Asian American Stereotypes Essay -- essays research papers

Relating to Tracy Lai’s article named, â€Å"Asian American Women†, Lai talks about how generalizations dehumanize individuals while transforming them into articles to be controlled. Lai addresses the subject of how Asian individuals and societies are generalized as being sub-par and intriguing. The issue that Lai brings to our consideration is that it is a battle to be an Asian in America because of the way that Asians have been denied political, monetary and social fairness in America. Lai moreover draws out into the open the fanatic fantasy that Asians have made it in America, which is a long way from reality. I sense that Lai’s contention is incredibly compelling because of the way that generalizations are not just observed among Asians, they are likewise observed in numerous other societies and sexual orientations. For example, ladies for quite a long time were doing combating for woman’s correspondence to have the option to cast a ballot, and today ladies are as yet fighting for fairness in political also, financial zones. What's more, African American’s are as yet attempting to be acknowledged into certain political jobs all through our general public. Since Tracy Lai is an Asian in America I feel that her contention holds incredible legitimacy because of the way that Lai shared her very own encounters. By perusing Lai’s individual emotions, it permitted me to comprehend her convictions undeniably in light of the fact that I had the option to see where she was originating from. Positively I concur with Lai’s sees since I have seen that Asians are portrayed as being sub-par. For instance, in the event that you have ever observed a film or a network show that...

Marketing Communications about advertising Assignment

Showcasing Communications about promoting - Assignment Example It is significant for an association to recognize potential clients before the presentation of the items dependent on the nature and qualities of the items. Fitting objective crowd for this specific promoting has been given underneath. â€Å"I have a bustling every day timetable and I am truly worried about my great wellbeing. I have caught wind of these kinds of items, yet never found out about these recently grown low in fat RTE items. I might want to encounter these items, if these are great and sterile for my health†. Significant goal of this promotion is to make noteworthy brand attention to the recently propelled RTE items in the psyches of the objective clients in Singapore. The association will guarantee preeminent nature of items in serious value level. The quantifiable goal is to breakeven inside a half year and become one of the best items in Singapore Market. The specific conduct result of this commercial is to make mindfulness about the brand among the individuals. The association should attempt to become pioneer by make mindfulness among target crowd through this battle. We should attempt to guarantee high brand review through this battle. It is significant for an association to situate the brand as per the nature and qualities of items and target clients. â€Å"To the bustling people, who have extraordinary incentive for every single second in your day by day life, our RTE items have been tried and come about as low fat and sound items inside the RTE food industry. You can remain protected and sound in the event that you devour our items. Furthermore, we will offer these items in monetary value level to back your acquiring level†. †Brand Position Statement. The message would be created is to pick our RTE items on the off chance that they need to devour top notch food items in restricted timespan. Youngsters and youthful grown-ups are our significant objective clients. In this manner, we might want to

How to Afford Private School Tuition

The most effective method to Afford Private School Tuition Non-public school can be costly, and taking care of those weighty educational cost tabs can be a weight for families from all salary levels. The normal national expense of non-partisan non-public schools is around $17,000 per year, and the yearly educational cost at schools in urban zones, for example, New York, Boston, San Francisco, and Washington, D.C. can be more than $40,000 for only a day school program. All inclusive schools are much increasingly costly. Be that as it may, that doesnt mean a tuition based school instruction is not feasible for your family. While you may imagine that there is minimal budgetary guide for tuition based schools, and yes it very well may be serious to get money related guide, there are a few wellsprings of subsidizing that you might not have thought of. Here are a few manners by which you can discover money related help to pay for tuition based school: Converse with the budgetary guide official at your school. The money related guide official at your school may think about legitimacy and need-based grants that your youngster might be qualified for; at times these are not broadly advanced. A few non-public schools offer free educational cost for guardians procuring not exactly about $75,000 every year. The same number of as 20% of tuition based school understudies get some type of need-based money related guide, and this figure is as high as about 35% at schools with huge gifts. Remember that schools with enormous gifts and longer narratives can commonly offer bigger measures of help, however ask about projects even at schools that are less settled. Look at grants. There are numerous grants andâ even voucher programsâ available for understudies at non-public schools. The school youre applying to or going to may even have grant programs for understudies; make certain to ask the affirmation office or money related guide office to see whether youre qualified and how to apply. There are additionally local grant programs that can help with discovering grants. Some striking projects incorporate A Better Chance, which gives chances to understudies of shading to go to boarding and day school private academies around the nation. Research free or low-tuitionâ private schools. Non-public school for nothing? ​Believe it or not, schools that offer zero tuitionâ do exist. There are totally educational cost free private and parochial schools the nation over. Look at this rundown of free non-public schools. You can likewise look into schools with low educational cost rates; with a budgetary guide bundle, in the event that you qualify, you could wind up with a chance to go to a tuition based school for practically no money.