The Act of State Doctrine and its Exceptions: An Introduction

The act of state doctrine poses a serious obstacle for plaintiffs seeking redress in United States courts for wrongful public acts by a recognized foreign sovereign within its own territory. Depending on the circumstances, however, various exceptions to the Doctrine may be invoked. This article is intended to be a brief introduction to the Doctrine and its exceptions and a survey of recent cases in which the Doctrine was construed by United States courts. The present inquiry into the nature and scope of the doctrine begins with the seminal case, Underhill v. Hernandez ... Almost all of the early case law around which the doctrine developed involved situations in which plaintiff was asserting the wrongful taking of property by revolutionary governments or military officials in the midst of political turmoil. The net effect of these decisions was to establish a rule that expropriation, nationalization, or confiscation of property by a foreign government (either before or after the taking) would be recognized by United States courts. The modern restatement of this rule and the current foundation for development of most act of state doctrine case law is found in Banco Nacional de Cuba v. Sabbatino

Hybrid computer Monte-Carlo techniques

Hybrid analog-digital computer systems for Monte Carlo method application

Complete chloroplast genome sequence of Holoparasite Cistanche Deserticola (Orobanchaceae) reveals gene loss and horizontal gene transfer from Its host Haloxylon Ammodendron (Chenopodiaceae)

The central function of chloroplasts is to carry out photosynthesis, and its gene content and structure are highly conserved across land plants. Parasitic plants, which have reduced photosynthetic ability, suffer gene losses from the chloroplast (cp) genome accompanied by the relaxation of selective constraints. Compared with the rapid rise in the number of cp genome sequences of photosynthetic organisms, there are limited data sets from parasitic plants. The authors report the complete sequence of the cp genome of Cistanche deserticola, a holoparasitic desert species belonging to the family Orobanchaceae

‘Snakes and Ladders’ – ‘Therapy’ as Liberation in Nagarjuna and Wittgenstein’s Tractatus

This paper reconsiders the notion that Nagarjuna and Wittgenstein’s Tractatus may only be seen as comparable under a shared ineffability thesis, that is, the idea that reality is impossible to describe in sensible discourse. Historically, Nagarjuna and the early Wittgenstein have both been widely construed as offering either metaphysical theories or attempts to refute all such theories. Instead, by employing an interpretive framework based on a ‘resolute’ reading of the Tractatus, I suggest we see their philosophical affinity in terms of a shared conception of philosophical method without proposing theses. In doing so, this offers us a new way to understand Nagarjuna’s characteristic claims both to have ‘no views’ (Mūlamadhyamakakārikā 13.8 and 27.30) and refusal to accept that things exist ‘inherently’ or with ‘essence’ (svabhāva). Therefore, instead of either a view about the nature of a mind-independent ‘ultimate reality’ or a thesis concerning the rejection of such a domain, I propose that we understand Nagarjuna’s primary aim as ‘therapeutic’, that is, concerned with the dissolution of philosophical problems. However, this ‘therapy’ should neither be confined to the psychotherapeutic metaphor nor should it be taken to imply a private enlightenment only available to philosophers. Instead, for Nagarjuna and Wittgenstein, philosophical problems are cast as a source of disquiet for all of us; what their work offers is a soteriology, a means towards our salvation

Gene duplication and phenotypic changes in the evolution of Mammalian metabolic networks

Metabolic networks attempt to describe the complete suite of biochemical reactions available to an organism. One notable feature of these networks in mammals is the large number of distinct proteins that catalyze the same reaction. While the existence of these isoenzymes has long been known, their evolutionary significance is still unclear. Using a phylogenetically-aware comparative genomics approach, we infer enzyme orthology networks for sixteen mammals as well as for their common ancestors. We find that the pattern of isoenzymes copy-number alterations (CNAs) in these networks is suggestive of natural selection acting on the retention of certain gene duplications. When further analyzing these data with a machine-learning approach, we found that that the pattern of CNAs is also predictive of several important phenotypic traits, including milk composition and geographic range. Integrating tools from network analyses, phylogenetics and comparative genomics both allows the prediction of phenotypes from genetic data and represents a means of unifying distinct biological disciplines

Infant Safety during and after Maternal Valacyclovir Therapy in Conjunction with Antiretroviral HIV-1 Prophylaxis in a Randomized Clinical Trial

