Property Versus Antidiscrimination: Examining the Impacts of Cedar Point Nursery v. Hassid on the Fair Housing Act

The Fair Housing Act is a groundbreaking federal law enacted in 1968 during the civil rights movement. Reflecting a policy judgment that the public’s interest in eliminating housing discrimination outweighs a prejudicial landlord’s property right to exclude, it prohibits landlords from rejecting tenants on a discriminatory basis. However, as the Act’s promises remain in the process of fulfillment, the Supreme Court’s 2021 decision in Cedar Point Nursery v. Hassid has placed it into unprecedented danger: by holding that a regulation authorizing temporary occupations of private property constituted a per se taking that requires compensation under the Takings Clause, Cedar Point threatens the constitutionality of the Act, which grants tenants a similar temporary right to access rental properties. This Comment takes up the task of finding an escape valve for the Act within the current legal landscape. Looking to Cedar Point’s Court-created exceptions, this Comment argues that the Act should fall under the “open to the public” exception because case law, common law considerations, and the normative value in preserving an important antidiscrimination law all support a finding that the Act regulates the business of offering dwelling rentals, a type of business open to the public

The Determinants of Customer Perceptions in a Dynamic Business Environment: An Exploratory Analysis of the ASP Business Model

Outsourcing attracted much attention in 1989 when Kodak outsourced its data center operation to IBM (International Business Machines Corp.). Nowadays, this strategy has become more popular. At the beginning of this century, the ASP (Application Service Provider) model was considered one of the typical solutions of Internet-based IT (Information Technology) outsourcing. Although this model has been transformed and renamed (e.g. SaaS - Software as a Service), the principle concept of providing IT service through the Internet or wide area network is still there. This study attempts to explore the determinants of customer perception of Internet-based IT outsourcing by obtaining a comprehensive understanding of the ASP model. The research dimensions not only include factors affecting users' perception of service quality but also ASP business position (i.e. the firm origin of ASP and its provider type) and services utilized by the customers. Through the study of firm history, two important theoretical themes of this research - path-dependence and Ansoff's product/ market growth matrix - are taken account of in exploring the influence of the determinants. Web-based questionnaire survey research is conducted together with a documentation study to collect data. Targeting the customers of the top 50 ASPs selected by ASPnews.com during the period 2001-2004, the researcher contacted 597 potential respondents, and 196 responses were returned. The valid sample consisted of 175 responses, and 124 of them not only provided full information for satisfaction evaluation but also the information for tracking their ASP vendors' business position. The GLM (General Linear Model) and the Pearson correlation coefficient were the major statistical approaches used to evaluate the survey data for developing a structural model. The research findings indicated that the factors associated with service competitiveness, such as capability and performance, reliability and trustworthiness, affordability, integration and customization, have positive effects on customer perceived satisfaction; whereas lock-in has a negative effect. More specifically, the origin of the ASP firm has a direct effect on capacity and performance, and also directly influences the use of IT adoption services. Based on this finding, a descriptive analysis and qualitative research shows that two mechanisms for path-dependence - existing expertise and perceived expertise - can affect the satisfaction level of capacity and performance of ASP services. On the other hand, provider type has a direct effect on affordability and also directly influences the use of facility supporting services. On this basis, another two mechanisms for path-dependence - transaction cost and standardization - can indirectly impact customer's perception of this business model via affordability. In addition to those major findings, some other determinants (e.g. software applications, brand of applications, and intensity of service used) were also identified in this study. The study result can be used for theoretical understanding about the determinants of ASP customer's perception. It not only indicates a new perspective to enhance the current body of research on this topic, but can also be more broadly applied to any fast-growth firm, rapid-change business, or technology intensive industry. Acknowledgements I would like to sincerely thank the following people for their contribution to this research project. Dr. Scott Koslow, my chief supervisor, for his continued encouragement, patience and guidance to ensure the completion of this project. His speciality in statistics has provided appropriate and valuable guidance in the data analysis for my research. Dr. Steven Lim, my second supervisor, for his advice, coherence, and support over the years. I also appreciate his constructive comments on my drafts and the shaping of my research. Dr. Bob McQueen and Dr. Jim Corner, for their assistance and advice in the early stages of my study. My parents, Yu-Ho and Lee-Chiung Liang, and my brother Ken, my sisters Annie, Eva, and Nancy, my brothers-in-law, J.C. and Chen, and Alice, my sister-in-law, for their emotional support throughout the length of my study. I also thank Bessie, my best friend for her assistance in data collection and her loving support, as well as Ted, Kevin, Mark, Frank, and Shirley, my study mates for their encouragement and friendship. Special thanks goes to Dr. Kuang-Ya Wang, the principal of Yu Da High School of Commerce and Home Economics, Taiwan, and also to the staff over there for their concern and assistance in data collection. Most importantly, my heartfelt appreciation goes to Warren, my husband. I am deeply grateful to him for his understanding, patience, and practical help. Without his enduring support I could not have done this study. Finally, my thanks and gratitude goes to those people who patiently answered my survey questionnaire as their kind assistance made it possible to complete this research

