The Doctrine In The Shadows: Reverse-Erie, Its Cases, Its Theories, And Its Future With Plausibility Pleading In Alaska

In 2007 and 2009, respectively, the United States Supreme Court decided Bell Atlantic Corp. v. Twombly and Ashcroft v. Iqbal, abrogated Conley v. Gibson’s notice pleading standard, and imposed a new plausibility pleading standard upon the federal court system. Alaska, along with a majority of states however, still retains Conley’s “no set of facts” notice pleading standard. This Note asks, in light of the difference between the federal and Alaska pleading standards, whether Alaska—or any state—could be forced to apply the federal pleading standard when it adjudicates federal substantive claims. Prior to Iqbal, a plaintiff in Alaska would have faced the same pleading obligations in state and federal court regardless of whether he pleaded a state or federal claim. As this Note describes, now, a plaintiff could face different pleading standards depending on not only where he brings his claim, but also, if he’s in state court, whether he brings a state or federal claim. The reason for this is the Reverse-Erie doctrine: an little-developed judicial choice of law theory that broadly asks which procedure, federal or state, applies in a state court proceeding. Using the differences between federal and state pleading standards as an opportunity to flesh out Reverse-Erie, this Note concludes that while it is unlikely that the Supreme Court would force a state to adopt the federal pleading standard, the jurisprudential framework for such a move exists

Huber, Marper and Others: Throwing new light on the shadows of suspicion. INEX Policy Brief No. 8, June 2010

The proliferation of large-scale databases containing personal information, and the multiple uses to which they can be put, can be highly problematic from the perspective of fundamental rights and freedoms. This paper discusses two landmark decisions that illustrate some of the risks linked to these developments and point to a better framing of such practices: the Heinz Huber v. Germany judgement, from the European Court of Justice, and the S. and Marper v. United Kingdom ruling, from the European Court of Human Rights. The paper synthesises the lessons to be learnt from such decisions. Additionally, it questions the impact of the logic of pure prevention that is being combined with other rationales in the design and management of databases. This Policy Brief is published in the context of the INEX project, which looks at converging and conflicting ethical values in the internal/external security continuum in Europe, and is funded by the Security Programme of DG Enterprise of the European Commission’s Seventh Framework Research Programme. For more information visit: www.inexproject.e

The Iray Light Transport Simulation and Rendering System

While ray tracing has become increasingly common and path tracing is well understood by now, a major challenge lies in crafting an easy-to-use and efficient system implementing these technologies. Following a purely physically-based paradigm while still allowing for artistic workflows, the Iray light transport simulation and rendering system allows for rendering complex scenes by the push of a button and thus makes accurate light transport simulation widely available. In this document we discuss the challenges and implementation choices that follow from our primary design decisions, demonstrating that such a rendering system can be made a practical, scalable, and efficient real-world application that has been adopted by various companies across many fields and is in use by many industry professionals today

Assessment of leaf cover and crop soil cover in weed harrowing research using digital images

Objective assessment of crop soil cover, defined as the percentage of leaf cover that has been buried in soil due to weed harrowing, is crucial to further progress in post-emergence weed harrowing research. Up to now, crop soil cover has been assessed by visual scores, which are biased and context dependent. The aim of this study was to investigate whether digital image analysis is a feasible method to estimate crop soil cover in the early growth stages of cereals. Two main questions were examined: (1) how to capture suitable digital images under field conditions with a standard high-resolution digital camera and (2) how to analyse the images with an automated digital image analysis procedure. The importance of light conditions, camera angle, size of recorded area, growth stage and direction of harrowing were investigated in order to establish a standard for image capture and an automated image analysis procedure based on the excess green colour index was developed. The study shows that the automated digital image analysis procedure provided reliable estimations of leaf cover, defined as the as the proportion of pixels in digital images determined to be green, which were used to estimate crop soil cover. A standard for image capture is suggested and it is recommended to use digital image analysis to estimated crop soil cover in future research. The prospects of using digital image analysis in future weed harrowing research are discussed

Selective rendering for efficient ray traced stereoscopic images

Depth-related visual effects are a key feature of many virtual environments. In stereo-based systems, the depth effect can be produced by delivering frames of disparate image pairs, while in monocular environments, the viewer has to extract this depth information from a single image by examining details such as perspective and shadows. This paper investigates via a number of psychophysical experiments, whether we can reduce computational effort and still achieve perceptually high-quality rendering for stereo imagery. We examined selectively rendering the image pairs by exploiting the fusing capability and depth perception underlying human stereo vision. In ray-tracing-based global illumination systems, a higher image resolution introduces more computation to the rendering process since many more rays need to be traced. We first investigated whether we could utilise the human binocular fusing ability and significantly reduce the resolution of one of the image pairs and yet retain a high perceptual quality under stereo viewing condition. Secondly, we evaluated subjects' performance on a specific visual task that required accurate depth perception. We found that subjects required far fewer rendered depth cues in the stereo viewing environment to perform the task well. Avoiding rendering these detailed cues saved significant computational time. In fact it was possible to achieve a better task performance in the stereo viewing condition at a combined rendering time for the image pairs less than that required for the single monocular image. The outcome of this study suggests that we can produce more efficient stereo images for depth-related visual tasks by selective rendering and exploiting inherent features of human stereo vision

Space time pixels

This paper reports the design of a networked system, the aim of which is to provide an intermediate virtual space that will establish a connection and support interaction between multiple participants in two distant physical spaces. The intention of the project is to explore the potential of the digital space to generate original social relationships between people that their current (spatial or social) position can difficultly allow the establishment of innovative connections. Furthermore, to explore if digital space can sustain, in time, low-level connections like these, by balancing between the two contradicting needs of communication and anonymity. The generated intermediate digital space is a dynamic reactive environment where time and space information of two physical places is superimposed to create a complex common ground where interaction can take place. It is a system that provides awareness of activity in a distant space through an abstract mutable virtual environment, which can be perceived in several different ways – varying from a simple dynamic background image to a common public space in the junction of two private spaces or to a fully opened window to the other space – according to the participants will. The thesis is that the creation of an intermediary environment that operates as an activity abstraction filter between several users, and selectively communicates information, could give significance to the ambient data that people unconsciously transmit to others when co-existing. It can therefore generate a new layer of connections and original interactivity patterns; in contrary to a straight-forward direct real video and sound system, that although it is functionally more feasible, it preserves the existing social constraints that limit interaction into predefined patterns