Note, Throwing a Monkey Wrench into the Wheels of International Finance: \u3cem\u3eWells Fargo Asia Ltd. V. Citibank, N.A.\u3cem\u3e

This note attempts to illustrate concisely the issues and potential ramifications of Wells Fargo. After describing the complex factual and procedural histories of the case, the note briefly surveys the various approaches to the Act of State doctrine and suggests that the Court should consider Act of State issues in Wells Fargo. Next, it examines the lower courts\u27 analyses of the case and what effects their rulings would have if the Court were to adopt them. Due to the resulting legal confusion that the lower courts\u27 decisions would wreak on the Eurodollar community, Wells Fargo should not remain as precedent. Currently, Wells Fargo would subject these deposits to the laws of New York. The Court should reject the lower courts\u27 narrow reasoning and instead decide Wells Fargo in light of the Act of State issues involved, especially by addressing questions of debt situs determination raised by previous cases. Upon examination of the various approaches to debt situs determination, the Court should adopt the incidents of the debt test, an approach that is both more equitable to bank expropriation cases and more consistent with the tenets of the Act of State doctrine. Since banks have always assumed that Eurodollar deposits are situated, or have their situs, in the host country of a branch office, the situs of the debt in Wells Fargo should be Manila. Philippine law would then decide the case. Yet, even if Philippine law were to govern the outcome of Wells Fargo, plaintiff Wells Fargo Asia Limited ( WFAL ) might still prevail

Prioritizing integration goals in the ASEAN economic community in a changing world

According to the Charter of the Association of Southeast Asian Nations (ASEAN), by 2015 ASEAN countries should have established the ASEAN Economic Community (AEC) to “create a single market and production base which is stable, prosperous, highly competitive and economically integrated” in paragraph 5 of Article 1. Unfortunately, in its current condition, ASEAN is not well-prepared to undertake such ambitious objectives. ASEAN does not have strong regional institutions to deal with economic integration, unlike the EU. Nor does ASEAN have detailed legal agreements and robust dispute settlement procedures, unlike NAFTA. As a result, the AEC faces structural problems in dealing with regional economic integration, particularly the cross-pressures coming from the Trans Pacific Partnership (TPP) and the EU’s bilateral FTAs with individual ASEAN members. This paper therefore advocates strengthening the ASEAN institutions and processes so that all of the AEC participants can interact in conjunction with the TPP and EU-ASEAN FTAs, and not become caught up in the cross-pressures of these modern FTAs. We present a series of potential reforms ranging from the modest to the ambitious that would allow the AEC to flourish and go beyond its current limitations. Ultimately that choice needs to be made by the ASEAN leaders themselves – but that choice needs to be made, and soon

Over-expression of cyclo-oxygenase-2 predicts poor survival of patients with nasopharyngeal carcinoma: a meta-analysis

Objectives The conclusive prognostic significance of cyclo-oxygenase-2 has been determined in various cancers but not in nasopharyngeal carcinoma. Therefore, this study aimed to evaluate the relationship of cyclo-oxygenase-2 expression with the survival outcome and treatment response of nasopharyngeal carcinoma patients via a systematic meta-analysis approach. Methods A meta-analysis was conducted in compliance with the Preferred Reporting Items for Systematic Reviews and Meta-Analyses (‘PRISMA’) checklist. The primary clinical characteristics of patients, and hazard ratios with 95 per cent confidence intervals of overall survival data, were tabulated from eligible studies. The relationship of cyclo-oxygenase-2 expression with survival outcome (expressed as hazard ratio) and treatment response (expressed as odds ratio) in nasopharyngeal carcinoma patients was analysed, and explained with the aid of forest plot charts. Results and conclusion The pooled hazard ratio for overall survival was 2.02 (95 per cent confidence interval = 1.65–2.47). This indicates that the over-expression of cyclo-oxygenase-2 is significantly associated with the poor survival of nasopharyngeal carcinoma patients. The pooled odds ratio of 0.98 (95 per cent confidence interval = 0.27–3.49) reveals that over-expression of cyclo-oxygenase-2 was not significantly related to the treatment outcome

Perception of Research Culture among Undergraduate Students in a Malaysian Public University