<div><h3>Background</h3><p>Maternal administration of the acyclovir prodrug valacyclovir is compatible with pregnancy and breastfeeding. However, the safety profile of prolonged infant and maternal exposure to acyclovir in the context of antiretrovirals (ARVs) for prevention of mother-to-child HIV-1 transmission (PMTCT) has not been described.</p> <h3>Methods</h3><p>Pregnant Kenyan women co-infected with HIV-1/HSV-2 with CD4 counts > 250 cells/mm³ were enrolled at 34 weeks gestation and randomized to twice daily 500 mg valacyclovir or placebo until 12 months postpartum. Women received zidovudine from 28 weeks gestation and single dose nevirapine was given to women and infants at the time of delivery for PMTCT. Infant blood was collected at 6 weeks for creatinine and ALT. Breast milk specimens were collected at 2 weeks postpartum from 71 women in the valacyclovir arm; acyclovir levels were determined for a random sample of 44 (62%) specimens. Fisher’s Exact and Wilcoxon rank-sum tests were used for analysis.</p> <h3>Results</h3><p>One hundred forty-eight women were randomized and 146 mother-infant pairs were followed postpartum. PMTCT ARVs were administered to 98% of infants and all mothers. Valacyclovir was not associated with infant or maternal toxicities or adverse events, and no congenital malformations were observed. Infant creatinine levels were all normal (< 0.83 mg/dl) and median creatinine (median 0.50 mg/dl) and infant growth did not differ between study arms. Acyclovir was detected in 35 (80%) of 44 breast milk samples collected at 2 weeks postpartum. Median and maximum acyclovir levels were 2.62 and 10.15 mg/ml, respectively (interquartile range 0.6–4.19).</p> <h3>Conclusions</h3><p>Exposure to PMTCT ARVs and acyclovir after maternal administration of valacyclovir during pregnancy and postpartum to women co-infected with HIV-1/HSV-2 was not associated with an increase in infant or maternal toxicities or adverse events.</p> <h3>Trial Registration</h3><p>ClinicalTrials.gov <a href="http://clinicaltrials.gov/ct2/show/NCT00530777">NCT00530777</a></p> </div

Dynamics of soil organic carbon following land-use change: insights from stable C-isotope analysis in black soil of Northeast China

Intensive soil tillage is a significant factor in soil organic matter decline in cultivated soils. Both cultivation abandonment and foregoing tillage have been encouraged in the past 30 years to reduce greenhouse gas emissions and soil erosion. However, the dynamic processes of soil organic carbon (SOC) in areas of either continuous cultivation or abandonment remain unclear and inconsistent. Our aims were to assess and model the dynamic processes of SOC under continuous tillage and after cultivation abandonment in the black soil of Northeast China. Soil profiles were collected of cultivated or abandoned land with cultivation history of 0–100 years. An isotope mass balance equation was used to calculate the proportion of SOC derived from corn debris (C4) and from natural vegetation (C3) to deduce the dynamic process. Approximately 40% of SOC in the natural surface soil (0–10 cm) was eroded in the first 5 years of cultivation, increasing to about 75% within 40 years, before a slow recovery. C4 above 30 cm soil depth increased by 4.5%–5% or 0.11–0.12 g·kg−1 on average per year under continuous cultivation, while it decreased by approximately 0.34% annually in the surface soil after cultivation abandonment. The increase in the percentage of C4 was fitted to a linear equation with given intercepts in the upper 30 cm of soil in cultivated land. A significant relationship between the change of C4 and time was found only in the surface soil after abandonment of cultivation. These results demonstrate the loss and accumulation of corn-derived SOC in surface black soil of Northeast China under continuous tillage or cultivation abandonment

