Causation and Injury in Corporate Control Transactions: \u3ci\u3eCede & Co. v. Technicolor, Inc.\u3c/i\u3e

In Cede & Co. v. Technicolor, Inc., the Delaware Supreme Court held that shareholders are not required to prove injury from corporate directors\u27 failure to exercise due care in approving a merger transaction. Tort principles, the court stated, have no role in a business judgment rule analysis. Therefore, once shareholders prove a violation of the directors\u27 duty of care, the burden is shifted to the directors to prove the entire fairness of the transaction despite the absence of a breach of the duty of loyalty. This Note argues that the entire fairness review of a disinterested board transaction is unworkable. Rather, courts should use tort principles to analyze a breach of the duty of care, and those principles require plaintiffs to prove causation and resulting injury. Because proving causation to an absolute certainty in the corporate control setting can be forbidding, this Note proposes a substantial lost chance causation standard as a more viable alternative

Herschel-ATLAS: statistical properties of Galactic cirrus in the GAMA-9 Hour Science Demonstration Phase Field

We study the spectral energy distribution (SED) and the power spectrum of Galactic cirrus emission observed in the 14 deg^2 Science Demonstration Phase field of the Herschel-ATLAS using Herschel and IRAS data from 100 to 500 μm. We compare the Spectral and Photometric Imaging Receiver (SPIRE) 250, 350 and 500 μm maps with IRAS 100-μm emission, binned in 6-arcmin pixels. We assume a modified blackbody SED with dust emissivity parameter β (F∝λ^(−β)) and a single dust temperature T_d, and find that the dust temperature and emissivity index varies over the science demonstration field as 10 < T_d < 25K and 1 < β < 4. The latter values are somewhat higher than the range of β often quoted in the literature (1 < β < 2). We estimate the mean values of these parameters to be T_d= 19.0 ± 2.4 K and β= 1.4 ± 0.4. In regions of bright cirrus emission, we find that the dust has similar temperatures with T_d = 18.0 ± 2.5 K, and similar values of β, ranging from 1.4 ± 0.5 to 1.9 ± 0.5. We show that T_d and β associated with diffuse cirrus emission are anti-correlated and can be described by the relationship: β(T_d) =NT^α_d with [N= 116 ± 38, α=−1.4 ± 0.1]. The strong correlation found in this analysis is not just limited to high-density clumps of cirrus emission as seen in previous studies, but is also seen in diffuse cirrus in low-density regions. To provide an independent measure of T_d and β, we obtain the angular power spectrum of the cirrus emission in the IRAS and SPIRE maps, which is consistent with a power spectrum of the form P(k) =P_0(k/k_0)^γ, where γ= 2.6 ± 0.2 for scales of 50–200 arcmin in the SPIRE maps. The cirrus rms fluctuation amplitude at angular scales of 100 arcmin is consistent with a modified blackbody SED with T_d 20.1 ± 0.9 K and β= 1.3 ± 0.2, in agreement with the values obtained above

LIBERAL EGALITARIANISM AND THE HARM PRINCIPLE

We analyse the implications of classical liberal and libertarian approaches for distributive justice in the context of social welfare orderings. We study an axiom capturing a liberal non-interfering view of society, Weak Harm Principle, whose roots can be traced back to John Stuart Mill. We show that liberal views of individual autonomy and freedom can provide consistent foundations for welfare judgements. In particular, a liberal non-interfering approach can help to adjudicate some fundamental distributive issues relative to intergenerational justice. However, a strong relation is established between liberal views of individual autonomy and non-interference, and egalitarian principles in the Rawlsian tradition

The Hi-GAL compact source catalogue – I. The physical properties of the clumps in the inner Galaxy (−71∘.0 < ℓ < 67∘0)

Hi-GAL (Herschel InfraRed Galactic Plane Survey) is a large-scale survey of the Galactic plane, performed with Herschel in five infrared continuum bands between 70 and 500 μm. We present a band-merged catalogue of spatially matched sources and their properties derived from fits to the spectral energy distributions (SEDs) and heliocentric distances, based on the photometric catalogues presented in Molinari et al., covering the portion of Galactic plane −71∘.0 < ℓ < 67∘.0. The band-merged catalogue contains 100 922 sources with a regular SED, 24 584 of which show a 70-μm counterpart and are thus considered protostellar, while the remainder are considered starless. Thanks to this huge number of sources, we are able to carry out a preliminary analysis of early stages of star formation, identifying the conditions that characterize different evolutionary phases on a statistically significant basis. We calculate surface densities to investigate the gravitational stability of clumps and their potential to form massive stars. We also explore evolutionary status metrics such as the dust temperature, luminosity and bolometric temperature, finding that these are higher in protostellar sources compared to pre-stellar ones. The surface density of sources follows an increasing trend as they evolve from pre-stellar to protostellar, but then it is found to decrease again in the majority of the most evolved clumps. Finally, we study the physical parameters of sources with respect to Galactic longitude and the association with spiral arms, finding only minor or no differences between the average evolutionary status of sources in the fourth and first Galactic quadrants, or between ‘on-arm’ and ‘interarm’ positions

