The \u3ci\u3eQuid Pro Quo Quark\u3c/i\u3e: Unstable Elementary Particle of Honest Services Fraud

From 1946 to 1987, the federal mail fraud statute, 18 U.S.C. § 1341, was a powerful tool for the prosecution of political corruption. In a line of decisions beginning with the Fifth Circuit’s in Shushan v. United States, and ending with the Supreme Court’s decision in McNally v. United States, courts upheld the use of the statute to prosecute officials who had deprived the public of its “intangible right” to the official’s “honest services.” In 1988, after the Supreme Court held this theory unconstitutionally vague in McNally, Congress enacted § 1346, intending to restore “honest services fraud” doctrine to its pre-McNally expanse. Yet in the 2010 case of Skilling v. United States, the Supreme Court narrowed 18 U.S.C. § 1346 to prohibit only the “core” of honest services fraud: bribery and kickback schemes. This Comment argues that, in reining in honest services fraud in the Skilling decision to bribery and kickbacks, the Supreme Court left open a fundamental question at the heart of honest services fraud: whether and to what extent prosecution under that law requires proof of a “quid pro quo.” This Comment argues that the Third Circuit’s “stream of benefits” theory of bribery strikes the right balance between the vagueness problems that the court addressed in McNally and Skilling, and Congress’s intent to cast a wide net to fight political corruption in enacting § 1346

The \u3ci\u3eQuid Pro Quo Quark\u3c/i\u3e: Unstable Elementary Particle of Honest Services Fraud

From 1946 to 1987, the federal mail fraud statute, 18 U.S.C. § 1341, was a powerful tool for the prosecution of political corruption. In a line of decisions beginning with the Fifth Circuit’s in Shushan v. United States, and ending with the Supreme Court’s decision in McNally v. United States, courts upheld the use of the statute to prosecute officials who had deprived the public of its “intangible right” to the official’s “honest services.” In 1988, after the Supreme Court held this theory unconstitutionally vague in McNally, Congress enacted § 1346, intending to restore “honest services fraud” doctrine to its pre-McNally expanse. Yet in the 2010 case of Skilling v. United States, the Supreme Court narrowed 18 U.S.C. § 1346 to prohibit only the “core” of honest services fraud: bribery and kickback schemes. This Comment argues that, in reining in honest services fraud in the Skilling decision to bribery and kickbacks, the Supreme Court left open a fundamental question at the heart of honest services fraud: whether and to what extent prosecution under that law requires proof of a “quid pro quo.” This Comment argues that the Third Circuit’s “stream of benefits” theory of bribery strikes the right balance between the vagueness problems that the court addressed in McNally and Skilling, and Congress’s intent to cast a wide net to fight political corruption in enacting § 1346

Resist materials for 157-nm microlithography: an update

Fluorocarbon polymers and siloxane-based polymers have been identified as promising resist candidates for 157 nm material design because of their relatively high transparency at this wavelength. This paper reports our recent progress toward developing 157 nm resist materials based on the first of these two polymer systems. In addition to the 2-hydroxyhexafluoropropyl group, (alpha) -trifluoromethyl carboxylic acids have been identified as surprisingly transparent acidic functional groups. Polymers based on these groups have been prepared and preliminary imaging studies at 157 nm are described. 2-Trifluoromethyl-bicyclo[2,2,1] heptane-2-carboxylic acid methyl ester derived from methyl 2-(trifluoromethyl)acrylate was also prepared and gas-phase VUV measurements showed substantially improved transparency over norbornane. This appears to be a general characteristic of norbornane-bearing geminal electron-withdrawing substituents on the 2 carbon bridge. Unfortunately, neither the NiII nor PdII catalysts polymerize these transparent norbornene monomers by vinyl addition. However, several new approaches to incorporating these transparent monomers into functional polymers have been investigated. The first involved the synthesis of tricyclononene (TCN) monomers that move the bulky electron withdrawing groups further away from the site of addition. The hydrogenated geminally substituted TCN monomer still has far better transparency at 157 nm than norbornane. The second approach involved copolymerizing the norbornene monomers with carbon monoxide. The third approach involved free-radical polymerization of norbornene monomers with tetrafluoroethylene and/or other electron-deficient comonomers. All these approaches provided new materials with encouraging absorbance at 157 nm. The lithographic performance of some of these polymers is discussed

Miniature exoplanet radial velocity array I: design, commissioning, and early photometric results

The MINiature Exoplanet Radial Velocity Array (MINERVA) is a US-based observational facility dedicated to the discovery and characterization of exoplanets around a nearby sample of bright stars. MINERVA employs a robotic array of four 0.7 m telescopes outfitted for both high-resolution spec- troscopy and photometry, and is designed for completely autonomous operation. The primary science program is a dedicated radial velocity survey and the secondary science objective is to obtain high precision transit light curves. The modular design of the facility and the flexibility of our hardware allows for both science programs to be pursued simultaneously, while the robotic control software provides a robust and efficient means to carry out nightly observations. In this article, we describe the design of MINERVA including major hardware components, software, and science goals. The telescopes and photometry cameras are characterized at our test facility on the Caltech campus in Pasadena, CA, and their on-sky performance is validated. New observations from our test facility demonstrate sub-mmag photometric precision of one of our radial velocity survey targets, and we present new transit observations and fits of WASP-52b—a known hot-Jupiter with an inflated radius and misaligned orbit. The process of relocating the MINERVA hardware to its final destination at the Fred Lawrence Whipple Observatory in southern Arizona has begun, and science operations are expected to commence within 2015

