Misguided Patent Reform: The Questionable Constitutionality of First-to-File

American cigarette warning labels are lackluster compared to others around the world. To address this inadequacy, the FDA created nine graphic-image cigarette warning labels that were scheduled to appear on all cigarette packages sold in the US beginning in 2012. However, before they debuted, the D.C. Circuit Court of Appeals struck the labels down in R.J. Reynolds Tobacco Co. v. FDA, holding that they constituted compelled commercial speech in violation of the First Amendment. This Note argues that the R.J. Reynolds decision conflicts with the Supreme Court\u27s commercial speech jurisprudence. Historically, the Supreme Court has applied limited First Amendment protection to commercial speech under a marketplace of ideas rationale. Accordingly, the Court has applied a rational basis standard to regulations compelling commercial speech since such regulations increase the amount of commercial information available to consumers and the public. Despite this precedent, the D.C. Circuit in R.J. Reynolds applied heightened scrutiny to the FDA\u27s graphic-image cigarette warning labels, protecting industry interests at the public\u27s expense. This Note argues that courts should apply a rational basis standard to all commercial disclosure requirements so long as they do not compel disclosure of misleading content. In turn, this note argues that the D.C. Circuit should have upheld the FDA\u27s cigarette warning labels under rationality review. Even if offensive to some, the labels would have enhanced the marketplace of ideas that the Supreme Court\u27s commercial speech doctrine was designed to protec

Peripheral primitive neuroectodermal tumour - A rare cause of a popliteal fossa mass: A case report and review of the literature

A literature review of peripheral primitive neuroectodermal tumours, illustrated with an index case report describing an 80-year-old woman who presented with a mass in the left popliteal fossa, is reported. An excision biopsy was performed, revealing a possible peripheral primitive neuroectodermal tumour as the primary pathology. Normally confined to the chest wall and axial soft tissues of children and young adults, reports of this tumour existing in other areas and in the elderly population are scarce

Third-wave cognitive behaviour therapies for weight management: A systematic review and network meta-analysis.

This systematic review and network meta-analysis synthesized evidence on the effects of third-wave cognitive behaviour therapies (3wCBT) on body weight, and psychological and physical health outcomes in adults with overweight or obesity. Studies that included a 3wCBT for the purposes of weight management and measured weight or body mass index (BMI) pre-intervention and ≥ 3 months post-baseline were identified through database searches (MEDLINE, CINAHL, Embase, Cochrane database [CENTRAL], PsycINFO, AMED, ASSIA, and Web of Science). Thirty-seven studies were eligible; 21 were randomized controlled trials (RCT) and included in the network meta-analyses. Risk of bias was assessed using RoB2, and evidence quality was assessed using GRADE. Random-effects pairwise meta-analysis found moderate- to high-quality evidence suggesting that 3wCBT had greater weight loss than standard behavioural treatment (SBT) at post-intervention (standardized mean difference [SMD]: -0.09, 95% confidence interval [CI]: -0.22, 0.04; N = 19; I2 = 32%), 12 months (SMD: -0.17, 95% CI: -0.36, 0.02; N = 5; I2 = 33%), and 24 months (SMD: -0.21, 95% CI: -0.42, 0.00; N = 2; I2 = 0%). Network meta-analysis compared the relative effectiveness of different types of 3wCBT that were not tested in head-to-head trials up to 18 months. Acceptance and commitment therapy (ACT)-based interventions had the most consistent evidence of effectiveness. Only ACT had RCT evidence of effectiveness beyond 18 months. Meta-regression did not identify any specific intervention characteristics (dose, duration, delivery) that were associated with greater weight loss. Evidence supports the use of 3wCBT for weight management, specifically ACT. Larger trials with long-term follow-up are needed to identify who these interventions work for, their most effective components, and the most cost-effective method of delivery.This study is funded by the National Institute for Health Research (NIHR) Programme Grants for Applied Research RP-PG-0216-20010. The views expressed are those of the authors and not necessarily those of the NIHR or the Department of Health and Social Care. ALA and SJG are supported by the Medical Research Council (MC_UU_12015/4). SJG is an NIHR senior investigator. The University of Cambridge has received salary support in respect of SJG from the National Health Service in the East of England through the Clinical Academic Reserve.We want to thank the patient user group panel for assisting with the refinement of the research question, and interpretation of results. We would like to thank individuals within the unit that assisted with article language translation, Eleanor Barker for help in developing the search strategy and Rebecca Jones for assisting with database searches. We would also like to thank all corresponding authors of articles that provided additional information or clarity on their studies

Prospective associations between sedentary time, sleep duration and adiposity in adolescents.

