Shifting Targets on Shifting Fees: Attorney’s Fees in the Wake of \u3cem\u3eSinger Management Consultants, Inc. v. Milgram\u3c/em\u3e

On June 15, 2011, in Singer Management Consultants, Inc. v. Milgram, the U.S. Court of Appeals for the Third Circuit sitting en banc held that a temporary restraining order vacated after a defendant’s change in position is insufficient to confer prevailing-party status for purposes of awarding attorney’s fees. As a result, parties who obtain in-court relief short of a formal court order may not be able to obtain attorney’s fees. This Comment argues that in arriving at that decision, the Singer court too narrowly construed the phrase “judicially sanctioned.” It further advises that, to avoid this result, attorneys who plan to seek fees should request a permanent formal order, which courts have recognized as sufficient to confer prevailing-party status

DEVELOPMENT OF NEW ANALYTICAL METHOD AND ITS VALIDATION FOR THE DETERMINATION OF SALBUTAMOL SULPHATE IN BULK AND MARKETED FORMULATIONS

Objective: The present study aims to develop a simple, sensitive, specific, and validated colorimetric method for the quantitative estimation of Salbutamol Sulphate in bulk and pharmaceutical dosage form.Method: A simple colorimetric method for the determination of Salbutamol Sulphate in pure as well as in its dosage form has been developed. The method is based on formation of a blue coloured chromogen by the interaction of Salbutamol Sulphate with Folin–Ciocalteu reagent under basic condition and the maximum absorbance of the developed chromogen was found. The developed method is validated in terms of Linearity, Accuracy, Precision, Limit of Detection, Limit of Quantitation, as per ICH Guidelines.Results: The λmax was found to be 723nm for assay. Linearity was found in the concentration range of 10-50 µg/ml respectively with a correlation coefficient of 0.9979. The regression equation was found as y=bx+a: 0.0199x+0.0208.Conclusion: The proposed method makes use of simple reagent, which an ordinary analytical laboratory can afford. The method was found to be simple, precise, economic and less time consuming. The method has been statistically evaluated and results obtained are accurate, precise and insensitive and free from the interferences of other additives present in the formulation

NDRG2 promotes myoblast proliferation and caspase 3/7 activities during differentiation, and attenuates hydrogen peroxide - but not palmitate-induced toxicity

The function of the stress-responsive N-myc downstream-regulated gene 2 (NDRG2) in the control of myoblast growth, and the amino acids contributing to its function, are not well characterized. Here, we investigated the effect of increased NDRG2 levels on the proliferation, differentiation and apoptosis in skeletal muscle cells under basal and stress conditions. NDRG2 overexpression increased C2C12 myoblast proliferation and the expression of positive cell cycle regulators, cdk2, cyclin B and cyclin D, and phosphorylation of Rb, while the serine/threonine-deficient NDRG2, 3A-NDRG2, had less effect. The onset of differentiation was enhanced by NDRG2 as determined through the myogenic regulatory factor expression profiles and myocyte fusion index. However, the overall level of differentiation in myotubes was not different. While NDRG2 up-regulated caspase 3/7 activities during differentiation, no increase in apoptosis was measured by TUNEL assay or through cleavage of caspase 3 and PARP proteins. During H2O2 treatment to induce oxidative stress, NDRG2 helped protect against the loss of proliferation and ER stress as measured by GRP78 expression with 3A-NDRG2 displaying less protection. NDRG2 also attenuated apoptosis by reducing cleavage of PARP and caspase 3 and expression of pro-apoptotic Bax while enhancing the pro-survival Bcl-2 and Bcl-xL levels. In contrast, Mcl-1 was not altered, and NDRG2 did not protect against palmitate-induced lipotoxicity. Our findings show that NDRG2 overexpression increases myoblast proliferation and caspase 3/7 activities without increasing overall differentiation. Furthermore, NDRG2 attenuates H2O2-induced oxidative stress and specific serine and threonine amino acid residues appear to contribute to its function in muscle cells

Looking ahead: Anticipatory cueing of attention to objects others will look at

Seeing a face gaze at an object elicits rapid attention shifts towards the same object. We tested whether gaze cuing is predictive: do people shift their attention towards objects others are merely expected to look at? Participants categorized objects while a face either looked at this object, at another object, or straight ahead. Unbeknownst to participants, one face would only look at drinks and the other at foods. We tested whether attention was drawn towards objects “favoured” by a face even when currently looking straight ahead. Indeed, while gaze expectations initially had a disruptive effect, participants did shift attention to the faces‟ favoured objects once learning had been established, as long as emotional expressions had indicated personal relevance of the object to the individual. These data support predictive models of social perception, which assume that predictions can drive perception and action, as if these stimuli were directly perceived

Predictive person models elicit motor biases: The face-inhibition effect revisited

Using an established paradigm, we tested whether people derive motoric predictions about an actor’s forthcoming actions from prior knowledge about them and the context in which they are seen. In two experiments, participants identified famous tennis and soccer players using either hand or foot responses. Athletes were shown either carrying out or not carrying out their associated actions (swinging, kicking), either in the context where these actions are typically seen (tennis court, soccer Pitch) or outside these contexts (beach, awards ceremony). Replicating prior work, identifying non-acting athletes revealed the negative compatibility effects: viewing tennis players led to faster responses with a foot than a hand, and vice versa for viewing soccer players. Consistent with the idea that negative compatibility effects result from the absence of a predicted action, these effects were eliminated (or reversed) when the athletes were seen carrying out actions typically associated with them. Strikingly, however, these motoric biases were not limited to In-Context trials but were, if anything, more robust in the Out-of-Context trials. This pattern held even when attention was drawn specifically to the context (Experiment 2). These results confirm that people hold motoric knowledge about the actions that others typically carry out and that these actions are part of perceptual representations that are accessed when those others are re-encountered, possibly in order to resolve uncertainty in person perception

COMPARISON OF NON-MAXIMAL TESTS FOR ESTIMATING EXERCISE CAPACITY

Although maximal incremental exercise tests (GXT) are the gold standard for outcome assessment and exercise prescription, they are not widely available in either fitness or clinical exercise programs. This study compared the prediction of VO2max in healthy, sedentary volunteers using a non-exercise prediction (Matthews et al., 1999), RPE extrapolation to 19 and 20 and the Rockport Walking Test (RWT), and of ventilatory threshold (VT) using the Talk Test and RPE @ 13,14,15. Subjects performed a treadmill GXT with gas exchange, a submaximal treadmill with RPE and Talk Test, the RWT and Matthews. All methods provided reasonable estimates of both VO2max and VT, with correlations of >0.80 and SEE~1.3 METs. VO2max was best estimated with the extrapolation to RPE=19. VT was intermediate between the TT Last Positive and Equivocal stages and between RPE 13 and 14. Non-maximal evaluation can be used in place of maximal GXT with gas exchange to make reasonable estimates of both VO2max and V