than 20 million subscribers. However, the Federal Court of Appeals has recently rendered judgment in re Comcast annulling the limit on the basis of technology and market grounds, upholding that "the new forms of competition are making cable television lose ground”.
No, it does not make sense from a production standpoint or from the standpoint of true diversity.
First of all, it has been proven that countries with strong private networks or chains are major content producers and exporters. The current high costs of producing quality fiction and entertainment programs can only be amortized by the size of a chain. It can be easily noticed just by looking at the television and radio networks in the US, Brazil, Mexico or Spain.
The 35% limit on the potential national audience the new law imposes on licensees, coupled with the prohibition of broadcasting more than 30% of the content simultaneously with other stations, are like "squeezers" that condemn private networks to death. This is not the case for state-owned stations which may have as many broadcast TV stations as they want, without being liable to add any local content. In arguing that the US also has a national audience limit (39%), the fact that this percentage, imposed in the largest economy worldwide, secures nationwide coverage is being ignored. In Argentina, the 35% limit only involves the Buenos Aires market.
From the point of view of true informative diversity, the prohibition of private networks or chains endangers pluralism, since it only provides national relevance and outreach to public voices, while private voices are economically and geographically fragmented.
The prohibition does not foster local production either. Currently, the channels in the provinces need to combine national and in-house programming, because the advertising markets are not enough to sustain a fully local programming, in addition to the fact that that “mix” is primarily required by the audience. National radio stations exist in perfect harmony with the local ones: These are supplementary rather than exclusive services, like national and regional newspapers.
The COMFER’s arguments are unfounded since the agency lacks jurisdiction. Mergers are considered and authorized by the ad-hoc agency, in this case, the National Antitrust Commission (CNDC, for its Spanish acronym), which has the technical and human resources in place to assess the scope and effects of a merger on the market, the consumer and the overall economic interest.
The COMFER may only verify compliance with the broadcasting law. The agency seeks to interfere in the merger, arguing that the company has more licenses than allowed. This is false since, in the last quarter of 2008, Cablevisión, without prior requirement, relinquished all licenses in excess of 1 (one) per location, as required by the law. In addition, as the height of arbitrariness, the COMFER has even considered that the license includes the physical assets used in exploiting it. It would be the same as if, upon the expiration of a radio or TV license, the National Government sought to keep the chattel and the buildings bought by the company: A plain and simple expropriation.
The audit the CNDC is conducting is another administrative abuse since it clearly surpasses the stated purpose of verifying compliance with the commitments undertaken in the merger. Anyhow, the Company has over-complied with all of them.
Cablevisión’s acquisition was a genuine U$S 1.1 billion investment of Grupo Clarín as a result of which the company became national again. The merger with Multicanal was executed in strict compliance with all legal formalities, after a 14-month analysis by the National Antitrust Commission and the favorable vote of its three members (the President, José Sbatella, voted for and not against the merger, as it was disclosed).
The merger involves market shares that are smaller than those recently approved in the country (Bimbo-Fargo, Quilmes-Brahma, Movicom-Unifón). It is also smaller than or similar to the main paid TV systems of countries such as France (65%), Italy (75%), Spain (57%), Germany (52%), United Kingdom (50%), Chile (67%), Peru (82%), Venezuela (50%), Brazil (46%), Colombia (46%) and Mexico (46%). Another key point is that Cablevisión, unlike other companies (such as fixed telephone companies), competes against other paid TV companies in all cities where it operates.
If we compare it to other mergers, it can be noticed that we were imposed more stringent requirements than in markets subject to technological limits, such as the mobile phone market. We had to undertake to make heavy investments in US dollars, which we have already surpassed; to sell our programming without discrimination to other cable operators, and to include other content providers in our grid.
In assessing the rationality of the transaction, the need for these mergers to compete against the major global telecommunication operators in the face of the technology convergence was also considered. It should be noted that in Argentina only, Telefónica’s and Telecom’s turnover is 7 times higher than the turnover of Cablevisión and Multicanal. And, worldwide, Telefónica is 66 times larger than Grupo Clarín.
In summary, there were conditions in place to avoid any kind of abuse whatsoever. These measures prove that what the new Broadcasting Law dogmatically proclaims can be achieved in a much more rational and sustainable way. In other words, the National Government knows how to act strategically without granting privileges when it wants to.
In the world, the soccer broadcasting market has many variants. Either the teams negotiate their rights on an individual basis or the associations negotiate them jointly. In Argentina, if teams were to negotiate rights, there would be - at the most - 4 teams that could enter into interesting contracts, and then there would be a large number of clubs with no access at all. This is why the local practice is joint negotiation.
Concerning revenues and broadcasting modalities, pay per view is the increasingly global trend. In other words, soccer matches are paid by those who will actually watch them and not by the rest of the audience. Broadcast TV barely has a residual spot, since costs can not be even covered in advertising markets that are much stronger than the Argentine market.
The local broadcast TV advertising pie does not reach ARS 1.2 billion. Therefore, it can not cover the 800 million required by the so-called “Fútbol para Todos” (Soccer for Everybody) in terms of broadcasting rights and production. As it was pointed out at the time, a free universal model could only be covered with public deficit. And this is what it is actually happening: So far, the government has spent almost ARS 240 million, out of which private advertisers have only contributed ARS 3 million.
The former model was not abusive: It was the only one that could be afforded in the Argentine market. By way of illustration, last year, Canal 7 used to pay 6 million per year for a single match. If that price was fair, today it should pay 60 million per year for the 10 matches of each fixture. However, the government and the AFA executed an agreement for a consideration of 600 million: a 1000% higher.
The threatened actions against Papel Prensa are legally groundless.
The company was not a concession made by the government to the partner newspapers, least by the military government. As it happened with other industrial projects of the time, the Government’s equity interest was stated in the original Articles of Incorporation, and dates back to 1972. The first private partner was Roberto Civita (from Editorial Abril); who then sold its equity interest to the banker David Graiver for USD 4 million (at the request of José Ber Gelbard, a minister of Perón’s administration). Then, Graiver's widow sold it to Clarín, La Nación and La Razón (which by the time belonged to the Peralta Ramos family) for a USD8 million consideration. This happened in 1976. Only in March 1977 would the military government start an investigation on Graiver’s heirs for alleged financial connections with the guerrilla organization Montoneros. At the time of the purchase, the paper mill was just a hope: Only the foundations of the civil works were laid. Newspapers made the company real and made it work only 2 year later in 1978.
Private partners have invested over USD 200 million in Papel Prensa. The paper mill has operated efficiently since its start-up. Since imported paper is duty free, the company faced competitiveness challenges in several times (such as, in the 90’s or at present) and had to be supported by its private partners, particularly, Clarín, which bought most of its production, in spite of the fact that it could have imported the input at a lower price. In some specific periods (some years in the 80’s or after the 2002 crisis), the price of Papel Prensa’s input was more competitive, though it did not become a differential factor in the long run. Grupo Clarín’s current equity interest in Papel Prensa (49%, Clarín and Cimeco combined) is similar to the output portion used by our newspapers. Therefore, the company’s eventual earnings as shareholder are offset by its expenditure as client.
Papel Prensa supplies 95% of the Argentine newspapers in different percentages. It applies the pricing, discount and payment term policies that are customary in the international paper market. The terms of sales to Clarín and La Nación are approved by Papel Prensa’s Board of Directors, with the abstention of both newspapers.
Clarín purchases imported newsprint at a cheaper price than that produced by Papel Prensa: It has just bought it at USD415 per ton, almost USD100 less expensive than what it pays for it to Papel Prensa.
Papel Prensa's directors from the government have been expressly approving its prices, as well as its quarterly financial statements since the start-up.
According to the contract executed in 1972, the government should have withdrawn from the company more than 15 years ago.
The harassing campaign against Grupo Clarín is unprecedented in the country's contemporary history and involves multiples actions from the formal and informal sectors of the political power.
- Street banner campaigns against our media, shareholders, directors and journalists.
- Telephone threats, e-mail tapping, espionage and personal persecution.
- Public denunciations and attacks on the premises of Grupo Clarín's companies and on the residence of its executives.
