Totally Class-Less?: Examining Bristol-Myer\u27s Applicability to Class Actions

In June 2017, the U.S. Supreme Court tightened the specific jurisdiction doctrine when it dismissed several plaintiffs’ claims in a mass tort action against pharmaceutical company Bristol-Myers Squibb (BMS) for lack of personal jurisdiction. The action was brought in a California state court and involved several hundred plaintiffs alleging that they were injured by Plavix, a drug BMS manufactures. The Supreme Court held that California could not constitutionally exercise personal jurisdiction over BMS as to the nonresident plaintiffs, who did not have an independent connection to California. While the nonresident plaintiffs argued that California had specific jurisdiction because their claims were identical to the California residents’ claims (with the only difference being that their experience with Plavix occurred in other states), the Court held that these claims did not arise out of BMS’s contacts with California, but rather out of BMS’s contacts with the particular states in which these plaintiffs were injured. In so holding, the Court emphasized that enabling California to exercise jurisdiction in this context would infringe on the sovereignty of other states—more specifically, the states who housed the nonresident plaintiffs involved in the action. This Note explores whether class actions should be bound by this decision. The fundamental question, then, is whether class actions are meaningfully distinguishable from mass tort actions such that they avoid Bristol-Myers’s reach

Strategies to achieve adequate vitamin A intake for young children: options for Cameroon.

Meeting children's vitamin A (VA) needs remains a policy priority. Doing so efficiently is a fiscal imperative and protecting at-risk children during policy transitions is a moral imperative. Using the Micronutrient Intervention Modeling tool and data for Cameroon, we predict the impacts and costs of alternative VA intervention programs, identify the least-cost strategy for meeting targets nationally, and compare it to a business-as-usual (BAU) strategy over 10 years. BAU programs effectively cover ∼12.8 million (m) child-years (CY) and cost ∼$30.1 m; ∼US$2.34 per CY effectively covered. Improving the VA-fortified oil program, implementing a VA-fortified bouillon cube program, and periodic VA supplements (VAS) in the North macroregion for 3 years effectively cover ∼13.1 m CY at a cost of ∼US$9.5 m, or ∼US$0.71 per CY effectively covered. The tool then identifies a sequence of subnational policy choices leading from the BAU toward the more efficient strategy, while addressing VA-attributable mortality concerns. By year 4, fortification programs are predicted to eliminate inadequate VA intake in the South and Cities macroregions, but not the North, where VAS should continue until additional delivery platforms are implemented. This modeling approach offers a concrete example of the strategic use of data to follow the Global Alliance for VA framework and do so efficiently

Bisphosphonate's and Intermittent Parathyroid Hormone's Effect on Human Spinal Fusion: A Systematic Review of the Literature.

There has been a conscious effort to address osteoporosis in the aging population. As bisphosphonate and intermittent parathyroid hormone (PTH) therapy become more widely prescribed to treat osteoporosis, it is important to understand their effects on other physiologic processes, particularly the impact on spinal fusion. Despite early animal model studies and more recent clinical studies, the impact of these medications on spinal fusion is not fully understood. Previous animal studies suggest that bisphosphonate therapy resulted in inhibition of fusion mass with impeded maturity and an unknown effect on biomechanical strength. Prior animal studies demonstrate an improved fusion rate and fusion mass microstructure with the use of intermittent PTH. The purpose of this study was to determine if bisphosphonates and intermittent PTH treatment have impact on human spinal fusion. A systematic review of the literature published between 1980 and 2015 was conducted using major electronic databases. Studies reporting outcomes of human subjects undergoing 1, 2, or 3-level spinal fusion while receiving bisphosphonates and/or intermittent PTH treatment were included. The results of relevant human studies were analyzed for consensus on the effects of these medications in regards to spinal fusion. There were nine human studies evaluating the impact of these medications on spinal fusion. Improved fusion rates were noted in patients receiving bisphosphonates compared to control groups, and greater fusion rates in patients receiving PTH compared to control groups. Prior studies involving animal models found an improved fusion rate and fusion mass microstructure with the use of intermittent PTH. No significant complications were demonstrated in any study included in the analysis. Bisphosphonate use in humans may not be a deterrent to spinal fusion. Intermittent parathyroid use has shown early promise to increase fusion mass in both animal and human studies but further studies are needed to support routine use

Quantum Bubble Nucleation beyond WKB: Resummation of Vacuum Bubble Diagrams

On the basis of Borel resummation, we propose a systematical improvement of bounce calculus of quantum bubble nucleation rate. We study a metastable super-renormalizable field theory, $D$ dimensional O(N) symmetric $\phi^4$ model ($D<4$) with an attractive interaction. The validity of our proposal is tested in D=1 (quantum mechanics) by using the perturbation series of ground state energy to high orders. We also present a result in D=2, based on an explicit calculation of vacuum bubble diagrams to five loop orders.Comment: 19 pages, 5 figures, PHYZZ