HIGH VOLTAGE SWITCHING SYSTEM FOR ELECTROWETTING ON-DIELECTRIC (EWOD)

Electrowetting-On-Dielectric (EWOD) is becoming a standout amongst all the broadly used method for controlling small amount of liquid on a flat electrode surface. Scaling down the EWOD process has been a technological development recently as it appeared to have better integration and automation of numerous procedures on a single device. The applied voltage plays an important role in this study. A low voltage will diminish the ionization effect happening within the droplet. Insufficient ionization will further cause the inability of droplet movement. Therefore, a high voltage must be applied to initiate droplet movement. This study focuses on high voltage switching system for electrowetting process. Results achieved shown that MOSFET IRF 740 acted as the best switching component for the system. Besides, this study proves the feasibility of electrowetting by describing the fabrication and testing of different dielectric layers using high voltage switching system. As for the coating of dielectric layer, cooking oil showed the most noticeable results out of all the material

The Return of the Plague: Inequitable Conduct After Regeneron V. Merus

The Return of the Plague: Inequitable Conduct After Regeneron V. Meru

Region-specific and activity-dependent regulation of SVZ neurogenesis and recovery after stroke.

Stroke is the leading cause of adult disability. Neurogenesis after stroke is associated with repair; however, the mechanisms regulating poststroke neurogenesis and its functional effect remain unclear. Here, we investigate multiple mechanistic routes of induced neurogenesis in the poststroke brain, using both a forelimb overuse manipulation that models a clinical neurorehabilitation paradigm, as well as local manipulation of cellular activity in the peri-infarct cortex. Increased activity in the forelimb peri-infarct cortex via either modulation drives increased subventricular zone (SVZ) progenitor proliferation, migration, and neuronal maturation in peri-infarct cortex. This effect is sensitive to competition from neighboring brain regions. By using orthogonal tract tracing and rabies virus approaches in transgenic SVZ-lineage-tracing mice, SVZ-derived neurons synaptically integrate into the peri-infarct cortex; these effects are enhanced with forelimb overuse. Synaptic transmission from these newborn SVZ-derived neurons is critical for spontaneous recovery after stroke, as tetanus neurotoxin silencing specifically of the SVZ-derived neurons disrupts the formation of these synaptic connections and hinders functional recovery after stroke. SVZ-derived neurogenesis after stroke is activity-dependent, region-specific, and sensitive to modulation, and the synaptic connections formed by these newborn cells are functionally critical for poststroke recovery

Multiphoton and Fluorescence Lifetime Imaging Microscopy in Studying Nanoparticle Pharmacokinetics in Skin and Liver

The use of nanoparticles has increased in consumer products in recent decades; however, concerns regarding their safety remain. Zinc oxide is used in sunblocking and may generate free radicals in response to UV illumination, leading to DNA damage and an immunological response. With high‐resolution, high‐contrast imaging in biological tissue, multiphoton microscopy is able to separate nanoparticles signals from endogenous fluorophores. It has been proven to be very useful in imaging penetration of zinc oxide nanoparticles in skin and in combination with fluorescence lifetime imaging microscopy study cellular function as well. This chapter aims to review the use of these imaging techniques in studying the uptake and distribution of nanoparticles in skin and liver. Due to the questionable clinical use and possible toxicity of nanoparticles, it is important to study their pharmacokinetics. Some nanomaterials have been identified as relatively toxic to humans and a few metal nanoparticles have been reported to penetrate and be detected in blood. Multiphoton microscopy has high resolution and is able to visualize nanoparticles, due to their optical properties, in vivo. The addition of fluorescence lifetime imaging makes it possible to measure the physiochemical environment, with outputs that can be statistically analyzed, posing an advantage over fluorescence intensity imaging only

