Chain, Chain, Chain—Chain of (Pharma) Fools: Why Third Party Payors Maintain the Proximate Causal Chain Under RICO § 1964(C)

On December 3, 2019, the U.S. Court of Appeals for the Ninth Circuit in Painters & Allied Trades District Council 82 Health Care Fund v. Takeda Pharmaceuticals Co. held that Third Party Payors (TPPs) may satisfy proximate causation in civil Racketeer Influenced and Corrupt Organizations Act (RICO) claims against pharmaceutical companies where they claim that, but for the pharmaceutical company’s failure to indicate a drug’s cancer-causing risk, they would not have incurred expenditures for the drug. In doing so, the Ninth Circuit joined the U.S. Courts of Appeals for the First and Third Circuits and split from the U.S. Courts of Appeals for the Second and Seventh Circuits as to whether TPPs are too far removed from pharmaceutical companies’ alleged fraud to satisfy RICO’s proximate cause requirement. This Comment argues that the Ninth Circuit was correct in concluding that TPPs may properly allege proximate cause, as its approach effectively followed Supreme Court precedent. It further argues that, as a matter of policy, proximate cause should not be allowed to shield pharmaceutical companies from the damages they inflict on TPPs and the healthcare system at large through their fraudulent drug promotion schemes

Quinine blocks 5-HT and 5-HT3 receptor mediated peristalsis in both guinea pig and mouse ileum tissue

Introduction. Quinine is commonly used to treat malaria; however one of the principal side effects is gastrointestinal disturbances (White, 1992). 5-HT3 receptors modulate gut peristalsis (Chetty et al., 2006), and, as quinine has been shown to act as a 5-HT3 receptor antagonist (Thompson and Lummis, 2008) it is possible that these side effects result from actions at gut 5-HT3 receptors. To address this question, we examined the ability of quinine to antagonise 5-HT and 5-HT3 mediated peristalsis in guinea pig and mouse ileum. Methods. Ileum was excised from male guinea pigs (200-300g) and C57BL/6 mice (25-35g) following cervical dislocation. Ileum segments (3-5 cm) were mounted in 50 ml organ baths containing Tryode’s solution at 35-37 °C. Concentration-response curves were constructed for 5-HT and the selective 5-HT3 agonist 2-Me-5-HT (non-cumulative doses). Quinine was pre-applied for 10 min and inhibition measured using agonist concentrations that elicited a submaximal response. Results. Concentration-dependent contractions produced by 5-HT (pEC50 = 5.45 ± 0.17, n = 8) and the selective 5-HT3 agonist 2-Me-5-HT (5.01 ± 0.17, n = 11) were not significantly different (Student’s t-test, t = 0.619, df = 17, p = 0.544) in guinea pig ileum. Increasing concentrations of quinine were able to antagonise the activities of both 5-HT (pIC50 = 5.03 ± 0.2, n = 6) and 2-Me-5HT (pIC50 = 4.59 ± 0.26, n = 4). At mouse ileum, 5-HT (pEC50 = 7.57 ± 0.33, n = 9) was more potent (Student’s t-test, t = 3.6, df = 12, p = 0.004) than 2-Me-5-HT (pEC50 = 5.45 ± 0.58, n = 5). Quinine antagonised both the 5-HT (pIC50 = 4.87 ± 0.31, n = 7) and 2-Me-5-HT-induced (pIC50 = 6.18 ± 1.14, n = 4) contractions. Conclusions. These results support previous electrophysiological studies that identified quinine as an antagonist at recombinant 5-HT3 receptors with IC50 values comparable with those reported here (pIC50 = 4.87, Thompson et al., 2007). Further, we found that quinine completely blocked 5-HT induced contractions in mouse and guinea pig, raising the possibility that quinine targets other 5-HT receptors in the gut (e.g., 5-HT4 receptors) and may influence intestinal function

Gender and the Climate Crisis: Equitable Solutions for Climate Plans

The effects of rising greenhouse gas emissions are more harmful to women, gender diverse people, and Black, Indigenous and people of color, although these communities contribute less to climate change. This underscores the need to include gender frameworks and gender diverse voices from communities of color into climate action planning.The Center for Biological Diversity sought to learn if gender and solutions related to gender were included in municipal climate plans. Twenty-one climate plans from cities across the United States were analyzed for this report, representing approximately 10% of the U.S. population (30,492,353). The plans were reviewed for the frequency of inclusion of each of the following topics: consumption, education, family planning/contraception/reproductive health, gender, human population/population growth/growth, public health/pollutants and vulnerable populations.The report analyzes gender-based solutions in municipal climate plans and provides practical policy recommendations for stakeholders to enhance their plans with mitigation and adaptation efforts based on gender empowerment and social justice. Gender empowerment initiatives include universal access to voluntary modern family planning methods (e.g. the oral contraceptive pill, long-acting reversible contraception, condoms and emergency contraception); LGBTQIA+ inclusive, culturally responsive and medically accurate comprehensive sexual education; and affordable sexual and reproductive healthcare that allows individuals to have agency and autonomy over their bodies. Additional solutions include supporting educational opportunities, redefining gender roles, creating equitable opportunities for women and LGBTQIA+ individuals, and guaranteeing safety from harassment and violence