- Excessive and intimidating inspections from the AFIP of Grupo Clarín's companies and its directors' residences.
- Threats from the Secretariat of Trade of intervening Papel Prensa and assaulting its directors. Express intent to use the CNV as a vehicle to achieve the same purposes.
- Fines imposed by the Secretariat of Trade on Cablevisión.
- Use of pro-government media to slander Grupo Clarín, as well as its directors and journalists.
- Production and distribution of anonymous pasquinades to attack Grupo Clarín.
- Official advertising campaigns against Grupo Clarín.
- Illegitimate resolutions from the Comfer and the CNDC against the Cablevisión-Multicanal merger.
- Secretariat of Communications’ award and subsequent revocation, within a week, of the numbering to provide telephone services through Fibertel.
- Audiovisual Communication Services Bill and operation of an oversight agency.
- Negotiation and agreement with the AFA to force the breach of the contract with TSC.
- Truck Drivers Union’s blockades to the free circulation of newspapers and magazines.
- Bill to abolish the deregulation of publication sales. Issuance of a decree to achieve the same purpose.
- Partnerships with related unions to attack the media in general and Grupo Clarín in particular.
- Banners against our media outlets in partisan political rallies.
- Verbal assault from high-rank officers and other leaders from the governing party.
- Public denunciations from activists of the Kirchner's administration in media-related areas and events.
- Partnerships with fugitives or convicts for them to make false accusations against Grupo Clarín.
- Pressure on the legislative and judicial branches.
This statement is absolutely false. Let’s just begin with Argentina. Papel del Tucumán, which original owners where provincial newspapers that were part of COOPAL and ADIRA, existed even before Clarín, La Nación and La Razón acquired an interest in the company. Papel del Tucumán was created for the sole purpose of producing newsprint. The company was subject to the same regulatory and tax scheme as Papel Prensa and was conceived to produce an output of 105,000 tons. However, it never managed to operate efficiently, was sold to other partners, such as Grupo Brida, discontinued newsprint production (for which it had been promoted) and replaced it with book paper (more profitable). It finally went bankrupt with pending tax liabilities and amounts owed to Banade for more than USD400 million. Finally, it was acquired by Grupo Pierri for a USD 14 million consideration and is no longer engaged in newsprint production.
There are also other examples in Latin America that refute such statement. Out of the 7 paper mills existing in the area, two of them were or are in a similar situation to Papel Prensa:
- Brazil: Pisa - currently Norske - was originally owned by newspaper publishers along with the Brazilian government.
- Mexico: Pipsa, currently owned by the publishing group Organización Editorial Mexicana, was originally owned by the Mexican government.
This situation does not take place in Latin America only. There are other several cases:
- The New York Times Company, publisher of the New York Times and the Boston Globe, owns shares in two paper mills: Donohue Makbaie and Madison Paper Industries.
- In 1974, Dow Jones Co., the publisher of the Wall Street Journal, the highest circulation and best-selling newspaper in the United States, created F.F. Soucy Inc., a paper mill with a printing capacity of around 250,000 meters of newsprint.
- 70% of the newsprint used in Australia is produced by the paper mills Albury NSW and Boyer Tasmania. In 1990, the paper mills were acquired by Australian Nesprint Mills, which was equally owned by the newspaper publishers News Limited and Fletcher Challenge Limited. Then, Fletcher purchased News Limited’s interest and ended up selling it to Norske.
- In the US, for example, SP Newsprint Co. is a company founded and operated by Cox Enterprises, Knight Ridder and Media General (newspaper publishers). SP Newsprint Co. conducts its business in Dublin, Georgia and Newberg, Oregon. Media General also owned another paper mill: Garden State Paper´s.
- Bowater Mersey Paper Company Limited is 51% owned by Bowater Canadian Limited and 49% owned by Daily Herald Company, a subsidiary of Washington Post Company, the Washington Post publishing company.
Finally, it should be again reminded that Papel Prensa is not a monopoly, it competes inch by inch with "zero duty" imported newsprint and is most often cheaper than national newsprint. Paradoxically, Papel Prensa is a more convenient option for smaller than for larger newspapers, as the former’s volume is not enough to import the input. In fact, Clarín and La Nación are the major newsprint importers and, currently, they purchase it for a lower price than that charged by Papel Prensa.
No. Even since 2006, when all this harassing campaign against the press had not yet been deployed at its best, Grupo Clarín was the media group with the least portion of official advertising revenues. Only 3% of Grupo Clarín’s advertising revenues were derived from official advertising slots.
Despite the fact that Grupo Clarín’s media have always had a leadership position in their specific advertising markets, the combined share of all its media outlets in the "official advertising pie" had always been substantially lower than in the "private advertising pie".
This share has become increasingly smaller since the government decided to barely invest in Grupo Clarín’s media outlets in 2009.
Within the framework of the official attack on the media, the government has arbitrarily distributed the official advertising investment as a tool to punish media regarded as “critical”, as well as a form of indirect censorship towards independent press.
Consistently with this line of thought, the government has heavily punished Grupo Clarín’s media outlets.
In 2010, the government spent ARS107 million in advertising in the broadcast TV of the City of Buenos Aires. El Trece, which leads the Prime Time, only received 5% of the pie, becoming the channel official with the least official advertising slots in that year.
During the same period, the government spent ARS127.5 million in official advertising in the printed media. Clarín, Olé, La Razón and Elle magazine only received 10% of that amount.
The government distributes the official advertising slots arbitrarily as a way to punish voices they deem critical and to reward pro-government media.
During the Kirchner’s administration which started in 2003, the official advertising allocation increased by 1300% and the criteria used to distribute these funds were increasingly arbitrary. Media outlets with few readers or channels with small audiences were the recipients of the largest shares in the official advertising pie.
In 2010, the government spent ARS107 million in five broadcast TV signals, 67.5% of which was allocated to Canal 9, which broadcasts openly pro-government programs. On the contrary, Canal 13, a leader in audience ratings, only received 5% of the official advertising and was the signal with the least official advertising slots.
In the January-November 2010 period, the government allocated 47% of the official advertising budget to two pro-government media outlets: Grupo Szpolski and Página 12 newspaper.
The discretional advertising distribution was worsened by the implementation of the Fútbol para Todos program. In 2010, the government spent ARS 1 billion. Private advertising is prohibited in the broadcasting of soccer matches, now monopolized by the government, and the only things displayed are repetitive and excessive announcements of government projects.
Official RhetoricAmidst these attacks, the pro-government media network that adheres to the official rhetoric as a doctrine has flamboyantly built and repeated accusations and false statements against Grupo Clarín. Here is our word.
Official Rhetoric: “Grupo Clarín is a monopoly". This is false.
Deep-rooted in the country since the mid-1940’s, Grupo Clarín is a media group that is organized and operates in Argentina and its controlling shareholders and management are Argentine. Grupo Clarín has managed to have a footprint amidst the major media players worldwide which are large international conglomerates. Accordingly, Grupo Clarín’s diversification is similar to that of other multimedia groups in the region and worldwide, such as, Time Warner, Fox or Disney (US); Sky (United Kingdom), Prisa (Spain), Globo (Brazil) and Televisa (Mexico).
- Clarín competes in Buenos Aires’ newsstands with 17 national paid newspapers featuring general information that make up a wide offering not easy to find in any other capital of the world. In the provinces, Clarín competes with more than 200 regional and local newspapers, with national newspapers having marginal penetration as it could be expected.
- Todo Noticias (TN) competes nationwide with other six signals of different ownership: Crónica TV, América 24, C5N, Canal 26, CN23 and 360 TV. Such a number of options is unprecedented worldwide.
- Clarín has been engaged in the cable TV market since 1993 with the network led by Cablevisión –which offers cable TV and Internet services- as competitor of the telephone monopoly in a market hard-fought by over 700 operators in the country. Cablevisión has a 47% share in the Argentine market, similar to that held by other international cable operators from France (65 %), Spain (57 %), Germany (52 %), United Kingdom (59 %), Chile (67 %), Peru (82 %), Venezuela (50 %), Brazil (46 %), Colombia (46 %) and Mexico (46 %).
Official Rhetoric: “Clarín does not want the broadcasting law from the democracy". This is false.
We need a modern broadcasting law that ensures pluralism, refrains from granting whatever government is in power wide discretion in the key issues of the business, safeguards the sustainability of media outlets for them to be independent from the political power or economic interests unrelated to the sector and that preserves the legal security of the Argentine citizens that have invested in the media industry.
However, several sections of the law that has been passed make the media dependant on the government’s discretion, eliminate voices, privilege foreign players and affect genuine Argentine investments.
- This law - both its language as well as its enforcement by the AFSCA – is part of a comprehensive plan that seeks to limit the reach and sustainability of independent media to replace them with pro-government voices.