â Don’t neglect to get some information about kin limits. Numerous schools will offer limits on the off chance that you as of now have a youngster at the school, or if a relative has gone to already (frequently alluded to as an inheritance understudy). Moreover, some non-public school money related guide officials will lessen the educational cost for families paying school educational cost while they are paying non-public school educational cost. Inquire as to whether the school youre applying to offers these sorts of limits! Exploit worker limits. This may sound odd, yet its actual. Numerous non-public schools offer full time representatives free educational cost or educational cost limits. On the off chance that you realize you need to send your youngster to non-public school and your range of abilities adjusts to an opening at a school you like, go after a position. Make certain to take a gander at necessities for the educational cost limits, as certain schools necessitate that representatives work at the school for a specific number of years before they are qualified. In the event that youre effectively a parent at the school, you can at present apply. Be that as it may, youll likely need to experience a similar proper request for employment process as the various up-and-comers. Dont stress, on the off chance that you dont land the position, your youngster can even now attend.â Spread out installments with educational cost installment plans. Numerous schools will permit you to spread out your yearly educational cost in portions. They may charge a level expense or enthusiasm for this administration, so make certain to peruse the fine print and decide whether this is directly for you. There are likewise numerous foundations that oversee educational cost installments at tuition based schools the nation over. Exploit pre-installment motivators. Numerous schools will offer guardians a markdown for forking over the required funds by a specific sum. On the off chance that you have a prizes program charge card, this can be an extraordinary method to win a few advantages. You can utilize tax-exempt Coverdell investment accounts. Coverdell Education Savings Accounts, which permit you to set aside to $2,000 per year per recipient in tax-exempt records, can be utilized for educational cost at tuition based schools. The disseminations from these records won't be burdened if the sum in the record is not exactly the beneficiary’s instructive costs at a qualified organization. Article altered by Stacy Jagodowskiâ -stacyjago

The Upside to Custom Term Paper Writing

The Upside to Custom Term Paper Writing Custom Term Paper Writing - Dead or Alive? Not just that, but college term papers will likely compose a huge part of the last grade you make it in your training course. A term paper is among the most crucial tasks students get at the close of the semester. Buying online term paper is now a standard habit for most academic level students. On-line term paper writing assistance is just what you require! Composing an excellent research paper begins with compiling an awesome thesis statement. When you would like to purchase research paper here are important things that you need to consider. Writing a research paper is a huge challenge to several students. Writing a great term paper is similar to a combat operation. To compose a well-organized paper, you must be aware of the way the appropriate term paper format. The paper is going to be written based on your instructions and academic standards. It's possible to receive a research paper from several places nowadays. Sometimes you might be asked to compose a research paper on a topic you don't understand clearly. Just because you're searching for an inexpensive term paper writing service doesn't imply that you should skimp on quality. The way you can locate a dependable term paper writing service comes in a lot of forms. So, you may rest assured your term paper service is going to be delivered by means of a pro. It is extremely easy to use our research paper services. Choosing online essay writers isn't a nightmare anymore. Writing an article with Essay help can be a challenging job. Therefore it's clear that the author is well informed about all of the comprehensive chapters and sections that need to be presented in the paper. It is preferable to address a company with several writers than one with a couple writers. It is tough to ascertain which freelance writer might handle your assignment best. Experienced term paper writers are affordable and they're able to help you acquire the information which you require for your topic. Who knew essay writing may be so tough. If you order from us, you can secure a draft of your paper to ensure your writer is heading in the correct direction. Our essay writers will provide you with custom accounting papers written and edited based on your request. Employing an essay writer on the internet isn't as expensive as some folks say. If it is possible to testosterone choose the right no cost essay with content articles published about charles darwin azines healthy selection, we'll be ready to provide you with a customized article which you will require. The most important body of the customized term paper comprises the precise method of creating the thesis statement with relevant explanations, analytical ideas and quotes from external sources. Folks may want to ask questions until they buy a term paper, or they may want to clarify something. If you discover that it's challenging to make the correct choice for your term paper custom, read unbiased and credible reviews to acquire more information concerning the experiences of different people. There are different types of term papers, each one with distinct methods of writing them. Thus, in the event you google write my term paper for me and our website is what you've found, then you're on a perfect track, and we are here in order to cover your back. You will have the ability to choose the academic requirement of the essay we create for you to be sure you know your customized essay will satisfy the compulsory assessment standards. Additionally, composing an essay is a far greater device of learning compared to reading as an example, as a result of simple fact that in case you have the capacity to cover precisely what you have actually discovered and checked out, it ind icates that you've recognized the material perfectly. Your term paper outline should incorporate the key points that you want to write about. It can be quite so overwhelming when you're predicted to compose a term paper, in part because you've got to learn to write it effectively and in part as you are snowed under with a lot of other work. You don't wish to address individuals who deliver your work late. Thus, the only logical way out is to begin seeking expert assistance with term paper. Understandably, some students feel a little bit of pressure when doing term papers on account of the time and effort it entails.