Counting Statistics of an Adiabatic Pump

We consider quantum statistics of charge transmitted through a mesoscopic device in the adiabatic pumping process. A general formula for the distribution function of the transmitted charge in terms of the time-dependent S-matrix is obtained. It is applied to a few simple examples of the pumping cycles. We identify coherent pumping strategies which lead to the binomial charge distribution and minimize the fluctuations of the pumped current. Conditions for the ideal noiseless quantized pump are discussed.Comment: 4 page

Correlation Functions of Harish-Chandra Integrals over the Orthogonal and the Symplectic Groups

The Harish-Chandra correlation functions, i.e. integrals over compact groups of invariant monomials prod tr{X^{p_1} Omega Y^{q_1} Omega^dagger X^{p_2} ... with the weight exp tr{X Omega Y Omega^dagger} are computed for the orthogonal and symplectic groups. We proceed in two steps. First, the integral over the compact group is recast into a Gaussian integral over strictly upper triangular complex matrices (with some additional symmetries), supplemented by a summation over the Weyl group. This result follows from the study of loop equations in an associated two-matrix integral and may be viewed as the adequate version of Duistermaat-Heckman's theorem for our correlation function integrals. Secondly, the Gaussian integration over triangular matrices is carried out and leads to compact determinantal expressions.Comment: 58 pages; Acknowledgements added; small corrections in appendix A; minor changes & Note Adde

Parameterization of single-scattering albedo (SSA) and absorption Ångström exponent (AAE) with EC/OC for aerosol emissions from biomass burning

Single-scattering albedo (SSA) and absorption Ångström exponent (AAE) are two critical parameters in determining the impact of absorbing aerosol on the Earth\u27s radiative balance. Aerosol emitted by biomass burning represent a significant fraction of absorbing aerosol globally, but it remains difficult to accurately predict SSA and AAE for biomass burning aerosol. Black carbon (BC), brown carbon (BrC), and non-absorbing coatings all make substantial contributions to the absorption coefficient of biomass burning aerosol. SSA and AAE cannot be directly predicted based on fuel type because they depend strongly on burn conditions. It has been suggested that SSA can be effectively parameterized via the modified combustion efficiency (MCE) of a biomass burning event and that this would be useful because emission factors for CO and CO2, from which MCE can be calculated, are available for a large number of fuels. Here we demonstrate, with data from the FLAME-4 experiment, that for a wide variety of globally relevant biomass fuels, over a range of combustion conditions, parameterizations of SSA and AAE based on the elemental carbon (EC) to organic carbon (OC) mass ratio are quantitatively superior to parameterizations based on MCE. We show that the EC/OC ratio and the ratio of EC/(EC + OC) both have significantly better correlations with SSA than MCE. Furthermore, the relationship of EC/(EC + OC) with SSA is linear. These improved parameterizations are significant because, similar to MCE, emission factors for EC (or black carbon) and OC are available for a wide range of biomass fuels. Fitting SSA with MCE yields correlation coefficients (Pearson\u27s r) of ∼0.65 at the visible wavelengths of 405, 532, and 660 nm while fitting SSA with EC/OC or EC/(EC + OC) yields a Pearson\u27s r of 0.94-0.97 at these same wavelengths. The strong correlation coefficient at 405 nm (r = 0.97) suggests that parameterizations based on EC/OC or EC/(EC + OC) have good predictive capabilities even for fuels in which brown carbon absorption is significant. Notably, these parameterizations are effective for emissions from Indonesian peat, which have very little black carbon but significant brown carbon (SSA = 0.990 ± 0.001 at 532 and 660 nm, SSA = 0.937 ± 0.011 at 405 nm). Finally, we demonstrate that our parameterization based on EC/(EC + OC) accurately predicts SSA during the first few hours of plume aging with data from Yokelson et al. (2009) gathered during a biomass burning event in the Yucatán Peninsula of Mexico

Comorbidities, exposure to medications, and the risk of community-acquired clostridium difficile infection: a systematic review and meta-analysis