- The law is unconstitutional since it sets forth retroactive effects and neglects legitimately granted licenses, among other things.
- Among the multiple objections to and arbitrary provisions of the law, of note is that the government has wide discretion in assessing content, applying penalties and granting and renewing licenses; all of which allows it to exercise indirect censorship against critical media and favor the colonization of the communication universe with pro-government media.
- Several sections of the law have been suspended by reason of unconstitutionality and are inconsistent with the international trend of the most developed countries. These countries foster the production of signals and content by multimedia groups, promote cable expansion to compete against the telephone companies and benefit private radio and television networks (in Argentina, only state-owned networks are allowed) in order to help to their sustainability and independence from public financing
- Through this law, the government allows large international groups - with turnovers that largely exceed Grupo Clarín’s - to have up to 20, 30 or more signals in their programming grids, while national groups are only permitted to have one.
- Therefore, the need for a broadcasting law that contemplates the interests and rights of the whole society has yet to be filled; a law that seeks to combine the diversity of voices with their sustainability, so that they do not depend on official resources; one that encourages national productions of high quality instead of the fragmentation of the local voices in favor of the large foreign multimedia or the state apparatus.
Official Rhetoric: "Fibertel does not have a license". This is false.
Since 2003, Cablevisión has been the legitimate holder of the license exploited under the brand Fibertel, upon its merger. The merger was approved by the Argentine Superintendency of Legal Entities (IGJ) after having complied with all administrative and legal requirements, all of which the government was aware of.
The government sought to revoke the license for the service Cablevisión has been efficiently rendering through Fibertel by way of an illegal and arbitrary action, which the courts have categorically dismissed:
Prohibiting the free choice of an Internet provider by punishing more than one million consumers, seeking to suspiciously strengthen the monopoly of telephone companies.
Multinational companies with a turnover in Argentina 7 times higher than Cablevisión’s, a company that competes with a cable TV and Internet offering that meets international quality and service standards
Official Rhetoric: "The Multicanal-Cablevisión merger was irregular". This is false.
The Cablevisión-Multicanal merger was approved in 2007 by the competent agency, the National Antitrust Commission (Comisión Nacional de Defensa de la Competencia or CNDC) by the unanimous vote of its three members.
The merger followed the worldwide trend of the cable television industry where the main operators of countries, such as, the US, Chile, Colombia, Mexico, Peru and Spain, merged platforms and integrated old competitors to be technologically and financially positioned to compete against large multinational telephone companies with much higher turnovers and with whom they share the triple and quadruple play market amidst the technology convergence process.
The government can not neglect these facts without revealing its intent to act against the law in order to attack the company’s legitimate right to compete in the cable service. Before approving the transaction, the CNDC had asked the COMER, as required by the procedures then in place, if the operation complied with the effective regulations and the COMFER did not object to the approval.
Official Rhetoric: "Cablevisión is a monopoly." This is false.
Cablevisión offers cable television and Internet services as the network that competes against the telephone monopoly, a market shared by more than 700 operators in the country. As it is the first alternative network to the telephone companies, it has managed to achieve a competitive footprint in the Internet segment that boosted the broadband market.
In the 2007-2009 period, Cablevisión invested more than USD 632 million, more than tripling the initial voluntary commitment undertaken with the CNDC.
Cablevisión has a 47% share in the Argentine cable TV market, similar to that held by other international cable operators in France (65 %), Spain (57 %), Germany (52 %), United Kingdom (59 %), Chile (67 %), Peru (82 %), Venezuela (50 %), Brazil (46 %), Colombia (46 %) and Mexico (46 %).
Official Rhetoric: "Clarín, La Nación and La Razón acquired Papel Prensa in an irregular fashion." This is false.
Clarín acquired its interest in Papel Prensa by way of a legal and lawful transaction which was publicly known. It purchased the company’s shares from the Graiver’s family, several months before they were persecuted by the military dictatorship. This fact has been evidenced by the statements made by the family at the time and at present.
At the time of the purchase, on November 2, 1976, Papel Prensa’s facility was halted and in default.
The price paid by Clarín, La Razón and La Nación was higher than the amount established nine years later by Raúl Alfonsín’s democratic government.
The Graiver case was investigated in democracy by the Judge Miguel Pons, by the Federal Court of Appeals, and by the Government Attorney Molinas. No link was found between Graiver’s kidnapping and Papel Prensa, and no charges were pressed against the newspapers.
At the time of selling the company, the Graiver family was free, had not been kidnapped, tortured or threatened by the military government.
However, the current administration, violating the separation of powers, prepared an illegal report based on distortions, whereby it seeks to twist historical facts to justify a subsequent intervention of the company and control newsprint.
Official Rhetoric: "Clarín and La Nación benefited from Papel Prensa in a preferential way.” This is false.
The company’s commercial policy regarding prices, discounts and quantities has always been approved by the directors appointed by the National Government and the independent directors, with the only abstention of the directors of the newspapers that are shareholders of the company.
These policies are similar to those in place in the newsprint industry worldwide. In fact, Papel Prensa’s volume rebates are higher than those of its international competitors.
Papel Prensa is a private company where the National Government owns a minority interest, it lists its shares in the stock exchange and supplies more than 170 newspapers worldwide, under absolutely open and competitive commercial conditions, with prices that are lower than other suppliers’.
Papel Prensa does not discriminate on the basis of the character, ideology or political party of the media outlet that demands its newsprint.
Official Rhetoric: "The newsprint supply is a monopoly". This is false.
Nowadays, the paper is a “commodity” and, in addition, one of the few products that are imported without restrictions or duties.
Papel Prensa competes like few other industries in the country, without any kind of protection against imported products. The market is so open and dynamic that many Argentine newspapers have been buying imported newsprint at a lower price than that produced by Papel Prensa.
Exports from a neighboring country such as Chile triple Argentina’s imports. The market is also shared by operators from Canada, Finland, Russia, United States and Sweden, among others.
Argentina should have another paper mill, Papel del Tucumán, a company that was tendered by the National Government by the same time, following a similar procedure to that of Papel Prensa. However, Papel del Tucumán had never produced the newsprint it was meant to, swindled USD 400 million from the National Government and today is engaged in the production of other types of paper, infringing its own articles of incorporation.
Official Rhetoric: "Private shareholders do not disclose information to the National Government." This is false.
Papel Prensa is a company characterized for its transparency. It is listed and complies with all disclosure and transparency regulations. It has decided to continue listing its shares, in spite of not being bound to.
The National Government has received the information on the company’s activities, like all other shareholders.
Official Rhetoric: "Clarín benefited from the pesification." This is false.
Grupo Clarín was one of the Argentine companies most damaged from the asymmetric devaluation and pesification measures that were taken.
In 2002-2003, 90% of Grupo Clarín’s indebtedness was comprised by US-dollar denominated credits granted by foreign institutions, which cost increased remarkably.
Since Grupo Clarín's revenues were and - still are - denominated in Argentine Pesos, neither did its liabilities shrink, nor did it obtain specific benefits from the devaluation. On the contrary, its financial burden increased substantially during this period.
All the information concerning Grupo Clarín’s and its subsidiaries’ financial position is public and has been audited by the competent agencies.
This is by far different from the situation of the large international groups, such as the telephone companies, that may borrow loans at much more competitive rates and use them to conduct business in the Argentine market, under absolutely preferential regulations.
Official Rhetoric: “There were irregularities in Canal 13 privatization process.” This is false.
In 1989, the privatization of Canal 13 and Canal 11 was conducted by way of a public bidding process, in accordance with a law called Ley de Reforma del Estado passed by the National Congress. All applicable regulatory, administrative and judicial requirements were met, without any objection or challenge whatsoever.
The very same National Prosecutor’s Office for Administrative Investigations, led by Ricardo Molinas, rejected the eventual existence of any kind of irregularities after a thorough investigation.
The COMFER itself conducted a specific study whereby it could verify that there were no dismissals in violation of the bidding specifications.
Of note is that Artear achieved the best scores in both public bidding processes (Canal 11 and Canal 13) and opted for Canal 13.