Analysis Of Bram Stoker s Dracula - 1448 Words

Dracula is a widely known novel written by Bram Stoker in 1897. It is popular worldwide for its intense love story and backstory of the infamous Count Dracula. Stoker was born in Dublin, Ireland in 1847. As a child, he was very ill, so in an attempt to entertain himself, he read several books and listened to the horror stories his mother told him. In turn, Stoker became interested in ghost stories and began writing them. Gothic fiction was a genre that was extremely popular during this time period, and Dracula is a wonderful example of this type of literature. Bram Stoker’s Dracula has all of the classic elements of a Gothic novel. Stoker incorporates these elements beautifully through the use of a variety of rhetorical devices, including symbolism, theme, tone, and setting. Dracula explores the tale of a powerful vampire’s attempt to move to England and the battle between him and a small group of men and women led by Professor Abraham van Helsing. This dispute ultimately leads to Dracula’s defeat and death. There are a lot of symbols in Dracula that tie into the actual themes of the story. One example is the symbol of blood. Obviously, blood is significant in a vampire story, but the amount of references of blood in this novel is extraordinary. Reinfold is the only character to explain this in Chapter 18, page 16: â€Å"I tried to kill him for the purpose of strengthening my vital powers by the assimilation with my own body of his life through the medium of his blood - relying,Show MoreRelatedAn Analysis Of Bram Stoker s Dracula 1330 Words   |  6 Pages Bram Stoker in Dracula imagines a â€Å"proper women† by demonizing Lucy ascribing to her traits of a wanton woman; a whore of a demon. A misogynistic attitude is popular in a patriarchal society, especially in the middle of the nineteenth century. On the other hand, Stoker unconsciously ties Mina’s behavior to emulate a woman of propriety. She is the very bane of what a progressive woman looks like but not when looking at her through a gynocritics lens. To prepare the reader for the ideology of theRead MoreLiterary Analysis : Bram Stoker s Dracula1285 Words   |  6 Pagesfamiliar, further explaining that the â€Å"uncanny effect is produced by effacing the distinction between imagination and reality.† (Freud pg.396) Bram Stoker s, Dracula, captures the thematic zeitgeist of gothic Europe; the repression and trappings of a rigid and formal society masking the carnal and base desires of the population at large. Freud s analysis of the uncanny, of attraction mixed with disgust, lays bare the underlying sentiment of stoker’s narrative; emphasizing on purity and virtue byRead MoreAnalysis Of Bram Stoker s Dracula 1997 Words   |  8 PagesBram Stoker’s Dracula was written in 1897. This was a time that the Victorian era and its values were changing and meeting their ends. The male-dominant world was evolving to an equal opportunity society. This meant women were no longer oppressed and limited socially, educationally, economically, or even sexually. The end of the Victorian era also called for growth in technology and medicines. Old ideas were diminishing while new ideas of the world were flourishing. Whether it be the pro femininityRead MoreAnalysis Of Walt Whitman s Dracula And Bram Stoker s `` Dracula ``1886 Words   |  8 Pagesestablished an impact worldwide. Writers such as Oscar Wilde and Bram Stoker, two Irishmen that know of Whitman’s writings through the poet’s popularity growing up as children and young adults, had become advocates of the controversial topics Whitman wrote about. Wilde and Stoker’s writing styles differ from Whitman’s: Wilde is known for his involve ment with the Aestheticism movement and Stoker for his classic horror novel, Dracula. Both men have personally met Whitman on multiple occasions in hisRead MoreSexuality In Bram Stokers Dracula1082 Words   |  5 PagesSexuality in Bram Stoker s DraculaBram Stoker s Dracula, favorably received by critics upon publication in 1897, entertained its Victorian audience with unspeakable horrors such as vampires invading bedrooms to prey on beautiful maidens under the guise of night. The novel s eroticism proved even more unspeakable. Received in the era of repression, it remains questionable whether Dracula s readership perceived the sexuality flowing from the page. An advocate for the censorship of sexual materialRead MoreFilm Adaptation Of Bram Stoker s Dracula1320 Words   |  6 PagesBram Stoker’s frightening tale of Count Dracula has struck horror into the hearts of many since it was originally penned. In 1987, Bram Stoker wrote the revolutionary tale Dracula that played off the fears of the people of the era. The plot and characters that make the novel great also translate nearly perfectly to cinematic adaptations. Starting in the early 1900’s, directors have done their best to portray the terror that the original novel