Simulation Results on the Impact of Changes in the Main EU Policy Tools on Farm Investment Behaviour. Factor Markets Working Document No. 56, June 2013

This paper completes the comparative analysis of the investment demand behaviour, of a sample of specialised arable crop farms, for farm buildings and machinery and equipment, as a function of the different types and levels of Common Agricultural Policy support, in selected European Union Member States. This contribution focuses on their quantitative interdependence calculating the relevant elasticity measures. In turn, they constitute the methodological tool to simulate the percentage expected change in average net investment levels associated to the implementation of the, recently proposed and currently under discussion, reductions in the Pillar I Direct Payments disbursed under the Common Agricultural Policy. Evidence suggests a statistically significant elastic and inelastic relationship between both types of subsidies and the investment levels for both asset classes in Germany and Italy, respectively. An elastic dependence of investment in farm buildings on decoupled subsidies exists in Hungary while changes in the level of coupled payments appear to translate into less than proportional changes in the demand for both farm buildings and machinery and equipment in France. Coupled payments appear to influence the UK demand for both asset classes in an elastic manner while decoupled support seems to induce a similar effect on investment in machinery and equipment. Since the currently discussed Common Agricultural Policy reform options imply, almost exclusively, a reduction in the level of support granted through Direct Payments, simulated effects were expected to reveal a worsening of the farm investment prospects for both asset types (i.e., a larger negative investment or a smaller positive one). The actual evidence largely respects this expectation with the sole exception of investment in machinery and equipment in France and Italy reaching smaller negative or larger positive levels irrespectively of the magnitude of the implemented cuts in Direct Payments

Spitzer And Herschel Multiwavelength Characterization Of The Dust Content Of Evolved H Ii Regions

We have analyzed a uniform sample of 16 evolved H II regions located in a 2 Degree-Sign Multiplication-Sign 2 Degree-Sign Galactic field centered at (l,b) = (30 Degree-Sign , 0 Degree-Sign ) and observed as part of the Herschel Hi-GAL survey. The evolutionary stage of these H II regions was established using ancillary radio-continuum data. By combining Hi-GAL PACS (70 {mu}m, 160 {mu}m) and SPIRE (250 {mu}m, 350 {mu}m, and 500 {mu}m) measurements with MIPSGAL 24 {mu}m data, we built spectral energy distributions of the sources and showed that a two-component gray-body model is a good representation of the data. In particular, wavelengths \u3e70 {mu}m appear to trace a cold dust component, for which we estimated an equilibrium temperature of the big grains (BGs) in the range 20-30 K, while for {lambda} \u3c 70 {mu}m, the data indicate the presence of a warm dust component at temperatures of the order of 50-90 K. This analysis also revealed that dust is present in the interior of H II regions, although likely not in a large amount. In addition, the data seem to corroborate the hypothesis that the main mechanism responsible for the (partial) depletion of dust in H II regions ismore » radiation-pressure-driven drift. In this framework, we speculated that the 24 {mu}m emission that spatially correlates with ionized gas might be associated with either very small grain or BG replenishment, as recently proposed for the case of wind-blown bubbles. Finally, we found that evolved H II regions are characterized by distinctive far-IR and submillimeter colors, which can be used as diagnostics for their identification in unresolved Galactic and extragalactic regions.« les

LANDSAT and radar mapping of intrusive rocks in SE-Brazil

The feasibility of intrusive rock mapping was investigated and criteria for regional geological mapping established at the scale of 1:500,00 in polycyclic and polymetamorphic areas using the logic method of photointerpretation of LANDSAT imagery and radar from the RADAMBRASIL project. The spectral behavior of intrusive rocks, was evaluated using the interactive multispectral image analysis system (Image-100). The region of Campos (city) in northern Rio de Janeiro State was selected as the study area and digital imagery processing and pattern recognition techniques were applied. Various maps at the 2:250,000 scale were obtained to evaluate the results of automatic data processing