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The Tuesday Readers
Fourth Tuesdays (with exceptions), 7:00 to 8:30 p.m, Michaux House, Fagan Parlor
2018 – 2019 season
September 25 The Sabbath
A classic of Jewish spirituality first published in 1951, The Sabbath is a brief but profound statement of the Seventh Day and how we can use Sabbath as the “architecture of holiness” in contemporary life.
October 23 The Distance Between Us by Reyna Grande
Grande’s memoir recounts her experiences as a child left behind by her Mexican parents, who venture to The Other Side to improve their lives, and later as an undocumented immigrant reunited with the father who has embraced a new life.
November 27 A spool of Blue Thread by Anne Tyler
Short listed for the 2015 Man Booker Award, Tyler introduces us to the Whitshank family as “nothing exceptional. None of them could claim exceptional intelligence. And in looks they were no more than average. But like most families, they imagined they were exceptional.”
December 18 Killer Pancake by Diane Mott Davidson
The most lighthearted of this year’s readings, Killer Pancake is from the Cereal Killers series. Caterer Goldie Bear is hard not to love. Despite her dysfunction, everything is “just right.” She is a whiz in the kitchen and as a detective, and she’s even Episcopalian.
January 22 Varina by Charles Frazier
The author of Cold Mountain weaves an historical novel grounded in the life of the former and only First Lady of the Confederacy, Varina Howell Davis, and her escape from Richmond.
February 26 Gospel Medicine by Barbara Brown Taylor
Through this collection of sermons, Taylor offers the healing power of God as a metaphor in restoring the active and ongoing restoration of this broken world.
March 26 The Invention of Wings by Sue Monk Kidd
Kidd casts her literary talents on the real but overlooked lives of Sarah and Angelina Grenke, 19th Century abolitionists and suffragists seen as guilty of the crime of speaking out for their beliefs. Some claim their 1830s pamphlet served as the inspiration for Harriett Beecher Stowe’s Uncle Tom’s Cabin.
April 23 Honey from the Rock by Lawrence Kushner
Goodreads describes Honey From The Rock “Quite simply, the easiest introduction to Jewish mysticism you can read.”
May 28 Sing, Unburied, Sing by Jesmyn Ward
Winner of the 2017 National Book Award for fiction, Sing, Unburied, Sing is an intimate, multigenerational tale of poverty, discrimination, guilt, and hope for redemption set in rural Mississippi.