inspired. Francis Ford Coppola’s Bram Stoker’s DraculaRead MoreOral Dracula from a Reader and Femminist Perspective1443 Words   |  6 PagesBram Stokers Dracula an oral presentation Good Morning/Afternoon Today I will review Bram stokers 1897 novel Dracula, the approaches I will be using to reviewing the novel include the world centred approach, and the reader response approach exploring the themes of reader positioning and the authors intented reading and reader, then focusing on the world centred approach of the feministtheory. reader centred -attention on the reader -different readers from different social, cultural, religiousRead MoreBram Strokers Dracula: The Man Behind the Count Essay794 Words   |  4 PagesBram Stoker’s Dracula is a story of horror, suspense, and repulsion. The main antagonist, Count Dracula, is depicted as an evil, repulsive creature that ends and perverts life to keep himself alive and youthful. To most onlookers that may be the case, but most people fail to see one crucial element to this character. Dracula is a character that, though it may be long gone, was once human, and thus has many human emotions and motives still within him. Let us delve into these emotions of a historicallyRead More Intertextual Exchange in Carmilla, Dracula and the Historian1639 Words   |  7 Pagesâ€Å"Writers seldom duplicate their influential precursor(s); rather, they often work within a certain framework established by other writers or generic conventions, but vary aspects of it in significant ways† (Friedman 155). Sh eridan Le Fanu’s, Carmilla, Bram Stoker’s, Dracula and Elizabeth Kostova’s, The Historian, clearly engage in this intertextual exchange, as evidenced by their use of narrative structure and striking character parallels. Published in 1872, Le Fanu relates the story of CarmillaRead MoreA Common Concern Throughout The Victorian Era2100 Words   |  9 Pagesconformed to these roles and followed the gender expectations of their society. Bram Stoker s Dracula describes a post dated European setting in which most women are subject to explicit gender roles and stereotypes. The norm in this society is for women to be modest, prim and proper. However, the novel narrates the possibilities of a situation in which women don t conform and thus are scrutinized. Bram Stoker s purpose in Dracula is to express the threat faced by men when encountering women who are in

Reflective Account Essays - 2198 Words

The theme of this reflective account is engaging children in participation, and enabling children to have a voice. The Every child matters documentation (Department for Education 2010) focuses on the important role of the adult in enabling children to make decisions and encouraging them to participate and make a positive contribution. As a result through this account, how children in my setting are encouraged to participate in the outdoor play space will be explored. A small piece of research was carried out which will be reflected on, as will theory relating to children making a positive contribution in the early years. The reason I chose to carry out my research on the outdoors area is that outdoors is very popular in my setting,†¦show more content†¦To enable the children’s voices to be heard, I explored various tools to engage the children from the Mosaic approach (Clark amp; Moss 2001). I disregarded using questionnaires as the children were unable to read and write so this would have been inappropriate. I disregarded role play as I didn’t feel I would get the responses I needed as directly, and I decided not to use tours as not all the children were confident communicators and they may have found this difficult. I wanted to be as inclusive as possible and ensure the technique was age and development appropriate. Therefore I chose to gather documentation by enabling the children to use cameras to take photos outdoors of what they liked and didn’t like. To ensure confidentiality of the photos taken I kept them in my private locked filing cabinet that only myself and my manager had access to. As my research required the children’s perceptions this technique ensured it was child led as were the later discussion where we came together in a quiet area to talk about why they took their particular images. This discussion enabled me to interpret what they were trying to say to me through the photos. As we looked at the photos it prompted their memory of why they had taken the picture. It was an interactive way to engage the children, and by the children taking their own photos helped lead theShow MoreRelatedReflective Account of ....10187 Words   |  41 PagesApart from that I can analyze to my knowledge, skills and practice as regards in infection control and can displays the credibility of medical personnel in implementing the tasks entrust by MOH. Reflective account is selected option for exploration of this dissertation. In my opinion with reflective account I can find the