Modulation of the virus-receptor interaction by mutations in the V5 loop of feline immunodeficiency virus (FIV) following in vivo escape from neutralising antibody

<b>BACKGROUND:</b> In the acute phase of infection with feline immunodeficiency virus (FIV), the virus targets activated CD4+ T cells by utilising CD134 (OX40) as a primary attachment receptor and CXCR4 as a co-receptor. The nature of the virus-receptor interaction varies between isolates; strains such as GL8 and CPGammer recognise a "complex" determinant on CD134 formed by cysteine-rich domains (CRDs) 1 and 2 of the molecule while strains such as PPR and B2542 require a more "simple" determinant comprising CRD1 only for infection. These differences in receptor recognition manifest as variations in sensitivity to receptor antagonists. In this study, we ask whether the nature of the virus-receptor interaction evolves in vivo.<p></p> <b>RESULTS:</b> Following infection with a homogeneous viral population derived from a pathogenic molecular clone, a quasispecies emerged comprising variants with distinct sensitivities to neutralising antibody and displaying evidence of conversion from a "complex" to a "simple" interaction with CD134. Escape from neutralising antibody was mediated primarily by length and sequence polymorphisms in the V5 region of Env, and these alterations in V5 modulated the virus-receptor interaction as indicated by altered sensitivities to antagonism by both anti-CD134 antibody and soluble CD134.<p></p> <b>CONCLUSIONS:</b> The FIV-receptor interaction evolves under the selective pressure of the host humoral immune response, and the V5 loop contributes to the virus-receptor interaction. Our data are consistent with a model whereby viruses with distinct biological properties are present in early versus late infection and with a shift from a "complex" to a "simple" interaction with CD134 with time post-infection.<p></p&gt

Changes in the Optic Nerve Head and Choroid Over 1 Year of Spaceflight

Importance: While 6-month data are available regarding spaceflight-associated neuro-ocular syndrome, manned missions for 1 year and beyond are planned, warranting evaluation for spaceflight-associated neuro-ocular syndrome beyond 6 months. Objective: To determine if the manifestation of spaceflight-associated neuro-ocular syndrome worsens during International Space Station missions exceeding the present 4- to 6-month duration. Design, Setting, and Participants: The One-Year Mission Study used quantitative imaging modalities to investigate changes in ocular structure in 2 crew members who completed a 1-year-long spaceflight mission. This study investigated the ocular structure of crew members before, during, and after their mission on the International Space Station. Two crew members participated in this study from March 2015 to September 2016. Analysis began in March 2015 and ended in May 2020. Exposures: Crew members were tested before, during, and up to 1 year after spaceflight. Main Outcomes and Measures: This study compares ocular changes (peripapillary retinal edema, axial length, anterior chamber depth, and refraction) in two 1-year spaceflight mission crew members with cohort crew members from a 6-month mission (n = 11). Minimum rim width (the shortest distance between Bruch membrane opening and the internal limiting membrane) and peripapillary total retinal thickness were measured using optical coherence tomography. Results: Both crew members were men. Minimum rim width and total retinal thickness increased in both participants throughout the duration of spaceflight exposure to the maximal observed change from preflight (minimum rim width: participant 1, 561 [+149 from preflight] μm at flight day 270; participant 2, 539 [+56 from preflight] μm at flight day 270; total retinal thickness: participant 1, 547 [+135 from preflight] μm at flight day 90; participant 2, 528 [+45 from preflight] μm at flight day 210). Changes in peripapillary choroid engorgement, axial length, and anterior chamber depth appeared similar between the 1-year mission participants and a 6-month mission cohort. Conclusions and Relevance: This report documents the late development of mild optic disc edema in 1 crew member and the progressive development of choroidal folds and optic disc edema in another crew member over the duration of 1 year in low Earth orbit aboard the International Space Station. Previous reports characterized the ocular risk associated with 4 to 6 months of spaceflight. As future spaceflight missions are planned to increase in duration and extend beyond low Earth orbit, further observation of astronaut ocular health on spaceflight missions longer than 6 months in duration may be warranted

Metal-Catalyzed Addition Polymers for 157 nm Resist Applications. Synthesis and Polymerization of Partially Fluorinated, Ester-Functionalized Tricyclo[4.2.1.0_(2,5)]non-7-enes

Fluorinated tricyclo[4.2.1.0^(2,5)]non-7-ene-3-carboxylic acid esters are shown to undergo metal-catalyzed addition polymerization. The resulting homopolymers are transparent at 157 nm and demonstrate the utility of these monomers in development of photoresists for 157 nm lithography. Fluorinated tricyclononene (TCN) structures with ester substituents exhibit up to 3 orders of magnitude more transparency at 157 nm than conventional ester-functionalized norbornene structures as determined by gas-phase vacuum-ultraviolet spectroscopy and variable angle spectroscopic ellipsometry. Unlike their fluorinated norbornene counterparts, the fluorinated, ester-functionalized TCN monomers successfully undergo transition-metal-catalyzed addition polymerization to produce polymers with high glass transition temperatures and the etch resistance required for photolithographic resist materials applications. The potential use of fluorinated TCN structures for 157 nm photoresists is demonstrated through the synthesis and characterization of TCN monomers and polymers