Affirming Firm Sanctions: The Authority to Sanction Law Firms Under 28 U.S.C. § 1927

A circuit split exists as to whether 28 U.S.C. § 1927 allows for an award of sanctions against nonattorneys or nonrepresentatives. Five federal courts of appeals—the Second, Third, Eighth, Eleventh, and the District of Columbia Circuits—hold that, to further the purpose of 28 U.S.C. § 1927, courts have the authority to sanction a law firm for the conduct of its attorneys, in addition to the authority to sanction individual officers of the court. The Sixth, Seventh, and Ninth Circuits disagree, concluding that the statute allows federal courts to sanction only individuals—“attorney[s] or other person[s] admitted to conduct cases in any court of the United States.” In In re MJS Las Croabas Properties, Inc., the U.S. Bankruptcy Appellate Panel of the First Circuit recently recognized this split of authority. The appellate panel discussed the text of § 1927 as well as policy considerations supporting its applicability to law firms. Although the panel noted that the statute does not expressly provide for vicarious liability, it nonetheless concluded that § 1927 implicitly allows for the imposition of sanctions against a law firm. This Note analyzes federal courts’ interpretations of § 1927 and argues that law firms ought to be within reach of the statute

Neural Modeling and Imaging of the Cortical Interactions Underlying Syllable Production

This paper describes a neural model of speech acquisition and production that accounts for a wide range of acoustic, kinematic, and neuroimaging data concerning the control of speech movements. The model is a neural network whose components correspond to regions of the cerebral cortex and cerebellum, including premotor, motor, auditory, and somatosensory cortical areas. Computer simulations of the model verify its ability to account for compensation to lip and jaw perturbations during speech. Specific anatomical locations of the model's components are estimated, and these estimates are used to simulate fMRI experiments of simple syllable production with and without jaw perturbations.National Institute on Deafness and Other Communication Disorders (R01 DC02852, RO1 DC01925

Pachystigmus Hellén, 1927 : a substitute name for Noserus Foerster, 1863 (Hymenoptera: Braconidae), not Noserus LeConte, 1862 (Coleoptera: Zopheridae)

By establishing the date of its first publication, Noserus Foerster, 1863 (Hymenoptera, Braconidae) is shown to be a junior primary homonym of Noserus LeConte, 1862 (Coleoptera, Zopheridae). The substitute name for Noserus Foerster is that of its subjective synonym, Pachystigmus Hellén, 1927 [type species: Pachystigmus nitidulus Hellén, 1927]. Other described species in the genus are: Pachystigmus facialis (Foerster, 1863) New Combination; P. similis (Szépligeti, 1896) New Combination, P. nitidulus Hellén, 1927, P. gigas (Tobias, 1964)New Combination, P. occipitalis (Belokobylskij, 1986) New Combination, P. olgensis (Belokobylskij, 1994) New Combination, and P. sculpturator (Belokobylskij, 1999) New Combination

The Crescent Student Newspaper, November 1, 1976

Student newspaper of Pacific College (later George Fox University). 4 pages, black and white.https://digitalcommons.georgefox.edu/the_crescent/1927/thumbnail.jp

Patent Clutter

Patent claims are supposed to clearly and succinctly describe the patented invention, and only the patented invention. This Article hypothesizes that a substantial amount of language in patent claims is in fact not about the core invention, which may contribute to well-documented problems with patent claims. I analyze the claims of 40,000 patents and applications, and document the proliferation of “clutter”—language in patent claims that is not about the invention. Although claims are supposed to be exclusively about the invention, clutter appears across industries and makes up approximately 25% of claim language. Patent clutter may contribute several major problems in patent law. Extensive clutter makes patent claims harder to search. Excessive language in patent claims may be the result of over-claiming—when patentees describe potential corollaries they do not possess—thereby making the patent so broad in scope as to be invalid. More generally, it strains the comprehensibility of patents and burdens the resources of patent examiners. After arguing that patent clutter may contribute to these various problems, this Article turns to reforms. Rejections based on prolix, lack of enablement, and lack of written description can be crafted to dispose of the worst offenders, and better algorithms and different litigation rules can allow the patent system to adapt (and even benefit from) the remaining uses of excess language. The Article additionally generates important theoretical insights. Claims are often thought of as entirely synonymous with the invention and all elements of the claim are thought to relate equally strongly to the invention. This Article suggests empirically that these assumptions do not hold in practice, and offers a framework for restructuring conceptions of the relationship between claims and the invention

Nearctic \u3ci\u3eAcleris\u3c/i\u3e: Resurrection of \u3ci\u3eA. Stadiana\u3c/i\u3e and a Revised Identity for \u3ci\u3eA. Semiannula\u3c/i\u3e (Lepidoptera: Tortricidae)

Type study showed that Acleris stadiana (Barnes & Busck), currently considered a junior synonym of A. semiannula (Robinson), is in fact a distinct taxon. Although superficially similar, these taxa differ markedly in genital structure. In males of A. semiannula, the aedeagus is short, broad, and virtually straight, whereas in those of A. stadiana, it is long, thin, and sharply bent. What was known in literature as A. semiannula proved to be A. stadi­ana. We redefine both A. semiannula and the resurrected A. stadiana

Credit constraints and the propagation of the Great Depression in Germany

We evaluate the role played by loan supply shocks in the decline of investment and industrial production during the Great Depression in Germany from 1927 to 1932. We identify loan supply shocks in the context of a time varying parameter vector autoregression with stochastic volatility. Our results indicate that credit constraints were a significant driver of industrial production between 1927 and 1932, supporting the view that a structurally weak banking sector was an important contributor to the German Great Depression. We find further that loan supply shocks were an important driver of investment in the early phase of the depression, between 1927 and 1929, but not between 1930 and 1932. We suggest possible explanations for this puzzle and directions for future research