strength and weaknesses of this problem which may be critical to reflect the situation at that time. The effect of this reflection will provide a change in practice to apply variousRead MoreREFLECTIVE ACCOUNT4916 Words   |  20 Pages REFLECTIVE ACCOUNT. Unit 1- 1.1, 1.2-This is a reflective account of the things I have done, experience and knowledge I have gained throughout the assessor s course mainly during the process of assessment. First, I would like to describe the definition of assessment, its key concepts, stages to show the knowledge and understanding I have gained throughout the courseRead MoreReflective Account.3366 Words   |  14 PagesINTRODUCTION For this assignment I will be writing a reflective account which will identify a significant episode of care in which I had been involved with, by identifying the pathophysiology and the disease process for the chosen patient; this will be presented by giving a brief outline of the psychosocial influences of the illness for the patient and others who may have been involved with the care. I will also reflect upon this episode by using a reflective model and examining the nursing process, usingRead MoreReflective Account2596 Words   |  11 PagesREFLECTIVE ACCOUNT UNIT 6 ROLE OF A HEALTH AND SOCIAL CARE WORKER AT 7.15AM I CLOCK IN AND TAKE MY COAT AND BAG OFF AND LOCK THEM IN MY LOCKER SO I AM READY TO START MY SHIFT STRAIGHT AWAY, EVEN THOUGH I SOMETIMES SOCIALISE WITH SOME OF THE STAFF I WORK WITH I ENSURE I AM IN THE RIGHT FRAME OF MIND TO WORD PROFFESIONALLY WITH THEM AND NOT PERSONALLY SO THAT WE ARE ABLE TO WORK AS PART OF A TEAM AND ARE ABLE TO DO THE JOBS THAT WE ARE EMPLOYED TO DO, THEN I WILL WALK INTO THE DINING ROOMRead MoreReflective Account Proforma1988 Words   |  8 PagesReflective account Subject title TDA 3.4 LO 5 AC 5.1 5.2 Reflective account support children with behavioural needs Complete a reflective account showing your own practice where you have done the following Demonstrate ways of supporting children and young people to review their behaviour and the impact of this on others, themselves and their environment. Include evidence of your actual practice using the past tense | When children fall out and say mean things to each other I alwaysRead MoreReflective Account Essay1420 Words   |  6 PagesReflective Account Moving handling One day I was ask to transfer Mrs X from bed into wheelchair. Mrs X is paralised so to transfer her a full body hoist is needed. I had to call for help, it wouldn’t be safe to do this by myself. So while I was waiting for the other carer to arrive I have explained to Mrs X what and how we are going to do it. I have also cheked the hoist and battery if its fully charged and operational. I put right size sling on Mrs X with her cooperation. I carefullyRead MoreReflective Account. for Communication1382 Words   |  6 PagesReflective Account On an occasion at work I was aware of a staff member communicating very negatively, for example sighing and tutting and general negativity. Supervision was due so it was brought into meeting that last had concerned had noticed a change in the person’s general attitude, I asked if there was a specific reason and was told there was not. Although they agreed that they were being negative. We discussed the workload and it was decided it was not that. It was mentioned by the staffRead MoreReflective Account - nursing2646 Words   |  11 PagesRETURN TO NURSING PRACTICE REFLECTIVE LOG MODULE LEADER: STUDENT NUMBER: 1 INTRODUCTION This essay demonstrates the significant learning that resulted as a consequence of using critical reflection on my practice. The reflective process helped me to realise how my practice needed to change after I experienced a personal and practice-related issue during and after my clinical placement. Reflective practice is an important component of allRead MoreReflective Account on Learning2907 Words   |  12 PagesReflection: More than just looking in the mirror Â…reflection in a mirror is an exact replica of what is in front of it. Reflection in professional practiceÂ… gives back not what it is, but what might be, an improvement on the originalÂ… Biggs (1999). Reflective practice, in this context, is not about just looking at myself in a mirror and accepting what I see blindly, without any question or evaluation. Rather, it is about looking at what I have learned and how I can utilise that learning in my teachingRead MoreReflective Account Unit 5231477 Words   |  4 Pagesï » ¿ Reflective Account Level 5 Diploma Health and Social Care Candidate Name: Unit Title: 523 Manage induction processes for health and social care or children and young people’s settings Reflective Account Assessor Use Only- Assessment Criteria Met Candidate to provide narrative under each statement of how they meet the criteria and list the number of the piece(s) of evidence supplied to demonstrate this. (See also possible examples of evidence sheet). You must provide answers to each question

