Extinguishing the Firewall: Addressing the Jurisdictional Challenges to Bringing the Cyber Tort Suits against Foreign Sovereigns

The rapid advancement of technology has resulted in new forms of tortious activity. Increasingly, these cyber torts are perpetrated by foreign states. Notwithstanding other barriers to collecting damages for a cyber tort, a plaintiff suing for a foreign-state-perpetrated cyber tort must prove that the alleged tortious activity satisfies one of the Foreign Sovereign Immunities Act\u27s exceptions-most likely the noncommercial tort exception. Recently the U.S. Court of Appeals for the D.C. Circuit held that a U.S. court lacked jurisdiction to hear a claim against a foreign state that hacked a U.S. national\u27s email account. The court found the noncommercial tort exception inapplicable because the intent to hack was held by a party abroad, and thus the entire tort did not occur in the United States. This Note argues that the D.C. Circuit improperly extended the entire tort doctrine from traditional physical torts to cyber torts. Instead, the noncommercial tort exception should apply to foreign-state-perpetrated cyber torts. This Note further proposes a modified location test for courts to use in determining whether a cyber tort satisfies the exception\u27s occurring in the United States requirement

Numerical prediction of ship resistance and squat in confined waters

Accurate prediction of hydrodynamic forces opposing a ship displacement in restricted waterways is necessary in order to improve energy efficiency of inland transport. When a ship moves in restricted waterways, a significant increase in ship squat (combination of sinkage and trim) and resistance occurs compared to a movement in open waters. In this paper, a 3D numerical model based on fluid-structure coupling is presented and used to investigate the effect of limited water depth and channel width on ship resistance and squat

Transport and percolation in a low-density high-mobility two-dimensional hole system

We present a study of the temperature and density dependence of the resistivity of an extremely high quality two-dimensional hole system grown on the (100) surface of GaAs. For high densities in the metallic regime (p\agt 4 \times 10^{9} cm$^{-2}$), the nonmonotonic temperature dependence ($\sim 50-300$ mK) of the resistivity is consistent with temperature dependent screening of residual impurities. At a fixed temperature of $T$= 50 mK, the conductivity vs. density data indicates an inhomogeneity driven percolation-type transition to an insulating state at a critical density of $3.8\times 10^9$ cm$^{-2}$.Comment: accepted for publication in PR

Impact of spin-orbit coupling on quantum Hall nematic phases

Anisotropic charge transport is observed in a two-dimensional (2D) hole system in a perpendicular magnetic field at filling factors nu=7/2, nu=11/2, and nu=13/2 at low temperature. In stark contrast, the transport at nu=9/2 is isotropic for all temperatures. Isotropic hole transport at nu=7/2 is restored for sufficiently low 2D densities or an asymmetric confining potential. The density and symmetry dependences of the observed anisotropies suggest that strong spin-orbit coupling in the hole system contributes to the unusual transport behavior.Comment: 4 pages, 4 figure

Seeing without Seeing? Degraded Conscious Vision in a Blindsight Patient

Blindsight patients, whose primary visual cortex is lesioned, exhibit preserved ability to discriminate visual stimuli presented in their “blind” field, yet report no visual awareness hereof. Blindsight is generally studied in experimental investigations of single patients, as very few patients have been given this “diagnosis”. In our single case study of patient GR, we ask whether blindsight is best described as unconscious vision, or rather as conscious, yet severely degraded vision. In experiment 1 and 2, we successfully replicate the typical findings of previous studies on blindsight. The third experiment, however, suggests that GR's ability to discriminate amongst visual stimuli does not reflect unconscious vision, but rather degraded, yet conscious vision. As our finding results from using a method for obtaining subjective reports that has not previously used in blindsight studies (but validated in studies of healthy subjects and other patients with brain injury), our results call for a reconsideration of blindsight, and, arguably also of many previous studies of unconscious perception in healthy subjects

Laparoscopic sacrocolpopexy with bone anchor fixation: short-term anatomic and functional results

Contains fulltext : 108485.pdf (publisher's version ) (Open Access)INTRODUCTION AND HYPOTHESIS: The aim of this study was to evaluate short-term anatomic and functional outcomes and safety of laparoscopic sacrocolpopexy with bone anchor fixation. METHODS: A prospective cohort study of women undergoing laparoscopic sacrocolpopexy between 2004 and 2009. Anatomic outcome was assessed using the pelvic organ prolapse quantification score (POP-Q). Functional outcomes were assessed using the Urogenital Distress Inventory, Defecatory Distress Inventory, and the Incontinence Impact Questionnaire preoperatively and at 6 months postoperatively. The Wilcoxon signed rank test was used to test differences between related samples. RESULTS: Forty-nine women underwent laparoscopic sacrocolpopexy. The objective success rate in the apical compartment was 98%, subjective success rate was 79%. One mesh exposure (2%) was found. One conversion was necessary due to injury to the ileum. CONCLUSIONS: Laparoscopic sacrocolpopexy with bone anchor fixation is a safe and efficacious treatment for apical compartment prolapse. It provides excellent apical support and good functional outcome 6 months postoperatively.1 april 201

Predictors of Poor Perinatal Outcome following Maternal Perception of Reduced Fetal Movements: A Prospective Cohort Study

Background Maternal perception of reduced fetal movement (RFM) is associated with increased risk of stillbirth and fetal growth restriction (FGR). RFM is thought to represent fetal compensation to conserve energy due to insufficient oxygen and nutrient transfer resulting from placental insufficiency. Objective To identify predictors of poor perinatal outcome after maternal perception of reduced fetal movements (RFM). Design Prospective cohort study. Methods 305 women presenting with RFM after 28 weeks of gestation were recruited. Demographic factors and clinical history were recorded and ultrasound performed to assess fetal biometry, liquor volume and umbilical artery Doppler. A maternal serum sample was obtained for measurement of placentally-derived or modified proteins including: alpha fetoprotein (AFP), human chorionic gonadotrophin (hCG), human placental lactogen (hPL), ischaemia-modified albumin (IMA), pregnancy associated plasma protein A (PAPP-A) and progesterone. Factors related to poor perinatal outcome were determined by logistic regression. Results 22.1% of pregnancies ended in a poor perinatal outcome after RFM. The most common complication was small-for-gestational age infants. Pregnancy outcome after maternal perception of RFM was related to amount of fetal activity while being monitored, abnormal fetal heart rate trace, diastolic blood pressure, estimated fetal weight, liquor volume, serum hCG and hPL. Following multiple logistic regression abnormal fetal heart rate trace (Odds ratio 7.08, 95% Confidence Interval 1.31–38.18), (OR) diastolic blood pressure (OR 1.04 (95% CI 1.01–1.09), estimated fetal weight centile (OR 0.95, 95% CI 0.94–0.97) and log maternal serum hPL (OR 0.13, 95% CI 0.02–0.99) were independently related to pregnancy outcome. hPL was related to placental mass. Conclusion Poor perinatal outcome after maternal perception of RFM is closely related to factors which are connected to placental dysfunction. Novel tests of placental function and associated fetal response may provide improved means to detect fetuses at greatest risk of poor perinatal outcome after RFM