Studies on research culture often focus on how administrators and academics inculcate this culture and what impact it has on undergraduates. Evidently, literature information on undergraduates’ perception of university research and publication agenda is lacking. Considering the fact that the campus community comprises largely of an undergraduate population and their activities, facts and conjectures alluding to research culture can be misleading without the views of undergraduate students. The study investigated the perception of research culture among undergraduate students in a Malaysian public university. The objectives of the study were to examine the students’ awareness of the research culture of the university, ranging from the research culture of the university as per the lecturers to the research reputation of the university. A survey was carried out using questionnaires incorporated within the e-learning platform (Morpheus) of a taught course on scientific communication. The analysis of questionnaire data from 56 students showed that undergraduates are more aware of research than publication matters. They do not think that good research correlates with better teaching. Local students are also indifferent to issues of university ranking. Our findings provide the basis for rethinking and deriving more accurate explanations of research culture appreciation in local public universities

Patterns and Determinants of Attitudes towards Genetic Risk of Cancer: Case Study in a Malaysian Public University

Genetic risk to cancer is a knowledge largely confined to experts and the more educated sectors of the developed western countries.The perception of genetic susceptibility to cancer among the masses is fragmented, particularly in developing countries. As cancer diseases affect developing countries as much as developed nations, it is imperative to study perception and reception of genetic risk to cancer in Southeast Asia. Here, we report on a novel case study to gauge the awareness and attitudes towards genetic determination of cancer among the undergraduates of a Malaysian public university. A total of 272 university undergraduate students completed an online questionnaire. On causes of cancer, the respondents believed that cancer is caused by lifestyle and environmental factors, but those with science background were more likely to associate it with genetic factors. The results on awareness of genetic profiling of cancer risk showed that there are significant differences between those with science and nonscience background but there are no significant differences for gender and socioeconomic background. As for attitudes towards cancer risk, female respondents, those from middle socioeconomic status and science background, are more likely to believe in genetic determinism of cancer. The findings have implications on target population segmentation in strategic health communication on cancer

Structure-to-Function Computational Prediction of a Subset of Ribosomal Proteins for the Small Ribosome Subunit

Extra-ribosomal functions of ribosomal proteins have been widely accepted albeit an incomplete understanding of these roles. Standard experimental studies have limited usefulness in defining the complete biological significance of ribosomal proteins. An alternative strategy is via in silico analysis. Here, we sought a sequence-to-structure-to-function approach to computationally predict the extra-ribosomal functions of a subset of ribosomal proteins of the small ribosome subunit, namely RPS12, RPS19, RPS20 and RPS24. Three-dimensional structure constructed from amino acid sequence was precisely matched with structural neighbours to extrapolate possible functions. Our analysis reveals new logical roles for these ribosomal proteins, of which represent important information for planning experimental and further in silico studies to elucidate their physiological roles