Liability of Company and Corporate Veil †Myassignmenthelp.Com

Question: Discuss About the Liability of Company and Corporate Veil? Answer: Introducation The investors who take risk to form a company usually have the guarantee the risk of debts and any liability usually will fall own the company because it is a separate legal entity and can sue and be sued in its own capacity. However, it bears noting that some investors such as is the case of Australian Careers Institute and the Sage Institute of Fitness, abuse the limited liability principle and the concept separate legal personality. The following two legal issues will apply to the Sage Institute of Fitness case study. Limited Liability of Company and Corporate Veil The concept of limited liability was established in the leading case of Salomon v Salomon Co Ltd[1] introduced the idea of separate legal personality of a company. Ideally, separate legal personality connotes that a company has a separate legal persona form the members of the company, the shareholders and the directors who have invested in it. [2] Under Australia law the principle of separate legal personality of a company has been provided under section 124 of Corporations Act 2001. In the case of Lee v Lees Air Farming Ltd[3] it was held that a company by having separate legal personality liability of the company is limited. Limited liability of a company means that the shareholders and directors are not liable in case any debts arise.[4] This implies that the shareholders have the assurance that they are protected from the effects of bankruptcy rules and insolvency during winding up of a company.[5] Because of the separate legal personality and limited liability of the company th e corporate veil is created which shields the shareholders of the company. However, the veil of incorporations may be lifted by the court if the company has is a sham and does not conduct the business it claims to in its article of association. Therefore, it has been held in Atlas Maritime Co SA v Avalon Maritime Ltd (No 1)[6] that when the veil of incorporation is lifted the shareholders of the company become personally liable for the debts of the company. The veil may also be lifted to prevent fraud or where the company formed is a sham and was merely intended to escape contractual or legal liability.[7] The principle lifting the corporate veil will help to prevent the mischief of the beneficial owners of Australian Careers Institute and Sage Institute of Fitness. The investors of the company will thus be personally liable for all the liabilities and debts which are being extended to the students and the stake holders. CompanyOfficer/Director Duties: Misleading and Deceptive Conduct Under section 180(1) of the corporation act the director has the duty to ensure that the care and due diligence that is expected of a reasonable person in his position.[8] These duties may also breached by the company officer who is regarded as any person who takes part in the decision making process of the company that in the end affects the entire business. In Lagunas Nitrate Co v Lagunas Syndicate[9] it was held that a director or company officer must act for the benefit of the company and that which is reasonable within his power after exercising his knowledge. According to section s1041H (1) a director or any company officer has the legal obligation to avoid practicing misleading and deceptive conduct during trade or any financial activity.[10] The main reason behind the sanction imposed by the duties given on directors is to protect investors of the corporation. As a matter of course, section 12DA of the Australian Securities Investment Commission Act prohibits any person from doing an act that is misleading or deceiving or is likely to do so while pursuing a financial activity. Based on the fact that this duty arises to persons dealing with a corporation or any business transaction it therefore means that the rule also applies to directors. It was noted in the case of Taco Bell of Australia Inc. v Taco Bell Pty Ltd,[11] that the information that is said by the director must actually be have a misleading and deceptive effect on the audience that the information targets. The audience that is being targeted by the representation must make a reasonable assumption that is not withdrawn from fanciful assumption.[12] In Australian Competition and Consumer Commission v Singtel Optus Pty Ltd[13] the court decided that if the intention of a director was to deceive and mislead if the information did not attain the desired result, the director will still be liable. The directors Australian Careers Institute and Sage Institute of Fitness will thus be personally liable for engaging in misleading and deceptive conduct through making advertisements for services which did not meet the expectation of a reasonable consumer Negligence is traditionally a common law action which is brought against one who has acted or omitted to do that which is in the ordinary course of his obligation, mandated to do.