Friends, Followers, Connections, Lend Me Your Ears: A New Test for Determining the Sufficiency of Service of Process Via Social Media

The emergence of social media as a driving force in modern society has brought it to the forefront of legal discussion in all areas of law. Fields of study such as evidence, ethics, and constitutional law are all currently wrestling with how social media ought to be handled. In particular, courts have attempted to determine whether service of process (or simply “service”) should be satisfied by the use of communication through social media. Since 1950, courts have relied upon the same test, regardless of the method used, to determine the sufficiency of service: the Mullane test. Mullane as currently applied, however, does not sufficiently scrutinize service via social media in a manner conducive to understanding the peculiarities of this method of communication. This Comment will not attempt to determine whether the use of social media to effect service of process is constitutional. Rather, it will show how the current application of the Mullane standard leads courts to categorically accept or reject service as effected, and, therefore, a new test ought to be adopted to measure the individual social media communication method used to attempt service. This test ought to be utilized to determine whether a particular use of a specific social media platform has fulfilled the constitutional requirements for service, vis-à-vis Mullane. This Comment will begin by examining the standard for sufficient service of process established by the Supreme Court in Mullane, followed by the cases expanding that decision; in particular Greene v. Lindsey, Mennonite Board of Missions v. Adams, and Jones v. Flowers. This Comment will also survey the technological advancements that have affected courts’ determinations regarding service. It will then observe how foreign courts have treated issues of electronic service, as well as review the development of this issue in the United States. Finally, this Comment will scrutinize current methods of service, propose a new test that courts ought to use to determine the sufficiency of service effected via social media, and compare the test’s advantages to the current test

Friends, Followers, Connections, Lend Me Your Ears: A New Test for Determining the Sufficiency of Service of Process Via Social Media

The emergence of social media as a driving force in modern society has brought it to the forefront of legal discussion in all areas of law. Fields of study such as evidence, ethics, and constitutional law are all currently wrestling with how social media ought to be handled. In particular, courts have attempted to determine whether service of process (or simply “service”) should be satisfied by the use of communication through social media. Since 1950, courts have relied upon the same test, regardless of the method used, to determine the sufficiency of service: the Mullane test. Mullane as currently applied, however, does not sufficiently scrutinize service via social media in a manner conducive to understanding the peculiarities of this method of communication. This Comment will not attempt to determine whether the use of social media to effect service of process is constitutional. Rather, it will show how the current application of the Mullane standard leads courts to categorically accept or reject service as effected, and, therefore, a new test ought to be adopted to measure the individual social media communication method used to attempt service. This test ought to be utilized to determine whether a particular use of a specific social media platform has fulfilled the constitutional requirements for service, vis-à-vis Mullane. This Comment will begin by examining the standard for sufficient service of process established by the Supreme Court in Mullane, followed by the cases expanding that decision; in particular Greene v. Lindsey, Mennonite Board of Missions v. Adams, and Jones v. Flowers. This Comment will also survey the technological advancements that have affected courts’ determinations regarding service. It will then observe how foreign courts have treated issues of electronic service, as well as review the development of this issue in the United States. Finally, this Comment will scrutinize current methods of service, propose a new test that courts ought to use to determine the sufficiency of service effected via social media, and compare the test’s advantages to the current test

Oncogenic gene expression and epigenetic remodeling of cis-regulatory elements in ASXL1-mutant chronic myelomonocytic leukemia

Myeloid neoplasms are clonal hematopoietic stem cell disorders driven by the sequential acquisition of recurrent genetic lesions. Truncating mutations in the chromatin remodeler ASXL1 (ASXL1MT) are associated with a high-risk disease phenotype with increased proliferation, epigenetic therapeutic resistance, and poor survival outcomes. We performed a multi-omics interrogation to define gene expression and chromatin remodeling associated with ASXL1MT in chronic myelomonocytic leukemia (CMML). ASXL1MT are associated with a loss of repressive histone methylation and increase in permissive histone methylation and acetylation in promoter regions. ASXL1MT are further associated with de novo accessibility of distal enhancers binding ETS transcription factors, targeting important leukemogenic driver genes. Chromatin remodeling of promoters and enhancers is strongly associated with gene expression and heterogenous among overexpressed genes. These results provide a comprehensive map of the transcriptome and chromatin landscape of ASXL1MT CMML, forming an important framework for the development of novel therapeutic strategies targeting oncogenic cis interactions

Focal CA3 hippocampal subfield atrophy following LGI1 VGKC-complex antibody limbic encephalitis

