Observational studies of low-frequency oscillations in the Southern Hemisphere

This work examines 40-50 day fluctuations in the Southern Hemisphere middle and high latitudes. The existence of these fluctuations are established in rawinsonde data at Easter Island (27°S, 109°W) and in global geopotential heights fields. These fluctuations behave as quasi-stationary wavetrains that propagate energy along an elliptical path from low latitudes in the Indian Ocean to the coast of Antarctica, near 70°W. The wavetrains exhibit vertical phase tilts from the surface to about 500 mb; above that, they are vertically in phase. However, the wavetrains are not observed in the middle and upper stratosphere. Over the Indian Ocean, there is also evidence suggesting that the wavetrains interact with the tropical 40-50 day oscillation. In addition, the extratropical 40-50 day fluctuations extract energy from the mean zonal flow through baroclinic processes but lose energy to the mean zonal flow through barotropic processes;The results revealed here increase the understanding of the global 40-50 day phenomena and may provide an important effect in the evolution of the tropical 40-50 day oscillation

CURIOSITIES OF STANDING IN TRADE SECRET LAW

Standing under the Uniform Trade Secrets Act – the right to pursue a misappropriation claim – is a vexing question when compared to patent, copyright, and trademark law. Instead of requiring ownership or license rights as a condition to sue, courts often find that mere possession of an asserted trade secret suffices for standing, even when the provenance of the information is murky. In some cases, courts even allow trade secret plaintiffs to claim intellectual property rights in the preferences and desires expressed to them by their customers in lawsuits designed to stop former employees from doing business with those same customers. Relaxed requirements for trade secret standing under the UTSA can weaken the showing needed to establish a valid trade secret. For example, a plaintiff with only mere possession may not always be able to account for the history of the information it possesses – but it would nonetheless be permitted to proceed even though the defendant cannot challenge whether reasonable security measures were always used to guard the information in the past. Dubious claims based on preferences expressed by customers could be transformed into intellectual property for the sole purpose of blocking an alternative supplier whom the very same customers may prefer. In the worst instances, loose standing rules centered on mere possession could encourage parties to claim rights over types of information to which trade secret law should never extend, such as workplace injury data and personal attributes of employees. This article explores how courts in trade secret cases have come to apply standing rules that are more permissive than those seen in other areas of intellectual property law. It concludes that some courts remain confused about whether trade secret claims are property rights or instead something closer to broader, looser restrictive covenants. This conceptual confusion results in questionable standing decisions inconsistent with the statutory elements of a trade secret claim and, more broadly, the goals of intellectual property law. Much of the conundrum results from a poorly-reasoned 2001 Fourth Circuit decision on trade secret standing. It offered a patina of suspect theory regarding what it styled the “inherent nature” of trade secret law and undercut a property-centered conception of trade secret law, and proposed that mere possession could suffice to assert a claim. Many courts addressing state law trade secret disputes in the last two decades have followed this decision, sometimes expressly adopting its vision of trade secret law as a relational doctrine rather than an intellectual property doctrine. This is the first comprehensive article on trade secret standing, and the first to probe the dangers posed when requirements for trade secret standing are relaxed. It will isolate the philosophy behind questionable rulings which deviate from the property-centered requirements of the UTSA. This article will also explore whether a mere-possession rule of trade secret standing undermines the requirement that a plaintiff prove that reasonable security measures were used to safeguard the information. We will explore whether allowing trade secret claims in the preferences and desires expressed by customers should be analyzed as a question of standing to best protect departing employees as well as robust market competition. The article will question whether the problematic conception of trade secret law seen in many standing cases could open the door to nontraditional trade secret claims which threaten important public policy interests. In the end, we will conclude with solutions that courts can effect without legislative change

Productivity of Huntington, Waynesboro, and Dickson soils for corn

The objectives of the study were outlined to the local agricultural workers before any farmers were contacted. Names of possible cooperators were obtained. When this system proved unfruitful, fields were located by driving through the county. When one of the soil types that had been in corn in 1957 or that might be planted in corn in 1958 was observed the farmer was contacted and his cooperation was solicited

Questioning the Employee Non-solicitation Covenant

Based on an in-depth review of the dubious justifications courts have offered when enforcing co-worker non-solicitation covenants, this Article proposes that courts have too strongly favored employers against their former employees in such disputes. A co-worker non-solicitation covenant is a contract term that prohibits a departing employee, for some period of time, from inviting his or her former co-workers to join him or her at a new job—or from encouraging a former co-worker to leave the company for any other reason. Some are worded so broadly that one could breach the contract by advising a colleague to leave a hostile or harassing workplace, or to seek higher pay. These covenants are ubiquitous in private sector employment agreements, at all income levels and occupations. They are frequently litigated, often alongside trade secret misappropriation claims. Courts often find violations based on communications with former co-workers. Despite that ubiquity, co-worker non-solicitation covenants receive scant attention. Court rulings see little in the way of sustained analysis. Notwithstanding the wave of academic and legislative attention paid to employee non-competition covenants in recent years, the co-worker non-solicitation clause remains an afterthought. This should change. Courts and commentators have overlooked how employers use co-worker non-solicitation covenants as a means to avoid giving employees raises or promotions, and to avoid improving workplace conditions. Employers’ litigation arguments that such covenants protect trade secrets, protect a company’s goodwill with its customers, or protect a supposedly “stable” workforce do not withstand critical scrutiny. These covenants operate first and foremost as salary suppression devices, not as an adjunct to trade secret law. To understand how these covenants came to exist, this Article explores the long history of restrictions on hiring employees. Rather than a contract term that arose in response to contemporary workplace needs, the co-worker non-solicitation covenant is instead an anachronistic remnant of the paternalistic workspaces of late medieval England and otherwise forgotten labor control mechanisms from long ago. Next, this Article offers the first comprehensive review of nationwide case law in this area, critiquing four common arguments employers offer for enforceability. Then, building on the insights of a small number of courts that have pushed back against such justifications, this Article proposes that courts reframe their adjudication of co-worker non-solicitation covenants. Courts should reject efforts to view these covenants as a category of trade secret law, and should reject other threadbare justifications. They should instead ask why employees want to leave the company, including whether better pay was available elsewhere, and they should examine the company’s attrition rates. By viewing disputes from the employee’s perspective and not just the employer’s perspective, and by considering broader empirical evidence of workplace conditions, courts can inject overdue skepticism

COMMERCIAL SWEETPOTATO PRODUCTION IN MISSISSIPPI

This report provides an estimate of selected costs incurred in sweetpotato production in Mississippi, 1999. Land, management and general farm overhead costs were not included. Per acre returns above specified costs are estimated at approximately $1,100.00 per acre.sweetpotatoes, production costs, net returns, cash flow, price sensitivity, equipment, chemicals, Production Economics,