Hi-GAL, the Herschel infrared Galactic Plane Survey: photometric maps and compact source catalogues: First data release for the inner Milky Way: +68° ≥ / ≥ 70°

Aims. We present the first public release of high-quality data products (DR1) from Hi-GAL, the Herschel infrared Galactic Plane Survey. Hi-GAL is the keystone of a suite of continuum Galactic plane surveys from the near-IR to the radio and covers five wavebands at 70, 160, 250, 350 and 500 μm, encompassing the peak of the spectral energy distribution of cold dust for 8 ≲ T ≲ 50 K. This first Hi-GAL data release covers the inner Milky Way in the longitude range 68° ≳ ℓ ≳ −70° in a | b | ≤ 1° latitude strip. Methods. Photometric maps have been produced with the ROMAGAL pipeline, which optimally capitalizes on the excellent sensitivity and stability of the bolometer arrays of the Herschel PACS and SPIRE photometric cameras. It delivers images of exquisite quality and dynamical range, absolutely calibrated with Planck and IRAS, and recovers extended emission at all wavelengths and all spatial scales, from the point-spread function to the size of an entire 2°× 2° “tile” that is the unit observing block of the survey. The compact source catalogues were generated with the CuTEx algorithm, which was specifically developed to optimise source detection and extraction in the extreme conditions of intense and spatially varying background that are found in the Galactic plane in the thermal infrared. Results. Hi-GAL DR1 images are cirrus noise limited and reach the 1σ-rms predicted by the Herschel Time Estimators for parallel-mode observations at 60"^(s-1) scanning speed in relatively low cirrus emission regions. Hi-GAL DR1 images will be accessible through a dedicated web-based image cutout service. The DR1 Compact Source Catalogues are delivered as single-band photometric lists containing, in addition to source position, peak, and integrated flux and source sizes, a variety of parameters useful to assess the quality and reliability of the extracted sources. Caveats and hints to help in this assessment are provided. Flux completeness limits in all bands are determined from extensive synthetic source experiments and greatly depend on the specific line of sight along the Galactic plane because the background strongly varies as a function of Galactic longitude. Hi-GAL DR1 catalogues contain 123210, 308509, 280685, 160972, and 85460 compact sources in the five bands

Detection and characterization of a 500 μm dust emissivity excess in the Galactic plane using Herschel/Hi-GAL observations

Context. Past and recent observations have revealed unexpected variations in the far-infrared – millimeter (FIR-mm) dust emissivity in the interstellar medium. In the Herschel spectral range, those are often referred to as a 500 μm emission excess. Several dust emission models have been developed to interpret astrophysical data in the FIR-mm domain. However, these are commonly unable to fully reconcile theoretical predictions with observations. In contrast, the recently revised two level system (TLS) model, based on the disordered internal structure of amorphous dust grains, seems to provide a promising way of interpreting existing data. Aims. The newly available Herschel infrared GALactic (Hi-GAL) data, which covers most of the inner Milky Way, offers a unique opportunity to investigate possible variations in the dust emission properties both with wavelength and environment. The goal of our analysis is to constrain the internal structure of the largest dust grains on Galactic scales, in the framework of the TLS model. Methods. By combining the IRIS (Improved Reprocessing of the IRAS Survey) 100 μm with the Hi-GAL 160, 250, 350, and 500 μm data, we model the dust emission spectra in each pixel of the Hi-GAL maps, using both the TLS model and, for comparison, a single modified black-body fit. The effect of temperature mixing along the line of sight is investigated to test the robustness of our results. Results. We find a slight decrease in the dust temperature with distance from the Galactic center, confirming previous results. We also report the detection of a significant 500 μm emissivity excess in the peripheral regions of the plane (35° < |l| < 70°) of about 13–15% of the emissivity, which can reach up to 20% in some HII regions. We present the spatial distributions of the best-fit values for the two main parameters of the TLS model, i.e. the charge correlation length, lc, used to characterize the disordered charge distribution (DCD) part of the model, and the amplitude A of the TLS processes with respect to the DCD effect. These distributions illustrate the variations in the dust properties with environment, in particular the plausible existence of an overall gradient with distance to the Galactic center. A comparison with previous findings in the solar neighborhood shows that the local value of the excess is less than expected from the Galactic gradient observed here