Lower Extremity Passive Range of Motion in Community-Ambulating Stroke Survivors

Background: Physical therapists may prescribe stretching exercises for individuals with stroke to improve joint integrity and to reduce the risk of secondary musculoskeletal impairment. While deficits in passive range of motion (PROM) exist in stroke survivors with severe hemiparesis and spasticity, the extent to which impaired lower extremity PROM occurs in community-ambulating stroke survivors remains unclear. This study compared lower extremity PROM in able-bodied individuals and independent community-ambulatory stroke survivors with residual stroke-related neuromuscular impairments. Our hypothesis was that the stroke group would show decreased lower extremity PROM in the paretic but not the nonparetic side and that decreased PROM would be associated with increased muscle stiffness and decreased muscle length. Methods: Individuals with chronic poststroke hemiparesis who reported the ability to ambulate independently in the community (n = 17) and age-matched control subjects (n = 15) participated. PROM during slow (5 degrees/sec) hip extension, hip flexion, and ankle dorsiflexion was examined bilaterally using a dynamometer that measured joint position and torque. The maximum angular position of the joint (ANGmax), torque required to achieve ANGmax (Tmax), and mean joint stiffness (K) were measured. Comparisons were made between able-bodied and paretic and able-bodied and nonparetic limbs. Results: Contrary to our expectations, between-group differences in ANGmax were observed only during hip extension in which ANGmax was greater bilaterally in people post-stroke compared to control subjects (P ≤ 0.05; stroke = 13 degrees, able-bodied = −1 degree). Tmax, but not K, was also significantly higher during passive hip extension in paretic and nonparetic limbs compared to control limbs (P ≤ 0.05; stroke = 40 Nm, able-bodied = 29 Nm). Compared to the control group, Tmax was increased during hip flexion in the paretic and nonparetic limbs of post-stroke subjects (P ≤ 0.05, stroke = 25 Nm, able-bodied = 18 Nm). K in the nonparetic leg was also increased during hip flexion (P ≤ 0.05, nonparetic = 0.52 Nm/degree, able-bodied = 0.37 Nm/degree.) Conclusion: This study demonstrates that community-ambulating stroke survivors with residual neuromuscular impairments do not have decreased lower extremity PROM caused by increased muscle stiffness or decreased muscle length. In fact, the population of stroke survivors examined here appears to have more hip extension PROM than age-matched able-bodied individuals. The clinical implications of these data are important and suggest that lower extremity PROM may not interfere with mobility in community-ambulating stroke survivors. Hence, physical therapists may choose to recommend activities other than stretching exercises for stroke survivors who are or will become independent community ambulators

A laser probe ⁴⁰Ar /³⁹Ar and INAA investigation of four Apollo granulitic breccias

Infrared laser probe 40Ar/39Ar geochronology, instrumental neutron activation analysis (INAA) and analytical electron microscopy have been performed on four 0.5 x 1.0 x 0.3 cm polished rock tiles of Apollo 16 and 17 granulitic breccias (60035, 77017, 78155, and 79215). Pyroxene thermometry indicates that these samples were re-equilibrated and underwent peak metamorphic sub-solidus recrystallization at 1000 – 1100°C, which resulted in homogeneous mineral compositions and granoblastic textures. 40Ar/39Ar data from this study reveal that three samples (60035, 77017, and 78155) have peak metamorphic ages of ~4.1 Ga. Sample 79215 has a peak metamorphic age of 3.9 Ga, which may be related to Serenitatis basin formation. All four samples contain moderately high concentrations of meteoritic siderophiles. Enhanced siderophile contents in three of the samples provide evidence for projectile contamination of their target lithologies occurring prior to peak metamorphism. Post-peak metamorphism, low-temperature (<300ºC) events caused the partial resetting of argon in the two finer-grained granulites (60035 and 77017). These later events did not alter the mineralogy or texture of the rocks, but caused minor brecciation and the partial release of argon from plagioclase. Interpretation of the low-temperature data indicates partial resetting of the argon systematics to as young as 3.2 Ga for 60035 and 2.3 Ga for 77017. Cosmic ray exposure ages range from 6.4 to ~339 Ma. Our results increase the amount of high-precision data available for the granulitic breccias and lunar highlands crustal samples. The results demonstrate the survival of pre-Nectarian material on the lunar surface and document the effects of contact metamorphic and impact processes during the pre-Nectarian Epoch, as well as the low-temperature partial resetting of ages by smaller impact events after 3.9 Ga. The mineralogy and chemical composition of these rocks, as well as exhumation constraints, indicate that the source of heat for metamorphism was within kilometres of the surface via burial beneath impact melt sheets or hot ejecta blankets