The language of risk : Self-assessment of nasopharyngeal cancer risk

The language of risk is a part of medical discourse that lay people have problems understanding. Scientists, doctors and patients speak a different language of risk because they understand risk differently. Scientists talk about risk factors and the likelihood of the disease while patients experience risk at a personal level (Gifford 1986). Scientists estimate level of risk in numbers but doctors and patients translate risk information to the groups that are more likely to be at risk and what signs appear before the onset of illness (Gifford 1986). For doctors and patients, the distinction between risk and cause is blurred (Jasen 2002). Lupton (1995) categorises risk factors as external factors which are beyond one’s control (e.g., family history), and internal factors which are within one’s control (e.g., dietary habits). Patients often have their own understanding of why cancer might develop and why they delay seeking of treatment, which may not align with scientific knowledge (Jasen 2002). Much of the research on the language of risk in relation to diseases have focused on breast cancer (e.g., Jasen 2002; Lobb et al. 1999). Women also have problems understanding prognostic information delivered by doctors (Lobb et al. 1999). Traditionally it was clinical examinations that confirmed whether one had a disease, but nowadays self-examination is encouraged for early detection. There is a lack of findings on understanding of risk information for nasopharyngeal (nose and throat) cancer which is not common in Western settings. However, nasopharyngeal cancer incidence is high in Asian countries, particularly in China, Indonesia, Vietnam, India and Philippines (Kumar et al. 2019). In Malaysia, nasopharyngeal cancer incidence is number five, affecting 4% of the population, based on the National Cancer Registry 2012-2016 (Ministry of Health Malaysia 2019). The incidence is high among males (age-standardised incidence rate of 5.2, ranked fifth among cancers) but not among the top 10 cancers for females. The 25-59 years old group (11.3%) is the most susceptible. This cancer is more common among the Chinese males, compared to Malay and Indian males (age-standardised incidence rates of 8.6, 2.7 and 0.6 respectively). Nasopharyngeal cancer incidence is also particularly high among the Bidayuh indigenous group of Sarawak (Devi et al. 2004; Kumar et al. 2019). Hence, studies on self-assessment of risk factors and potential signs of the cancer are needed. The preliminary study on nose and throat cancer risk involved 101 respondents (55.4% male, 44.6% female). The age distribution is as follows: below 20 (6.9%), 20-39 (61.4%), 40-59 (21.8%), 60 and above (9.9%). There were more Malays (31.7%) and Chinese (38.5%) among the respondents, followed by Others (12.9%), Iban (6.9%), Bidayuh (5.0%), Indian (3%), Orang Ulu (1%) and Kadazandusun (1%). The instrument was a questionnaire on external risk factors (family history, 1 item) and internal risk factors (lifestyle, 3 items), and signs (4 items). Demographic information obtained were gender, age and ethnic background which are linked to nasopharyngeal cancer incidence in Malaysia. Respondents filled in the questionnaire after they had given consent. Subsequently, the data on risk factors and signs were computed to obtain a nasopharyngeal cancer assessment score. The risk associated with gender, age, ethnic group and signs were weighted for the computation. At the research exposition, the respondents could see the score and the risk level: low, moderate, high. They were also given an interpretation of what the risk score meant in terms of health protective measures. The results showed an average nasopharyngeal cancer risk score of 10.7 points out of the maximum of 48 points (range: 3-20). When converted to 100%, the average is 22.3% (range: 6.2%-41.7%). This means that on average, the respondents were at low risk of having nasopharyngeal cancer. Pearson correlation tests showed that there was no relationship between the nasopharyngeal cancer risk score and age. The t-test showed that there were also no significant differences between male and female respondents in their cancer risk score. As for ethnic group, the mean scores show some variation: Chinese (24.6%), Bidayuh (24.2%), Malay (22.7%), Iban (22.3%), Others (16.9%), and Indian (13.1%). The Orang Ulu and Kadazandusun were grouped with ‘Others’ category as there was only one respondent each. Among the lifestyle risk factors, the greatest risk is from consumption of preserved food, followed by exposure to chemicals and smoking. Smoking was a minimal risk factor for the respondents. A small percentage (0.8%) were non-smokers, 95% reported that they rarely smoked and 1% smoked one to three cigarettes per month and 4% smoked more than five cigarettes per day. The respondents were at minimal risk to nasopharyngeal cancer due to exposure to hazardous chemicals (no exposure, 86.1%; exposure, 13.9%). However, this group was at greater risk due to their consumption of preserved food (never, 2%; one to two times per year, 20.8%; one to two times per month, 54.5%; once per week, 22.8%). Nasopharyngeal cancer risk from family history was generally low for the respondents. The results showed that 91.1% did not have a family history of the cancer, while 6.9% had one uncle or aunt, and 2% had one parent who contracted the cancer. The results on the four early signs of nasopharyngeal cancer are as follows, arranged in the order of progressively more certain signs of the cancer: (1) Symptoms of common cold or flu, such as sore throat, cough, and running nose: less than 2 times per year, 43.6%; 3-5 times per year, 39.6%, 3 times per month, 16.8%; (2) Ear pain: nul incidence, 78.2%; occasional incidence, 19.8%; frequent incidence, 2%. (3) Blood in sputum or nasal discharge: nul incidence, 82.2%; occasional incidence, 16.8%; whenever they coughed, 1%. (4) Lump in neck area: absence, 98%; presence, 2%. The small percentage who reported blood in their sputum or nasal discharge and a lump in the neck area may be at risk of nasopharyngeal cancer. Taken together, about one-quarter of the respondents self-reported presence of lifestyle risk factors, family history and nasopharyngeal cancer signs (25% Indian respondents, 20.7% Malay respondents, 23.7% Chinese respondents). In conclusion, our results showed that respondents could perform self-assessment of cancer risk if the ‘diagnostic questions’ were phrased in everyday language and about tangible matters. In our study, we showed the nasopharyngeal cancer risk score in numerical form to respondents because this kind of information appears scientific. However, to help them understand the language of risk, we worded the ‘diagnostic outcome’ as low, moderate and high risk. For example, the high-risk respondents were told, ‘NasoCRA indicates a moderate to high NPC risk. We strongly suggest that you seek medical assistance from relevant medical specialist(s) as soon as possible to get further professional advice, and proper diagnosis. It is necessary that you consider quarterly to half yearly medical check-up’. The findings suggest that to help the lay person understand the language of risk, it is important to provide the risk information in both numerical and text form, and to focus the information on health measures within their control. References Devi, Beena C., Pisani, Paola, Tang, Tieng Swee., & Parkin, D. Maxwell. 2004. ‘High incidence of nasopharyngeal carcinoma in native people of Sarawak, Borneo Island,’ Cancer Epidemiology and Prevention Biomarkers 13(3), 482-486. Gifford, Sandra M. 1986. ‘The meaning of lumps: A case study of the ambiguities of risk,’ in C. R. Janes, Ron Stall, & Sandra M. Gifford, eds., Anthropology and epidemiology: Interdisciplinary approaches to the study of health and illness, 217-230. Dordrecht. Jasen, Patricia. 2002. Breast cancer and the language of risk, 1750-1950. The Society for the Social History of Medicine, 15(1), 17-43. Kumar, Karen Michell Othaya, & Mydin, Rabiatul Basria S. M. N. 2019. ‘Nasopharyngeal cancer: Geographic variation and risk factors,’ Malaysian Journal of Medicine and Health Sciences 15(109), 116-121. Lobb, Elizabeth A., Butow, Phyllis N., Kenny Dianna T., & Tattersall, Martin H. N. 1999. ‘Communicating prognosis in early breast cancer: Do women understand the language used?’ Medical Journal of Australia 171(6), 290-294. Lupton, Deborah. 1995. ‘The imperative of health: Public health and the regulated body,’ London. Ministry of Health Malaysia. 2019. Malaysia National Cancer Registry Report (MNCR) 2012-2016, Ministry of Health, Kuala Lumpur.ng Kong: Linguistic Society of Hong Kong