domain: library


Garuda to fly to Auckland, Taipei, Haneda
The Jakarta Post
National flag carrier Garuda Indonesia is going to provide direct service connecting Jakarta and Auckland, New Zealand, next year and to open sales offices in Taipei, Taiwan, and Haneda, Japan, to expand its Asian reach.
“We are going to open the route in early 2013. New Zealand is a country with tourism and business potential and we would like to grab this market,” Garuda Indonesia pre...
- Police remain vigilant in areas with tight election margins
- Indonesia ready for Freeport tribunal
- Indonesia's tough stance causes headache for tuna exporters
- Police terminate investigation into UI lecturer’s alleged blasphemy
- Muslim group promises no violence at anti-Ahok rally
- Freeport gives government four months to negotiate new settlement
- Millenials ask Jokowi questions, their way
- Police to investigate North Korean restaurant on spy activity
- Jakarta Police to deploy 10,000 personnel to anti-Ahok rally
- TV footage appears to show deliberate attack on North Korean


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Bird flu has been reported on a central Japanese quail farm but no animals have died and no humans have been infected, an agriculture ministry official said Friday.
The Philippines will slaughter 6,000 pigs at a hog farm north of the capital Manila to prevent the spread of the Ebola-Reston virus, health and farm officials said on Monday.
Researchers have discovered human antibodies that neutralize not only H5N1 bird flu but other strains of influenza as well and say they hope to develop them into lifesaving treatments.
Scientists on Sunday unveiled lab-made human antibodies that can disable several types of influenza, including highly-lethal H5N1 bird flu and the "Spanish Flu" strain that killed tens of millions in 1918.
A 23-year-old woman from northern Vietnam has died of the H5N1 virus in Vietnam's first bird flu death of the year, a doctor said Sunday.
Hong Kong authorities said Friday that a dead bird found in the southern Chinese territory had tested positive for the deadly H5N1 strain of the bird flu virus.
A recent string of bird flu infections in humans in China posed no pandemic risk as the cases were unrelated, but authorities need to remain alert, U.N. experts said on Wednesday.
A Vietnamese man has tested positive for bird flu, the third confirmed infection by the deadly H5N1 virus in the Southeast Asian country this year, health officials said Monday.
A second outbreak of bird flu in less than a month has been detected on another poultry farm in Canada's westernmost British Columbia province, the Canadian Food Inspection Agency said Wednesday.
Japan's plan for any future influenza pandemic calls for shutting down airports, closing schools and organizing mass cremations of the dead in hopes of keeping the virus off its shores or at least containing it.

domain: news


text:
The thriller "Stoker" — premiering at the 2013 Sundance Film Festival — marks the English-language debut of Korean director Park Chan-Wook, whose thriller "Old Boy" set a new mark for excitement and violence. So this isn’t some mamby-pamby kind of movie.
"Stoker" centers on India (Mia Wasikowska), whose father (Dermot Mulroney) dies in a car accident — which prompts her uncle Charlie (Matthew Goode) to come live with India and her mother, Evelyn (Nicole Kidman). India starts developing an infatuation with Charlie, even as she suspects his ulterior motives.
The cast includes Jacki Weaver ("Silver Linings Playbook"), and was written by the actor Wentworth Miller.
"Stoker" is one of the few movies at Sundance this year that already has its distribution in place: Fox Searchlight Pictures is releasing the film in March.
- Sean P. Means
|1.||Utah Football: Utes beat Michigan 26-10|
|2.||Monson: BYU is imperfect and undefeated (VIDEO)|
|3.||BYU football: Sloppy Cougars hold off Virginia to improve to 4-0 (VIDEO)|
|4.||BYU football: Virginia linebacker says Taysom Hill will win the Heisman|
|5.||BYU Football LIVE: BYU beats Virginia 41-33|
|6.||BYU football: Defense struggles as Virginia runs 102 plays|
|7.||Utah teacher to stand trial on charges of sex with second boy|
|8.||Elton John rocks his way down memory lane at Utah show|
|9.||Utah football: Victory over Michigan could be big boost to Utes’ season|
|10.||Tony Bennett, Lady Gaga: Kids should know more about jazz|