Supermassive Black-hole Demographics & Environments With Pulsar Timing Arrays

Precision timing of large arrays (>50) of millisecond pulsars will detect the nanohertz gravitational-wave emission from supermassive binary black holes within the next ~3-7 years. We review the scientific opportunities of these detections, the requirements for success, and the synergies with electromagnetic instruments operating in the 2020s.Comment: Submitted to the Astro2020 Decadal Survey. One of 5 core white-papers authored by members of the NANOGrav Collaboration. 9 pages, 2 figure

Observation of centimetre-scale argon diffusion in alkali feldspars: implications for ⁴⁰Ar/³⁹Ar thermochronology

New data from a gem-quality feldspar from Itrongay, Madagascar, record naturally occurring 40Ar/39Ar age profiles which can be numerically modelled by invoking a single diffusion mechanism and show that microtexturally simple crystals are capable of recording complex thermal histories. We present the longest directly measured, naturally produced 40Ar*-closure profiles from a single, homogeneous orthoclase feldspar. These data appear to confirm the assumption that laboratory derived diffusion parameters are valid in nature and over geological timescales. Diffusion domains are defined by crystal faces and ancient cracks, thus in gem-quality feldspars the diffusion domain size equates to the physical grain size. The data also illustrate the potential of large, gem-quality feldspars to record detailed thermal histories over tens of millions of years and such samples should be considered for future studies on the slow cooling of continental crust

The Oneida County 4-H Conservation Field Days Conflict

In its 30-year history, New York\u27s Oneida County 4-H Conservation Education Field Days program generated no known controversy. That trend changed radically when a citizens group shot undercover video footage portraying the event as children being brainwashed into thinking guns, hunting and trapping are okay. The video aired statewide and resulted in a national controversy. Oneida County 4-H responded by trying to build consensus among the organizations involved, but discovered that this was not possible. This article relates the events that precipitated this conflict, and examines the various perspectives on the conflict held by the three major organizations involved

Laying the Groundwork for a Trail at Breton Preserve with Androscoggin Land Trust

Public access to the coastal, mountainous and historic hotspots is one of the reasons Maine’s population is increasing. These natural areas are threatened by land turnover and human development, forcing government funded conservation programs, local land trusts, and nationwide privately held conservation groups to take action. Throughout cities in Maine, there is a push for more public outdoor areas providing further recreational opportunities to facilitate holistic and educated relationships with the land. For these reasons, the Androscoggin Land Trust (ALT) has identified a need for a multi-use trail along the Androscoggin River at the Breton Preserve in Lisbon, Maine. To accomplish this goal, the ALT is hoping to apply for grant funding from the Recreational Trail Program (RTP). In this report, we include a proposed trail route in the form of a GIS map, a budget spreadsheet with infrastructure and construction costs, answers to grant application questions regarding the importance and feasibility of the trail route, and research on the indigenous, colonial and land ownership history of the property In order to propose a trail, four trail determinants were established to meet ALT’s goals: the desired trail aspects, points of interest, identifying route based on paths of least resistance, and indicating infrastructure required based on the paths chosen. Based on these determinants, two potential trail routes were proposed: the optimal route that portrays a greater variety of ecological features on the property, and the secondary route that is shorter in length and follows existing logging roads. While we propose the primary trail to the ALT, the secondary option would be more cost efficient. Both options include an ADA accessible portion of the trail with access to the Androscoggin River. We created a virtual Story Map of both route options, including a map tour of the infrastructure and points of interest along with a portion of our historical research meant for the Informational Kiosk at the entrance of the trail. The intention for the Story Map is to help promote the trail, help visualize both route options and provide a virtual experience of the property. The budget spreadsheet, containing the costs of infrastructure, construction, design, and labor, emphasizes the cost differences between the two proposed trails based on the length, additional infrastructure and construction. With the GIS maps, budget spreadsheet, application questions, and research for the kiosk provided, we hope to position the Androscoggin Land Trust with the framework to apply for RTP grant fundin

Tourism, Cinema and TV Series Conference

A day conference on Tourism, Cinema and TV Series was held at the University of Lille on Friday 12th October 2018. Speakers from a variety of institutions in France and the UK presented their work in this field, creating a transnational discussion on the impact of cinema and TV tourism. This event was organised by Nathalie Dupont, Laetitia Garcia and Raphael Eppreh-Butet, who successfully put together a bilingual programme. During the welcome address, attendees were encouraged to consider the..