Background. Clostridium difficile infection (CDI) has been extensively escribedin healthcare settings; however, risk factor sassociated with community-acquired (CA) CDI remain uncertain. This study aimed to synthesize the current evidence for an association between commonly prescribed medications and comorbidities with CA-CDI. methods. A systematic search was conducted in 5 electronic databases for epidemiologicstudi esthatexamined the associtation between the presence of comorbidities and exposure to medications with the risk of CA-CDI. Pooled odds ratios were estimated using 3 meta-analytic methods. Subgroup analyses by location of studies and by life stages were conducted. results. Twelve publications (n=56,776 patients) met inclusion criteria. Antimicrobial (odds ratio, 6.18; 95% CI, 3.80-10.04) and corticosteroid (1.81; 1.15-2.84) exposure were associated with increased risk of CA-CDI. Among the comorbidities, inflammatory bowel disease (odds ratio, 3.72; 95% CI, 1.52-9.12), renal failure (2.64; 1.23-5.68), hematologic cancer (1.75; 1.02-5.68), and diabetes mellitus (1.15; 1.05-1.27) were associated with CA-CDI. By location, antimicrobial exposure was associated with a higher risk of CA-CDI in the United States, whereas proton-pump inhibitor exposure was associated with a higher risk in Europe. By life stages, the risk of CA-CDI associated with antimicrobial exposure greatly increased in adults older than 65 years. conclusions. Antimicrobial exposure was the strongest risk factor associated with CA-CDI. Further studies are required to investigate the risk of CA-CDI associated with medications commonly prescribed in the community. Patients with diarrhea who have inflammatory bowel disease, renal failure, hematologic cancer, or diabetes are appropriate populations for interventional studies of screening

Simplifying External Load Data in NCAA Division-I Men\u27s Basketball Competitions: A Principal Component Analysis

The primary purpose was to simplify external load data obtained during Division-I (DI) basketball competitions via principal component analysis (PCA). A secondary purpose was to determine if the PCA results were sensitive to load demands of different positional groups (POS). Data comprised 229 observations obtained from 10 men\u27s basketball athletes participating in NCAA DI competitions. Each athlete donned an inertial measurement unit that was affixed to the same location on their shorts prior to competition. The PCA revealed two factors that possessed eigenvalues \u3e1.0 and explained 81.42% of the total variance. The first factor comprised total decelerations (totDEC, 0.94), average speed (avgSPD, 0.90), total accelerations (totACC, 0.85), total mechanical load (totMECH, 0.84), and total jump load (totJUMP, 0.78). Maximum speed (maxSPD, 0.94) was the lone contributor to the second factor. Based on the PCA, external load variables were included in a multinomial logistic regression that predicted POS (Overall model, p \u3c 0.0001; AUCcenters = 0.93, AUCguards = 0.88, AUCforwards = 0.80), but only maxSPD, totDEC, totJUMP, and totMECH were significant contributors to the model\u27s success (p \u3c 0.0001 for each). Even with the high significance, the model still had some issues differentiating between guards and forwards, as in-game demands often overlap between the two positions. Nevertheless, the PCA was effective at simplifying a large external load dataset collected on NCAA DI men\u27s basketball athletes. These data revealed that maxSPD, totDEC, totJUMP, and totMECH were the most sensitive to positional differences during competitions. To best characterize competition demands, such variables may be used to individualize training and recovery regimens most effectively

Relative importance of black carbon, brown carbon, and absorption enhancement from clear coatings in biomass burning emissions

A wide range of globally significant biomass fuels were burned during the fourth Fire Lab at Missoula Experiment (FLAME-4). A multi-channel photoacoustic absorption spectrometer (PAS) measured dry absorption at 405, 532, and 660 nm and thermally denuded (250 °C) absorption at 405 and 660 nm. Absorption coefficients were broken into contributions from black carbon (BC), brown carbon (BrC), and lensing following three different methodologies, with one extreme being a method that assumes the thermal denuder effectively removes organics and the other extreme being a method based on the assumption that black carbon (BC) has an Ångström exponent of unity. The methodologies employed provide ranges of potential importance of BrC to absorption but, on average, there was a difference of a factor of 2 in the ratio of the fraction of absorption attributable to BrC estimated by the two methods. BrC absorption at shorter visible wavelengths is of equal or greater importance to that of BC, with maximum contributions of up to 92 % of total aerosol absorption at 405 nm and up to 58 % of total absorption at 532 nm. Lensing is estimated to contribute a maximum of 30 % of total absorption, but typically contributes much less than this. Absorption enhancements and the estimated fraction of absorption from BrC show good correlation with the elemental-carbon-to-organic-carbon ratio (EC/OC) of emitted aerosols and weaker correlation with the modified combustion efficiency (MCE). Previous studies have shown that BrC grows darker (larger imaginary refractive index) as the ratio of black to organic aerosol (OA) mass increases. This study is consistent with those findings but also demonstrates that the fraction of total absorption attributable to BrC shows the opposite trend: increasing as the organic fraction of aerosol emissions increases and the EC/OC ratio decreases