OBJECTIVE: The objective of this study was to investigate whether objectively measured sedentary time and sleep duration are associated with changes in adiposity from mid- to late adolescence. METHODS: Students (n = 504, 42% boys) were recruited from schools in Cambridgeshire, UK. At baseline (mean age 15.0 ± 0.3 years), sedentary time was objectively measured by ≥3 days of combined heart rate and movement sensing. Concurrently, sleep duration was measured by combined sensing in conjunction with self-reported bed times. Fat mass index (FMI; kg/m(2)) was estimated at baseline and follow-up (17.5 ± 0.3 years) by anthropometry and bioelectrical impedance. FMI change (ΔFMI) was calculated by subtracting the baseline from follow-up values. Linear regression models adjusted for basic demographics, moderate-to-vigorous physical activity (MVPA), and depressive symptoms were used to investigate associations of sedentary time and sleep duration (mutually adjusted for one another) with ΔFMI. RESULTS: FMI increased by 0.5 and 0.6 kg/m(2) in boys and girls, respectively, but there was no association between sedentary time and ΔFMI in either gender (p ≥ 0.087), and no association between sleep duration and ΔFMI in girls (p ≥ 0.61). In boys, each additional hour of baseline sleep significantly reduced the ΔFMI by 0.13 kg/m(2) (p = 0.049), but there was little evidence for this association after adjusting for MVPA and depressive symptoms (p = 0.15). CONCLUSIONS: Sedentary time may not determine changes in adiposity from mid- to late adolescence, nor may sleep duration in girls. However, sleep length may be inversely associated with adiposity gain in boys, depending on whether the relationship is confounded or mediated by MVPA and depression.This work was supported by the Medical Research Council (Unit Programme number MC_UU_12015/3), the Wellcome Trust (grant 074296/Z/04/Z) and the British Heart Foundation (grant FS/12/58/29709 to KW).This is the final version of the article. It first appeared from Elsevier via http://dx.doi.org/10.1016/j.sleep.2015.02.53

Youth identity and postsecondary decision making in a rural state: evidence of a College for All master narrative

This study examined the normative messages that inform youth postsecondary decision making in a predominantly rural state in the northeastern U.S., focusing on the institutionalization and circulation of identity master narratives. Using a multilevel, ecological approach to sampling, the study interviewed 33 key informants in positions of influence in educational, workforce, and quality of life domains. Narrative analysis yielded evidence of a predominant master narrative – College for All – that participants described as a prescriptive expectation that youth and families orient their postsecondary planning toward four-year, residential baccalaureate degree programs. Both general and domain-specific aspects of this master narrative are elaborated, as well as findings indicating that the College for All ideology appears to both obscure and stigmatize the development and institutionalization of alternative postsecondary pathways. Implications for rural communities, rural mobility, and future research on narratives informing postsecondary options for youth are discussed

The SAMI galaxy survey: Can we trust aperture corrections to predict star formation?

In the low-redshift Universe (z < 0.3), our view of galaxy evolution is primarily based on fibre optic spectroscopy surveys. Elaborate methods have been developed to address aperture effects when fixed aperture sizes only probe the inner regions for galaxies of ever decreasing redshift or increasing physical size. These aperture corrections rely on assumptions about the physical properties of galaxies. The adequacy of these aperture corrections can be tested with integral-field spectroscopic data. We use integral-field spectra drawn from 1212 galaxies observed as part of the SAMI Galaxy Survey to investigate the validity of two aperture correction methods that attempt to estimate a galaxy's total instantaneous star formation rate. We show that biases arise when assuming that instantaneous star formation is traced by broad-band imaging, and when the aperture correction is built only from spectra of the nuclear region of galaxies. These biases may be significant depending on the selection criteria of a survey sample. Understanding the sensitivities of these aperture corrections is essential for correct handling of systematic errors in galaxy evolution studies

The SAMI Galaxy Survey: spatially resolving the main sequence of star formation

We present the ∼800 star formation rate maps for the Sydney-AAO Multi-object Integral field spectrograph (SAMI) Galaxy Survey based on H α emission maps, corrected for dust attenuation via the Balmer decrement, that are included in the SAMI Public Data Release 1. We mask out spaxels contaminated by non-stellar emission using the [O III]/H β, [N II]/H α, [S II]/H α, and [O I]/H α line ratios. Using these maps, we examine the global and resolved star-forming main sequences of SAMI galaxies as a function of morphology, environmental density, and stellar mass. Galaxies further below the star-forming main sequence are more likely to have flatter star formation profiles. Early-type galaxies split into two populations with similar stellar masses and central stellar mass surface densities. The main-sequence population has centrally concentrated star formation similar to late-type galaxies, while galaxies >3σ below the main sequence show significantly reduced star formation most strikingly in the nuclear regions. The split populations support a two-step quenching mechanism, wherein halo mass first cuts off the gas supply and remaining gas continues to form stars until the local stellar mass surface density can stabilize the reduced remaining fuel against further star formation. Across all morphologies, galaxies in denser environments show a decreased specific star formation rate from the outside in, supporting an environmental cause for quenching, such as ram-pressure stripping or galaxy interactions.Support for A.M.M. is provided by National Aeronautics and Space Administration (NASA) through Hubble Fellowship grant #HST-HF2-51377 awarded by the Space Telescope Science Institute, which is operated by the Association of Universities for Research in Astronomy, Inc., for NASA, under contract NAS5-26555. S.M.C. acknowledges the support of an Australian Research Council Future Fellowship (FT100100457). S.B. acknowledges funding support from the Australian Research Council through a Future Fellowship (FT140101166). B.C. is the recipient of an Australian Research Council Future Fellowship (FT120100660). C.F. gratefully acknowledges funding provided by the Australian Research Council’s Discovery Projects (grants DP150104329 and DP170100603). M.S.O. acknowledges the funding support from the Australian Research Council through a Future Fellowship (FT140100255). R.Mc.D. is the recipient of an Australian Research Council Future Fellowship (project number FT150100333). N.S. acknowledges support of a University of Sydney Postdoctoral Research Fellowship. J.v.d.S. is funded under Bland-Hawthorn’s Australian Research Council (ARC) Laureate Fellowship (FL140100278)