“Positive” Results Increase Down the Hierarchy of the Sciences

The hypothesis of a Hierarchy of the Sciences with physical sciences at the top, social sciences at the bottom, and biological sciences in-between is nearly 200 years old. This order is intuitive and reflected in many features of academic life, but whether it reflects the “hardness” of scientific research—i.e., the extent to which research questions and results are determined by data and theories as opposed to non-cognitive factors—is controversial. This study analysed 2434 papers published in all disciplines and that declared to have tested a hypothesis. It was determined how many papers reported a “positive” (full or partial) or “negative” support for the tested hypothesis. If the hierarchy hypothesis is correct, then researchers in “softer” sciences should have fewer constraints to their conscious and unconscious biases, and therefore report more positive outcomes. Results confirmed the predictions at all levels considered: discipline, domain and methodology broadly defined. Controlling for observed differences between pure and applied disciplines, and between papers testing one or several hypotheses, the odds of reporting a positive result were around 5 times higher among papers in the disciplines of Psychology and Psychiatry and Economics and Business compared to Space Science, 2.3 times higher in the domain of social sciences compared to the physical sciences, and 3.4 times higher in studies applying behavioural and social methodologies on people compared to physical and chemical studies on non-biological material. In all comparisons, biological studies had intermediate values. These results suggest that the nature of hypotheses tested and the logical and methodological rigour employed to test them vary systematically across disciplines and fields, depending on the complexity of the subject matter and possibly other factors (e.g., a field's level of historical and/or intellectual development). On the other hand, these results support the scientific status of the social sciences against claims that they are completely subjective, by showing that, when they adopt a scientific approach to discovery, they differ from the natural sciences only by a matter of degree

Molecular evolution of a chordate specific family of G protein-coupled receptors

<p>Abstract</p> <p>Background</p> <p>Chordate evolution is a history of innovations that is marked by physical and behavioral specializations, which led to the development of a variety of forms from a single ancestral group. Among other important characteristics, vertebrates obtained a well developed brain, anterior sensory structures, a closed circulatory system and gills or lungs as blood oxygenation systems. The duplication of pre-existing genes had profound evolutionary implications for the developmental complexity in vertebrates, since mutations modifying the function of a duplicated protein can lead to novel functions, improving the evolutionary success.</p> <p>Results</p> <p>We analyzed here the evolution of the GPRC5 family of G protein-coupled receptors by comprehensive similarity searches and found that the receptors are only present in chordates and that the size of the receptor family expanded, likely due to genome duplication events in the early history of vertebrate evolution. We propose that a single GPRC5 receptor coding gene originated in a stem chordate ancestor and gave rise by duplication events to a gene family comprising three receptor types (GPRC5A-C) in vertebrates, and a fourth homologue present only in mammals (GPRC5D). Additional duplications of GPRC5B and GPRC5C sequences occurred in teleost fishes. The finding that the expression patterns of the receptors are evolutionarily conserved indicates an important biological function of these receptors. Moreover, we found that expression of GPRC5B is regulated by vitamin A <it>in vivo</it>, confirming previous findings that linked receptor expression to retinoic acid levels in tumor cell lines and strengthening the link between the receptor expression and the development of a complex nervous system in chordates, known to be dependent on retinoic acid signaling.</p> <p>Conclusions</p> <p>GPRC5 receptors, a class of G protein-coupled receptors with unique sequence characteristics, may represent a molecular novelty that helped non-chordates to become chordates.</p

Attachment and Entry of Chlamydia Have Distinct Requirements for Host Protein Disulfide Isomerase

Chlamydia is an obligate intracellular pathogen that causes a wide range of diseases in humans. Attachment and entry are key processes in infectivity and subsequent pathogenesis of Chlamydia, yet the mechanisms governing these interactions are unknown. It was recently shown that a cell line, CHO6, that is resistant to attachment, and thus infectivity, of multiple Chlamydia species has a defect in protein disulfide isomerase (PDI) N–terminal signal sequence processing. Ectopic expression of PDI in CHO6 cells led to restoration of Chlamydia attachment and infectivity; however, the mechanism leading to this recovery was not ascertained. To advance our understanding of the role of PDI in Chlamydia infection, we used RNA interference to establish that cellular PDI is essential for bacterial attachment to cells, making PDI the only host protein identified as necessary for attachment of multiple species of Chlamydia. Genetic complementation and PDI-specific inhibitors were used to determine that cell surface PDI enzymatic activity is required for bacterial entry into cells, but enzymatic function was not required for bacterial attachment. We further determined that it is a PDI-mediated reduction at the cell surface that triggers bacterial uptake. While PDI is necessary for Chlamydia attachment to cells, the bacteria do not appear to utilize plasma membrane–associated PDI as a receptor, suggesting that Chlamydia binds a cell surface protein that requires structural association with PDI. Our findings demonstrate that PDI has two essential and independent roles in the process of chlamydial infectivity: it is structurally required for chlamydial attachment, and the thiol-mediated oxido-reductive function of PDI is necessary for entry