[14] For an act or omission to amount to the tort of negligence a duty of care owed to the plaintiff, breached of the duty and harm must be proved to exist.[15] It is imperative to note that the concept of duty of care applies to negligent misstatements that may have been made by a professional without regard to the veracity of the statements. [16] The duty of care is created by reliance on professional advice and the defendant is usually liable for professional negligence. The issue in this case is whether Tina and Aristotle can bring a claim for negligent misstatement or professional negligence after relying on Professional advice from William a Financial adviser. Negligent Mistatement The concept of negligent misstatement and professional misstatement is primary illustrated in the case of Hedley Byrne Co Ltd v Heller and Partners Ltd[17] which affirmed that a person is liable for a negligent misstatement if another party relied on the professional advice that has been given. However, in Byrne the court held if a disclaimer if given during the process of giving the advice one may, the defendant may be excluded from liability for negligent misstatement. Today, section 951A states that a disclaimer given during financial advise is void and is not effective.[18] The relationship between common law duty of care and negligent misstatement was given meaning in Caparo Industries plc. v Dickman[19] in which the court held that the person that is rendering advice must comprehend the significance of the advice and must know that the other party will not rely on any other independent advice. In Mutual Life and Citizens' Assurance Co Ltd v Evatt[20] the High Court of Australi a established that negligent misstatements does not only apply to people who are traditionally regarded as professionals but it also extends but even to non professionals provided the essential elements of negligence have been proved. Conversly, in the case of Shaddock Associates Pty Ltd Anor v Parramatta City Council[21] the court ruled that a person who makes statements which are reasonably relied upon by another individual has a duty to ensure that the advice given entails correct information. It is apparent that the test applied in negligent misstatement or advise is that; the maker of statements must know that the other party trusts him, the advice or information passed must be of serious business value and it was reasonably expected that the other party would rely on the information. In Ali v Hartley Poynton Limited[22] the plaintiff was an elderly woman who relied on financial advise given by a stoke broker. The court held that the defendant was liable for negligent misstat ement because he failed to conduct due diligence and proper analysis and did not disclose the risk of taking the investments. The remedy sought in an action for is one of recovery of loss for pure economic or financial loss that has been suffered due to reliance on the information that has been give. [23] It bears noting that the defendant in an action for negligence misstatement may lean on the defense of Vonlentis non fit injuria by asserting that the claimant solely relied on independent advice and thereby voluntary invited the financial injury to himself. Misleading Conduct Pursuant to section 12DA(1) of the Australian Securities and Investments Commission Act[24] any person who takes part in any trade or commerce is not allowed to perpetrate misleading or deceptive conduct. It bears noting that misleading or deceptive conduct also includes representations or an omission to disclose important information. The Corporation Act also echoes similar sentiments by absolutely prohibiting misleading and deceptive conduct during the process of trade or commerce.[25] Misleading and deceptive conduct can be referred to unconscionable conduct in trade and commerce because it is unreasonable and is an utterly display of ignorance. It thus goes without saying that ignorance of the law is not a defense in trade or commerce. The duty to avoid misleading and deceptive conduct to people who are expected to give advise or information because of there special possession of a skill or knowledge. In the case of ASIC v Accounts Control Management Services Pty Ltd[26] it was r uled that people should avoid unfair business practices that put other people at risk. In this sense professional advise must be given with due regards to all duties and obligation expected from a n ordinary professional. It has been held in the case of Wardley Australia Ltd v Western Australia[27] that in an action for misleading and deceptive conduct the complainant has the remedy of damages for loss suffered although an action may not be brought until loss has occurred. It thus follows that where the misleading and deceptive conduct is an omission to