A Further Note on Federal Causes of Action

In the article, I argue that federal causes of action ought to be treated as (1) distinct from substantive rights, (2) synonymous with the availability of a remedy (but not whether a remedy will in fact issue) and (3) distinct from subject matter jurisdiction (unless Congress instructs otherwise). This thesis is built principally on a historical recounting of the cause of action from eighteenth century England to twenty-first century America. In taking an historical approach, I did not mean to argue that federal courts are bound to adhere to centuries-old conceptions of the cause of action. I merely used history to show why the cause of action has taken on various identities and, further, why these identities have changed over time. By closely attending to these changes, we can better determine whether linguistic changes signal substantive changes in doctrine, or are simply loose language

NMR Evidence for Specific Germanium Siting in IM-12 Zeolite

SSCI-VIDE+ING+NKS:ATUInternational audienceGe-rich ITQ-13 and ITQ-22 zeolites were degermanated by acid leaching of as-made still containing organic template and calcined forms. These two zeolites could be almost completely degermanated without modifying the framework structure. This behavior is different from IM-12 zeolite, which undergoes framework transformation from UTL to OKO type upon degermanation. All three zeolite types contain double four-ring (D4R) units populated by germanium atoms. The UTL to OKO transformation involves the elimination of Germanate 4 rings (Ge 4R) from double four-ring (D4R) units connecting the layers. The differences of Si and Ge atom siting in D4R units in the three zeolites were probed using F-19 MAS NMR after post synthetic incorporation of fluoride and H-1-Si-29 CP/MAS NMR. In IM-12, NMR suggests that Ge atoms are all located in one of the faces of D4R units and form 4Rs that connect Si-rich layers together. In the degermanation process, the 4 Ge atoms of the Ge 4Rs are dislodged simultaneously, in excellent agreement with earlier EXAFS data. In ITQ-13 and ITQ-22 zeolites, Ge distributions are more complex, leading a progressive degermanation of the framework and to the presence of Si-O-Si bridges that prevents the structure from collapsing upon Ge extraction. Data suggest that IM-12 is unique in the family of Ge-containing zeolites