domain: entertainment


text:
DUBLIN, June 29, 2021–(BUSINESS WIRE)–The report “Pediatric Imaging – Global Market Trajectory & Analytics” has been added to ResearchAndMarkets.com’s to offer.
Global pediatric imaging market $11 billion by 2027
Amid the COVID-19 crisis, the global pediatric imaging market, estimated at US$7.1 billion in the year 2020, is expected to reach a revised size of US$11 billion by 2027, growing at a CAGR of 6. 4% during the analysis period 2020-2027.
Magnetic Resonance Imaging, one of the segments analyzed in the report, is expected to record a CAGR of 6.8%, reaching US$3.7 billion by the end of the analysis period. After an early analysis of the business implications of the pandemic and the economic crisis caused, growth in the ultrasound segment is being adjusted to a revised CAGR of 7% for the next 7 years.
The US market is estimated at $1.9 billion, while China is expected to grow at 9.8% CAGR
The pediatric imaging market in the US is estimated to be worth $1.9 billion by the year 2020. China, the world’s second largest economy, is expected to reach a projected market size of $2.4 billion by the year 2027, with a CAGR of 9.8%. over the analysis period 2020 to 2027. Other notable geographic markets are Japan and Canada, each of which is expected to grow by 3.5% and 5.7% respectively over the 2020-2027 period. Within Europe, Germany is expected to grow at approximately 4.1% CAGR.
Computed Tomography Segment To Pick Up 6% CAGR
In the global computed tomography segment, the US, Canada, Japan, China and Europe will achieve the estimated CAGR of 5.5% for this segment. These regional markets, representing a combined market size of $1.1 billion by the year 2020, are projected to reach $1.6 billion by the end of the analysis period.
China remains one of the fastest growing in this cluster of regional markets. Led by countries such as Australia, India and South Korea, the Asia-Pacific market is projected to reach US$1.5 billion by the year 2027, while Latin America will grow at a CAGR of 7.2 during the analysis period. %.
Main topics covered:
II. MANAGEMENT SUMMARY
1. MARKET OVERVIEW
Market insights from influencers
Global market trajectories
Impact of Covid-19 and a looming global recession
2. FOCUS ON SELECT PLAYERS (Total 36 Recommended):
3. MARKET TRENDS & DRIVERS
4. GLOBAL MARKET PERSPECTIVE
III. MARKET ANALYSIS
REST OF EUROPE
REST OF ASIA-PACIFIC
REST OF LATIN AMERICA
UNITED ARAB EMIRATES
REST OF MIDDLE EAST
For more information on this report, please visit https://www.researchandmarkets.com/r/nci44w
Check out the source version at businesswire.com: https://www.businesswire.com/news/home/20210629005563/en/
Laura Wood, senior press manager
For EST business hours, call 1-917-300-0470
For USA/CAN Toll Free Call 1-800-526-8630
For GMT office hours, please call +353-1-416-8900

domain: geography


2019 TOSHIBA Tecra A50-E 15.6″ FHD Business Laptop Computer, 8th Gen Quad-Core i7-8550U up to 4.0GHz, 12GB DDR4 RAM, 256GB SSD, 802.11ac WiFi, Bluetooth, HDMI, USB 3.0, Windows 10 Professional, Brought to you By TOSHIBA.
802.11ac and Bluetooth; 2 x USB 3.0, 2 x USB 2.0, 1 x HDMI, 1 x VGA, 1 x Headphone output/Microphone input combo, Gigabit LAN and WLAN, 10/100/1000Mbps LAN
12GB DDR4 2400 SDRAM Memory for full-power multitasking;256GB SSD offer enough storage for your files
Windows 10 Professional, 64-Bit
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15.6″ FHD 1920×1080 LED backlight display, Intel HD Graphics 620
A few of the links on this page are “affiliate links”. This means if you click on an affiliate link and buy the item, we receive a small commission. The price of the item is the same whether it is an affiliate link or not. We only recommend items that add value to our customers. By using our affiliate links, you’re helping support Burnpedia, and we greatly appreciate it.


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There is a seller on ebay that sells a mac tools socket that is a combo for both the fuel and oil filters I thinks it is like 36 & 35 mm it is a combo socket and sells for like 15 bucks delivered or you could just use the right size wrench. Just be careful to not overtighten it as YOU WILL CRACK THE PLASTIC CAP and do change the O-ring DO NOT reuse the old one.
There is a section on this in the 6.0 tech folder as well on how to do alot of things to this motor: here is the link for the oil filter
On our E450, the filter housing always comes loose when I use the metric allen wrench to remove the drain plug in the center of the hex, I then just hold it with my hand and remove the drain plug. After the filter drains I spin the housing off with my hand, I have never actually used a socket on it.

domain: hobby


text: 04-24-2013 Rhode Island’s State Senate passed gay marriage legislation by a comfortable 26-12 margin. This followed a vote by the House in January, 2013. The bill goes back to the House for a largely procedural vote. The Governor says he will sign the bill and did sign the bill on April 30, 2013. Rhode Island became the 10th state to recognize same-sex marriage. The legislation took effect on August 1, 2013.


text:
Influences: Shania Twain, Alanis Morissette, Goo Goo Dolls, Taylor Swift, Journey, Sara Bareilles, Lady Antebellum, Jewel
27/11/ 2019 - EP Release - ‘Blue eyed Girl’
24/09/2019 - Single Released - 'Good Times'
17/07/2019- Single Released - 'Worthy'
8/05/2019 - Single Released - ‘Destined to You’
September 2019 - Wrote commercial Melody line and Lyrics - Starnow Client : Melody composer & Lyric
August 2019 - Wrote/Composed/ performed Jingle/ Media CV & Award Launch original music - GirlBoss NZ
August 2018 - Wrote Commercial Jingle - Advanced Safety
Nov 2011 - Wrote two original songs for Independent film in the USA called “ Brutal”
Nov 2009- Rise national Songwriting competition
Won recording grant and music video grant for my original single “I have a dream” http://www.youtube.com/watch?v=GCqIE8I8qdY
15/03/2020 - Unplugged Artist show - At a Rolling Stone
1/03/2020 - Arts Centre Christchurch
7/02/2020 - Next Music Festival
26/01/2020 - Lulu's Bar and Eatery Live Performance
22/11/2019 - EP Release Performance/ Launch - A Rolling Stone, Christchurch, NZ
2/06/2018 - The Church of Jesus Christ of Latter day Saints
12/05/2018 - Peel Forest bar and cafe
9/03/2018 - The Church of Jesus Christ of Latter day Saints
14/10/2017 - Wedding Singer
30/09/2017 - Peel Forest bar and cafe
13/04/2017 - Coca - Centre of contemporary Art
1/04/2017 - Christchurch Farmers Market
Jan 2016 - Wedding Singer
May 2015 - Pearls of Harmony Competition - National winners - Christchurch Chorus
September 2015 - Wedding Singer
Feb 2012 - Resurgence Christian Festival
Jan 2012 - Parachute Music Festival - Opening Act for Parachute
July 2011- Church concert special guest Hilary Weeks - I was the opening musical item for the big time LDS artist Hilary Weeks. It was a spiritual and uplifting experience and performance.
Jan 2011- Parachute Music Festival - Opening Act for Parachute
June 2010 - Performing on the Erin Simpson show - I appeared on the Erin Simpson show did an interview and performed my own original song I have a dream.
Jan 2010 - Carnival Cruise - I won a karaoke competition for the legends night on the carnival cruise ship. I was chosen to sing like a virgin and portray Madonna. I had the costume, the live band, male backup dancers and performed in front of 1500 people.
June 2010 – Erin Simpson show performed original song ‘I have a dream’ White bait TV
I heart songwriting club ( write 1 song a week for 10 week program) August- November 2019
Songwriting Development 3 day Workshop with Bic Runga - July 2019
Sept- Dec 2012 Berklee Songwriting course - Writing hit songs