Magnetic resonance imaging has linked chronic voltage-gated potassium channel (VGKC) complex antibody-mediated limbic encephalitis with generalized hippocampal atrophy. However, autoantibodies bind to specific rodent hippocampal subfields. Here, human hippocampal subfield (subiculum, cornu ammonis 1-3, and dentate gyrus) targets of immunomodulation-treated LGI1 VGKC-complex antibody-mediated limbic encephalitis were investigated using in vivo ultra-high resolution (0.39 x 0.39 x 1.0 mm³) 7.0T magnetic resonance imaging [n = 18 patients, 17 patients (94%) positive for LGI1 antibody and one patient negative for LGI1/CASPR2 but positive for VGKC-complex antibodies, mean age: 64.0 ± 2.55 years, median 4 years post-limbic encephalitis onset; n = 18 controls]. First, hippocampal subfield quantitative morphometry indicated significant volume loss confined to bilateral CA3 [F(1,34) = 16.87, P 3 months from symptom onset) were associated with CA3 atrophy. Third, whole-brain voxel-by-voxel morphometry revealed no significant grey matter loss. Fourth, CA3 subfield atrophy was associated with severe episodic but not semantic amnesia for postmorbid autobiographical events that was predicted by variability in CA3 volume. The results raise important questions about the links with histopathology, the impact of the observed focal atrophy on other CA3-mediated reconstructive and episodic mechanisms, and the role of potential antibody-mediated pathogenicity as part of the pathophysiology cascade in humans

Pathogen Recognition Receptor Signaling Accelerates Phosphorylation-Dependent Degradation of IFNAR1

An ability to sense pathogens by a number of specialized cell types including the dendritic cells plays a central role in host's defenses. Activation of these cells through the stimulation of the pathogen-recognition receptors induces the production of a number of cytokines including Type I interferons (IFNs) that mediate the diverse mechanisms of innate immunity. Type I IFNs interact with the Type I IFN receptor, composed of IFNAR1 and IFNAR2 chains, to mount the host defense responses. However, at the same time, Type I IFNs elicit potent anti-proliferative and pro-apoptotic effects that could be detrimental for IFN-producing cells. Here, we report that the activation of p38 kinase in response to pathogen-recognition receptors stimulation results in a series of phosphorylation events within the IFNAR1 chain of the Type I IFN receptor. This phosphorylation promotes IFNAR1 ubiquitination and accelerates the proteolytic turnover of this receptor leading to an attenuation of Type I IFN signaling and the protection of activated dendritic cells from the cytotoxic effects of autocrine or paracrine Type I IFN. In this paper we discuss a potential role of this mechanism in regulating the processes of innate immunity

Plant species composition alters the sign and strength of an emergent multi-predator effect by modifying predator foraging behaviour

The prediction of pest-control functioning by multi-predator communities is hindered by the non-additive nature of species functioning. Such non-additivity, commonly termed an emergent multi-predator effect, is known to be affected by elements of the ecological context, such as the structure and composition of vegetation, in addition to the traits of the predators themselves. Here we report mesocosm experiments designed to test the influence of plant density and species composition (wheat monoculture or wheat and faba bean polyculture) on the emergence of multi-predator effects between Adalia bipunctata and Chrysoperla carnea, in their suppression of populations of the aphid Metopolophium dirhodum. The mesocosm experiments were followed by a series of behavioural observations designed to identify how interactions among predators are modified by plant species composition and whether these effects are consistent with the observed influence of plant species composition on aphid population suppression. Although plant density was shown to have no influence on the multi-predator effect on aphid population growth, plant composition had a marked effect. In wheat monoculture, Adalia and Chrysoperla mixed treatments caused greater suppression of M. dirhodum populations than expected. However this positive emergent effect was reversed to a negative multi-predator effect in wheat and faba bean polyculture. The behavioural observations revealed that although dominant individuals did not respond to the presence of faba bean plants, the behaviour of sub-dominants was affected markedly, consistent with their foraging for extra-floral nectar produced by the faba bean. This interaction between plant composition and predator community composition on the foraging behaviour of sub-dominants is thought to underlie the observed effect of plant composition on the multi-predator effect. Thus, the emergence of multi-predator effects is shown to be strongly influenced by plant species composition, mediated, in this case, by the provision of extra-floral nectar by one of the plant species

LAT1 activity of carboxylic acid bioisosteres: Evaluation of hydroxamic acids as substrates.

Large neutral amino acid transporter 1 (LAT1) is a solute carrier protein located primarily in the blood-brain barrier (BBB) that offers the potential to deliver drugs to the brain. It is also up-regulated in cancer cells, as part of a tumor's increased metabolic demands. Previously, amino acid prodrugs have been shown to be transported by LAT1. Carboxylic acid bioisosteres may afford prodrugs with an altered physicochemical and pharmacokinetic profile than those derived from natural amino acids, allowing for higher brain or tumor levels of drug and/or lower toxicity. The effect of replacing phenylalanine's carboxylic acid with a tetrazole, acylsulfonamide and hydroxamic acid (HA) bioisostere was examined. Compounds were tested for their ability to be LAT1 substrates using both cis-inhibition and trans-stimulation cell assays. As HA-Phe demonstrated weak substrate activity, its structure-activity relationship (SAR) was further explored by synthesis and testing of HA derivatives of other LAT1 amino acid substrates (i.e., Tyr, Leu, Ile, and Met). The potential for a false positive in the trans-stimulation assay caused by parent amino acid was evaluated by conducting compound stability experiments for both HA-Leu and the corresponding methyl ester derivative. We concluded that HA's are transported by LAT1. In addition, our results lend support to a recent account that amino acid esters are LAT1 substrates, and that hydrogen bonding may be as important as charge for interaction with the transporter binding site