Putative Target Proteins Of The Ribosomal Protein, Rpel27 In Nasopharyngeal Carcinoma Cells

The pathogenesis of nasopharyngeal carcinoma (NPC) is multifactorial and multigenic. Despite the identification of several NPC-associated ribosomal proteins (RPs), the roles of these factors and their interacting partners in NPC tumourigenesis are poorly understood. To date, NPC- associated RP genes are either up or down-regulated in diseased/tumour situation compared to normal condition. The ribosomal protein eL27 (RPeL27) has been known to be over-expressed at both transcript and protein levels in NPC cell lines. This hypothesis was reinforced by our study herein. More importantly, using gene knockdown (RNA interference technique) followed by 2D gelelectrophoresis (2D GE) and in silico analysis; we revealed 15 proteins that are likely to interact with RPeL27 during situation of NPC tumourigenesis. These include COTL1, MAGOHB, UBE2N, NDPKA, TMED10, PSMB6, CA2, PGAM1, RPeL14, RPeS8, TPI1,PSMA2, RPeL19, GSTP1, and TPM1. Their association with RPeL27 could attribute to gene expression alteration, cell migration disruption and invasion, promotion of cancer cell survival, immune evasion, and genomic instability. Our findings provide new theoretical insights into the mechanism and involvement of RPeL27 in NPC pathogenesis. This is pertinent in understanding the molecular pathogenesis mediated by ribosomal proteins in the malignancy of the nasopharyngeal tissues

Expression Analysis of Ribosomal Protein Genes, eL13 and eL14 in Nasopharyngeal Carcinoma Cell Lines

Increasing evidence of the association between ribosomal protein (RP) genes with nasopharyngeal carcinoma (NPC) have been derived from findings of their differential expression patterns in NPC cell lines. Nevertheless, expression data from a comprehensive list of RP gene family members is still lacking. This paper reports the assessment of two RP genes, eL13 and eL14, with regards to their expression patterns in several NPC cell lines (TW04, TW01, HK1, HONE1 and SUNE-1) relative to a non-malignant control (NP69). A conventional Reverse Transcriptase-Polymerase Chain Reaction (RT-PCR) assay was employed. Analysis of eL13 has never been explored before this, whereas investigation of eL14 represents an extended study. We found a general over-expression trend of eL14 in 40% (2 of 5; TW01 and HONE-1) of the NPC cell lines studied, with higher upregulated level in only one (TW01) of them. However, this pattern of expression level is not statistically significant. Expression of eL13 was not detected in any of the cell lines used. The inconsistency of these expression patterns demonstrates an elusive nature of RP activities in the malignancy of the nasopharynx