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Simple steps can keep food safe
Warmer weather means more family picnics, camping and outdoor barbecues. It also means there's a greater risk for food contamination and poisoning.
According to information from the Centers for Disease Control and Prevention, an estimated 40 million Americans suffer food poisoning each year, and most foodborne infections are undiagnosed and unreported.
Planning ahead and careful attention to just a few details can help prevent many of those illnesses.
"The four steps to food safety are clean, separate, cook and chill," said Betty English, Family and Consumer Science agent with the Augusta-Richmond County UGA Cooperative Extension office. "Whether you are at a campsite, grilling on the patio or in your own kitchen, these four steps are essential in keeping your food safe."
English explains that when preparing for a picnic, be mindful of how much food is needed and take just that amount. Any extra might end up becoming spoilage. It's best to select items such as peanut butter, bread, crackers and dried meats that don't need refrigeration.
An insulated cooler should be used to transport perishable foods and should include ice, frozen gel packs or even frozen cans or drink boxes that will thaw by serving time. A separate cooler should be used for ice for drinks, and another for any raw meats in order to prevent cross-contamination.
"Make sure you understand that ice is a food and can be contaminated," said English. "You should use separate coolers for cold storage of food and drinks."
Foods that are to be grilled should be kept cold until the grill is hot, and need to be cooked thoroughly. Investing in a food thermometer is recommended. Clean plates should be used for serving and any unused marinade should be discarded.
With temperatures rising, it's important to note that no food should be left sitting out for longer than an hour in temperatures of 85 degrees or more. On hot days, perishable foods - including mayonnaise, potato salad, cole slaw, baked beans, cut fruits and meats - should be thrown out if they're out for longer than an hour.
By following these steps, the next picnic or camping trip will be one to remember for the fun and not the illnesses incurred.

domain: food


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A twelfth birthday party for fraternal twins, during a summer twilight, was attended by their fellow tween-girl guests!
Above photos, courtesy of the party-giving mom. :-) Thanks, Margie!
Since it was a small group, I had time to do deluxe full-color, full-body-with-hobby caricatures. Soccer was an oft-repeated request, but I also had two more unusual ones:
A mud-race on the left, and to the right: enjoying a strawberry-iced doughnut with rainbow sprinkles! When I was a kid, we called those "jimmies." Well. they were fun to draw!
After drawing the young ladies, the good-natured big brother got his done, with his sport (not soccer!).I learned that you can refer to rowing as "crew" but not "crewing." :-)
Then the mom, with HER favorite things!
Here's a view of most of them after I'd finished ( there's one missing, I think)
Thanks for having me, M & M!


Why no footpath?
I WOULD like to know why there is no footpath or cycle lane running from the top end of Sapley Road to Kings Ripton Road. The current footpath in Sapley Road ends at the playing fields and then re-starts at the entrance to the car park for the same playin
I WOULD like to know why there is no footpath or cycle lane running from the top end of Sapley Road to Kings Ripton Road.
The current footpath in Sapley Road ends at the playing fields and then re-starts at the entrance to the car park for the same playing fields in Kings Ripton Road.
It has long been hoped by residents in Hartford and the "birds estate" that getting to the leisure parks and Tesco would be made safer and easier, without the use or need of a car. In particular, as there is no access to public transport for residents of the estate and the top end of Sapley Road, it still means that pedestrians have to walk along muddy verges, in dangerous roads or across the playing fields.
With Persimmon building new homes on the site opposite the playing fields, I cannot understand why an agreement was not set in place for the builders to link the pathways. They have put in footpaths from the new estate for residents to get to the leisure and industrial parks but not for their safe journey by foot to Sapley Road. This is a wasted golden opportunity, a view expressed by a lot of local residents.
You may also want to watch:
With the current climate of trying to reduce unnecessary usage of cars, reduction of carbon emissions and to get people fitter, it does seem ludicrous that the large population of Hartford and the birds estate cannot walk to the cinema or to shop.
GINA CRUICKSHANK, Huntingdon Liberal Democrats, Eagle Way, Hartford
- 1 The Windmill pub is set to reopen after extensive refurbishment
- 2 Life is sweet! Cheesecake emporium opens in Brampton
- 3 Woman dies after being hit by lorry
- 4 Tudor history and famous Chinese Bridge in Godmanchester
- 5 Riley turns imagination into reality with best-selling adventure book
- 6 Celebration of food and drink at town's first street food festival
- 7 Paedophile foiled by undercover officer
- 8 Rainbow alliance set out their stall for Cambridgeshire
- 9 Do you have items of history for nostalgia group?
- 10 Godmanchester community pulled together throughout the pandemic


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Cute little critters and other art
Sunday, July 15, 2012
Sorry, I haven't posted lately. It always seems that I slow down a bit in the Summer. Here's little pixie. Her eBay auction starts this evening at 6:45 pm PST. I hope you are all staying cool and enjoying the outdoors.
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Michael Goldfarb dissents from my conclusions on the implications of the NIE on missile defense, and further asserts that liberals should love missile defense:
And finally, liberals fundamentally misunderstand the effect of deploying a missile defense system–it would decrease the likelihood of conflict, not increase it. Missile defense would provide decision makers with one more option in a world where options are the scarcest commodity.
Imagine the U.S. intelligence community, or more likely their Israeli counterpart, is able to determine with some degree of certainty that the Iranians are mere months away from an operational nuclear capability. Right now, they’d have two options: bomb or do nothing, aka diplomacy. But if those leaders could have some confidence in their ability to shoot down an Iranian missile, wouldn’t this strengthen the argument for doing nothing–the argument Farley would most certainly be making. As it is, the American people would likely demand military action, but missile defense would give liberals a fall-back position–‘it doesn’t matter if they build a nuclear missile, we can shoot it down.’
Let me explain the concept of “deterrence”. Deterrence means the creation in the mind of on adversary the belief that the costs of an action will outweigh the benefits. In this specific sense, it means creating in the mind of the Iranians the belief that they’ll suffer drastic consequences for doing things like firing nuclear missiles at other countries. Now, I tend to think that the dramatic military supremacy of the United States over Iran in any conceivable military confrontation is enough to deter Iran from firing nuclear missiles at random European targets. As such, I reject Michael’s premise; because of deterrence, we don’t need to overly worry about the threat of Iran committing national suicide by firing a nuke at Paris or Berlin. Indeed, this has pretty much always been the liberal position on missile defense; even the job it purports to do can be done better by deterrence. Of course, it’s been a wingnutty article of faith that the leaders of Iran are not sensitive to costs, but whatever else it has to say, I think that the NIE has put that argument decisively to bed. Backing me up on that I have no less august authority than Victor Davis Hanson, who noted recently that Iran is not a suicidal state and is sensitive to costs. Now, a sensible reader might reply “but isn’t Victor Davis Hanson an unredeemed hack who can’t be trusted to supply reliable information about his academic specialty, much less the decision-making process of the Iranian state?” The answer is yes, but the point still holds.
So, since in my world liberals are against throwing money away on weapon systems that have dramatic and unsolved technical problems, that agitate foreign countries (while it might be objected that Russia is already irritable, that’s no reason to poke it with a sharp stick for no good reason), that are extremely expensive, and whose flimsy strategic rationale has vanished like an April frost, I’d have to say that liberals like myself are quite rational in our belief that missile defense is a pointless waste.