give adequate financial advice, am action will only be valid if there is proof of financial loss or damages. Application It is advised to Tina and Aristotle the financial advise that was given by William amounts to negligent misstatement. This is because their relationship with William was founded on the concept of duty of care where they trusted the information that was given to them and actually relied on it. Additionally, by applying the tenets of Ali v Hartley Poynton Limited[28] William neither revealed the risks that were involved in pursuing the investment option nor did he exercise due diligence before giving the information. It is instructive to note that the defense of volentis non fit inujria will be defeated because Tina and Aristotle did not rely on any independent advice. Ideally, William will be liable for negligent misstatement and will be compelled by the court to pay full amount of pure financial loss that Tina and Aristotle suffered. Tina and Aristotle must also evince that they have suffered damage for them to bring an action of misleading and deceptive conduct pursuant to the Austr alian Securities and Investments Commission Act. Williams conduct amount to a misleading and deceptive conduct because he failed to give important information which should ordinary be submitted it course of his practice. Conclusion It can be conceded that Tina and Aristotle have a strong claim of negligent misstatement or professional negligence against William. On the other hand, they can claim the financial suffered provided they all prove all the essential legal elements required in an action for negligent misstatement. References Article and Books Cathy S. Krendl, et al., Piercing The Corporate Veil: Focusing The Inquiry, Denver Law Journal 1 (Vol. 55, No. 1, 1978) Gonzalo Villalta, A Two-Edged Sword: Salomon and the Separate Legal Entity Doctrine, Murdoch University Electronic Journal of Law 2000 William J. Reader, Versatility Unlimited: Reflections on the History and Nature of the Limited Liability Company, in Tony Orhnial, Ed., Limited Liability and the Corporation 191 (Croom Helm, London Canberra, 1982). Ali v Hartley Poynton Limited[2002] VSC 113 - 20 ACLC 1006 ASIC v Accounts Control Management Services Pty Ltd [2012] FCA 1164 ASIC v Macdonald (No 11) [2009] NSWSC 287 AstraZeneca v GSK [2006] ATPR Atlas Maritime Co SA v Avalon Maritime Ltd (No 1) [1991] 4 All ER 769 Australian Competition and Consumer Commission v Singtel Optus Pty Ltd (2010) 276 ALR 102 Blyth v Birmingham Waterworks Company (1856) 11 Ex Ch 781 Caparo Industries plc. v Dickman (1990) 2 AC 605 Grant v The Australian Knitting Mills [1935] UKPC 2, [1936] A.C. 562 Hedley Byrne Co Ltd v Heller and Partners Ltd [1964] AC 465 Lee v Lees Air Farming Ltd (1961) AC 12 Mutual Life and Citizens' Assurance Co Ltd v Evatt [1968] HCA 74 Salomon v Salomon Co Ltd [1897] AC 22, 48 San Sebastian Pty Ltd v Minister Administering the Environmental Planning and Assessment Act 1979 (NSW) (1988) 162 CLR 340 Shaddock Associates Pty Ltd Anor v Parramatta City Council (1981) 150 CLR 225 Sharrment Pty Ltd v Official Trustee in Bankruptcy (1988) 82 ALR 530 Taco Bell of Australia Inc. v Taco Bell Pty Ltd (1982) 42 ALR 177 Turner v Garland and Christopher (1853) cited in Hudson's Building Contracts (4th ed., 1914) Vol. 2, p. 1 Wardley Australia Ltd v Western Australia (1992) 175 CLR 514 Legislation Australian Securities and Investments Commission Act 2001 (cth) Corporations Act 2001(cth [1] [1897] AC 22, 48 [2] Gonzalo Villalta, A Two-Edged Sword: Salomon and the Separate Legal Entity Doctrine, Murdoch University Electronic Journal of Law 2000 [3] [1961] AC 12 [4] Cathy S. Krendl, et al., Piercing The Corporate Veil: Focusing The Inquiry, Denver Law Journal 1 (Vol. 55, No. 1, 1978) [5] William J. Reader, Versatility Unlimited: Reflections on the History and Nature of the Limited Liability Company, in Tony Orhnial, Ed., Limited Liability and the Corporation 191 (Croom Helm, London Canberra, 1982). [6] [1991] 4 All ER 769 [7] Sharrment Pty Ltd v Official Trustee in Bankruptcy (1988) 82 ALR 530 [8] ASIC v Macdonald (No 11) [2009] NSWSC 287 [9] [1899] 2 Ch. 392 [10] Corporations Act 2001(cth) [11] (1982) 42 ALR 177 [12] AstraZeneca v GSK [2006] ATPR [13] (2010) 276 ALR 102 [14] Blyth v Birmingham Waterworks Company (1856) 11 Ex Ch 781 [15] Grant v The Australian Knitting Mills [1935] UKPC 2, [1936] A.C. 562 [16] Turner v Garland and Christopher (1853) cited in Hudson's Building Contracts (4th ed., 1914) Vol. 2, p. 1 [17] [1964] AC 465 [18] Corporations Act 2001(cth) [19] (1990) 2 AC 605 [20] [1968] HCA 74 [21] (1981) 150 CLR 225 [22] [2002] VSC 113 - 20 ACLC 1006 [23] San Sebastian Pty Ltd v Minister Administering the Environmental Planning and Assessment Act 1979 (NSW) (1988) 162 CLR 340 [24] 2001 (cth) [25] Section 1041H of the Corporations Act 2001 [26] [2012] FCA 1164 [27] (1992) 175 CLR 514 [28] [2002] VSC 113 - 20 ACLC 1006