Testing an intervention codesigned with stakeholders for altering wildlife consumption: Health messaging matters

Consumer behavior change is a key priority to address the illegal wildlife trade, but evaluation of these interventions is lacking. We used surveys and randomized controlled trials to assess the effectiveness of three types of messages, which were codesigned with key stakeholders, with 2496 potential consumers and nontarget consumers in China. We found a 23% decrease in intention among potential consumers to use wild animal medicinal products by health‐related messages, and a 14% decrease by legality‐related messages, compared with the control group, though the effect size was small. Furthermore, we revealed that the effect of health‐related messages occurred indirectly by increasing health risk perceptions associated with improper utilization of wild animals. Yet, we did not find a clear effect pathway of the legality‐related messages. Regarding the nontarget consumers, information of whistleblowing platforms and incentives improved willingness to report illegal wildlife use directly, as well as indirectly through adding messages to increase perceived legality risk of using wild products and improve self‐efficacy in identifying legal products. Our findings can inform future larger scale efforts to influence wildlife consumption

Applying a co-design approach with key stakeholders to design interventions to reduce illegal wildlife consumption

1. Co-design, an approach that seeks to incorporate the experiences and perspectives of different stakeholders, is increasingly being used to develop audience-oriented behaviour change interventions. 2. The complexity of wildlife consumption behaviour makes the co-design approach an important potential tool for the design of conservation interventions that aim to reduce illegal wildlife trade. Yet, little is known about how to adapt and apply the co-design approach to the wildlife trade sector. 3. Here, we applied a co-design approach to develop interventions aimed at reducing illegal animal-based medicine consumption in China. We conducted three workshops with key stakeholders: consumers of animal-based medicines, pharmacy workers who sell them and traditional Chinese medicine (TCM) doctors who prescribe them. We then developed a theory of change to ensure the relevance of the co-designed intervention prototypes. 4. Our co-design process identified five main pathways of interventions, including two inclusive solutions that may have been previously overlooked in behaviour change work in this context. These were an intervention to promote the appropriate use of TCM and one to increase consumers' capacity to identify the legality of products. Our prototype interventions also enhanced existing views related to the role of medical practitioners in health-risk communication. 5. We used our co-design process and reflections on its application to this specific market to provide guidelines for future conservation program planning in the broader wildlife trade context. Some intervention prototypes produced during co-design may need wider stakeholder involvement to increase their feasibility for implementation. 6. We show that the co-design process can integrate multiple stakeholders' perspectives in the ideation stage, and has the potential to produce inclusive intervention designs that could drive innovation in conservation efforts to reduce illegal consumption of a range of wild species

Targeting fibroblast activation protein in tumor stroma with chimeric antigen receptor T cells can inhibit tumor growth and augment host immunity without severe toxicity.

The majority of chimeric antigen receptor (CAR) T-cell research has focused on attacking cancer cells. Here, we show that targeting the tumor-promoting, nontransformed stromal cells using CAR T cells may offer several advantages. We developed a retroviral CAR construct specific for the mouse fibroblast activation protein (FAP), comprising a single-chain Fv FAP [monoclonal antibody (mAb) 73.3] with the CD8α hinge and transmembrane regions, and the human CD3ζ and 4-1BB activation domains. The transduced muFAP-CAR mouse T cells secreted IFN-γ and killed FAP-expressing 3T3 target cells specifically. Adoptively transferred 73.3-FAP-CAR mouse T cells selectively reduced FAP(hi) stromal cells and inhibited the growth of multiple types of subcutaneously transplanted tumors in wild-type, but not FAP-null immune-competent syngeneic mice. The antitumor effects could be augmented by multiple injections of the CAR T cells, by using CAR T cells with a deficiency in diacylglycerol kinase, or by combination with a vaccine. A major mechanism of action of the muFAP-CAR T cells was the augmentation of the endogenous CD8(+) T-cell antitumor responses. Off-tumor toxicity in our models was minimal following muFAP-CAR T-cell therapy. In summary, inhibiting tumor growth by targeting tumor stroma with adoptively transferred CAR T cells directed to FAP can be safe and effective, suggesting that further clinical development of anti-human FAP-CAR is warranted