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|Type / Tags||Reverb|
GigaPulse is Tascam's first VST plug-in for Windows. Using convolving technology, which essentially "samples" a room or acoustic body, GigaPulse can emulate any room, vintage EQ or microphone.
GigaPulse goes beyond most convolving reverb plug-ins with its built-in mic modeling, which can change the quality of the reverb recording or can be used on its own to add vintage microphone warmth to your recordings. The user can select the position of the sound source in the room with a 2-dimentional grid, the perfect effect for orchestral arrangements and other spacious mixes. And Tail Extension technology allows the reverb impulse recording to be stretched for a longer decay, and when combined with Turbo mode reduces the processing load on the computer, allowing more instances of the plug-in to be used.
- Acoustic space modeling via exclusive convolving algorithms.
- Create new impulses from your own recordings.
- 2D mic/source placement – move your source to up to 18 locations in a room.
- Microphone modeling can be applied to the environment or used alone.
- Tail extension lets you stretch reverb decay.
- Turbo Mode reduces the processing load to free up your CPU for more instances.
- "Move" the mic using the Perspective slider, controlling the reverb amount while maintaining phase and stereo imaging.
- Impulse libraries will be available from TASCAM, or download numerous freeware impulses from the internet.
Reviewed By taijiguy
July 14, 2006
GUI: Nice interface, very intuitive and user friendly.
Sound: My only other experience with a convolution reverb is with SIR. Both are great sounding reverbs, but I prefer GigaPulse because you can change microphone simulations, microphone to source distance, and stereo/surround separation using multiple microphones; and I think it sounds a little better.
Features: GigaPulse has virtually no latency, so it can be used live. You can use multiple impulse responses in a cascading fashion. The microphone selection list looks to have at least 25 different microphones. I especially like the Neumann U47.
Docs: The documentation is a compiled .CHM file, although I would prefer a paper manual. But the software is so simple to use that you can probably figure out how to use it without a manual.
Presets: The onboard presets are very nice and cover a wide range of room types, studio quality electronic and plate reverbs, and several unusual objects like a metal broiler and a ceramic pot. Very interesting hearing a Mellotron coming out of one of those!
Support: I haven’t needed to contact Tascam support, so I’ll give them the benefit of the doubt.
VFM: For what I paid, GigaPulse is a steal. For what the online stores are selling it for, it’s probably still a good deal since it’s only 1/2 to 1/3 the price of some brands.
Stability: It seems stable; at least it hasn’t crashed so far. You do have to be careful of feedback with some settings though, and using one of the downloadable .WAV impulse responses from the many websites offering free ones makes it even more critical that you be careful. The .WAV files seem to be louder than GigaPulse’s native formats.
I’ve downloaded several free reverbs and demos of commercial reverbs, but I don’t think I’ll be using them any longer. This one does the job for me.Read more


The Mild Seven Renault F1 Team are hoping for more points in this weekend's San Marino Grand Prix and Executive Director of Engineering, Pat Symonds believes the R202 will be perfectly suited to continue a string of impressive finishes which sees...
The Mild Seven Renault F1 Team are hoping for more points in this weekend's San Marino Grand Prix and Executive Director of Engineering, Pat Symonds believes the R202 will be perfectly suited to continue a string of impressive finishes which sees the team lying fourth in the World Championship at the start of the European season.
Drivers Jarno Trulli and Jenson Button have run competitively during the first three fly-away races, and Symonds believes that the car's impressive traction will ensure the pair can cope with demands of the 4.933km Imola circuit.
"The 202 is a good all-round car and we now have experience with it on a number of different types of circuit," said Symonds. "It has performed well on all of them, but if there is one area in which we are particularly strong, it is traction, which comes from a combination of the chassis, engine design and traction control. Imola features a lot of acceleration from low speed, so we can be hopeful of points."
Technical Director Mike Gascoyne and his team at the Mild Seven Renault F1 Team's Enstone headquarters have been hard at work on the continuous development programme, and this has once again yielded new parts to further improve the car for the weekend at San Marino.
The car will feature new front wing endplates, and Gascoyne is confident that the reliability and pace shown by the R202 so far this season will continue at Imola.
"Overall the car's reliability is good and we have been running in the points regularly," said Gascoyne. "Given our level of performance, it is slightly disappointing not to have had more points finishes, but I strongly hope we can do so with both cars at Imola.
"The drivers are doing exceptionally well. Jarno has been settling into the team without any problems, and both he and Jenson have qualified and raced strongly. I think they are evenly matched and because of that they are both pushing the team forward in a very productive way."
Gascoyne believes that Michelin are well equipped to cope with the lower temperatures expected at the Imola circuit, and added: "Michelin have made considerable progress during the start of the season and over the last few races. Although I expect it will be slightly more even than the past few races, they will still be very strong."
At Viry-Chatillon, the engine team is also pushing forward in their development cycle. "Imola demands an engine which is strong across the board - in terms of power, fuel consumption and driveability," explained Denis Chevrier, Head of Race Engineering (Engine).
As the first European race, the San Marino Grand Prix often sees manufacturers introduce major new engine developments. However, this won't be the case for the Mild Seven Renault F1 Team. "With the RS22, we decided to introduce small steps race by race," said Chevrier. "This first European race will therefore form part of our incremental programme of development with this engine, both in terms of performance and reliability."
For the team, the return to Europe provides the welcome arrival of the trucks and motorhomes that provide a 'home away from home' for engineers and mechanics alike. And Symonds himself is looking forward to the return of his mobile engineering office.
"The start of the European season means it is the first time we get to work with all the equipment and that affects how we operate," said Symonds. "It is significantly easier. We are well set up to work on the fly-aways, but it is much easier with the trucks at the circuit.
"We can take more equipment and we have one truck dedicated to an engineering office. That allows much better factory communications and a much better working environment, because you don't have an engine starting up in your ear every five minutes!"