A Murder Most Fowl: \u3ci\u3eUnited States v. CITGO Petroleum Corp.\u3c/i\u3e, 801 F.3d 477 (5th Cir. 2015), and Incidental Killings Under the Migratory Bird Treaty Act

I. Introduction II. Background ... A. God Save the Birds: The History of United States Environmental Protection Legislation and the U.S.–Great Britain Treaty ... B. No Clear Skies Ahead: The Relevant Sections of the MBTA ... C. Walking on Eggshells: The Federal Circuits Disagree on Whether Incidental Killings May Be Sanctioned Under the MBTA ... D. Ruffled Feathers: United States v. CITGO Petroleum Corp. and the Continued Confusion III. Analysis: Despite the Fifth Circuit’s Ruling, the MBTA’s Language Has an Expansive Wingspan ... A. The Sky Is the Limit: The MBTA’s Language and Legislative History Support Sanctioning Incidental Taking of Protected Birds … 1. Taking a Different Direction: The MBTA’s Plain Language Supports Misdemeanor Penalties for Incidental Takings ... 2. Under Congress’s Wing: The MBTA’s Legislative History Supports MBTA Penalties for Misdemeanor Incidental Takings ... B. Migrating in the Right Direction: Persuasive Policy Considerations for Sanctioning Incidental Killings … 1. Compliance at 5000 Feet: International Obligations and Department of the Interior’s Regulations ... 2. Not Just Winging It: Extending Violations of the MBTA to Include Incidental Killing Does Not Risk Inappropriate Sanctions IV. Conclusio

PD-L1 partially protects renal tubular epithelial cells from the attack of CD8+cytotoxic T cells

Background. Activated infiltrating T cells play a crucial role in nephritic inflammation via the direct interaction with proximal tubular epithelial cells (TEC). Under inflammatory conditions, major histocompatibility complex class I and II molecules are upregulated on the surface of renal TEC, enabling them to function as ‘non-professional' antigen-presenting cells (APC) to activate T cells, and, in turn to be targeted by cytotoxic T lymphocytes (CTL) to cause tissue damage. It is known that co-stimulatory (e.g. B7/CD28) and co-inhibitory (e.g. PD-L1/PD-1) signals regulate and determine the magnitude of T cell responses. In this study, we examined the expression of co-stimulatory molecule PD-L1 by renal TEC and the functional role of renal PD-L1/PD-1 pathway in regulating CD8+ T cell responses induced by antigen-presenting renal TEC. Methods. Renal TEC were treated with type I and type II interferons (IFN-α, IFN-β or IFN-γ). PD-L1 expression was then determined with flow cytometry and RT-PCR. To investigate the functional role of renal epithelial PD-L1 on CD8+ CTL responses, H-2Kb-restricted, OVA257-264 peptide-specific CD8+ T cells isolated from OT-1 T cell receptor transgenic mice were co-incubated with IFN-stimulated, OVA257-264 peptide-pulsed congeneic TEC. The activation of OT-1 CD8+ CTL was estimated either by IFN-γ production in the supernatants of co-cultures or by CTL activity. Results. TECs do not constitutively express PD-L1 on their surface. However, a strong and dose-dependent upregulation of PD-L1 was observed on TEC after stimulation with IFN-β or IFN-γ, but not with IFN-α. OVA257-264 peptide pulsed-TEC were able to activate OT-1 CD8+ T cells, indicated by the high amount of IFN-γ production and cytolysis of TEC. Blockade of epithelial PD-L1 with specific mAb significantly increased OT-1 CD8+ T cell activity, indicating that the PD-L1 pathway has a negative effect on CD8+ T cell responses. Moreover, IFN- β- or IFN-γ-stimulated TEC with high surface PD-L1 expression were more resistant to the cytolysis by OT-1 CTL. Conclusion. Together our data reveal that the renal PD-L1/PD-1 pathway has a negative effect on CD8+ CTL activation. PD-L1 might, therefore, act as a protective molecule on TEC, downregulating the cytotoxic renal parenchymal immune respons

Comportement magneto-mécanique dissipatif des matériaux ferromagnétiques sous chargement mécanique multiaxial.

4National audienceDans l'état de l'art actuel, les parties électrotechniques représentent environ 35% de la masse des équipements de la chaîne de puissance électrique, et les technologies actuellement utilisées ont atteint leur seuil d'optimisation. Pour atteindre les objectifs de réduction de masse et d'augmentation de la densité de puissance massique, il est impératif de trouver un ensemble de solutions cohérentes permettant d'optimiser l'ensemble des systèmes électriques embarqués. L'augmentation de la puissance massique de ces équipements passera donc par l'augmentation de la contrainte admissible des matériaux magnétiques utilisés mais aussi par l'approfondissement des connaissances de leurs modes de défaillance. Les tâches concernées par ce travail regroupent la mise en évidence expérimentale des phénomènes de couplage magnéto-mécanique, la modélisation des lois de comportement des matériaux, ainsi qu'une mise en place d'une modélisation (type éléments finis) d'une nouvelle géométrie de rotor chez THALES AES, avec les comparaisons modèle/expérience qui s'imposent

Magnetoelastic modelling in soft nanocrystalline alloys

Magnetoelastic effects in ultra soft nanocrystalline alloys are investigated theoretically and experimentally. From Hc measurements, extraction of magnetoelastic contribution is carried out using a formalism obtained revisiting random anisotropy model (RAM) in the light of domain walls (DW) displacements, our approach based on theoretical investigations on the way of a reversal of a correlated volume (CV) located in the vicinity of a DW. Modelling of magnetoelastic effects shows that even in perfectly relaxed samples, a magnetoelastic contribution exists due to elastic frustration experienced by a CV during its magnetization reversal. Magnitude of this energy is large enough to drive coercivity of samples featuring grain diameter D around 10 nm, which are of major interest for applications

Evolutionary Political Economy: Content and Methods

In this paper we present the major theoretical and methodological pillars of evolutionary political economy. We proceed in four steps. Aesthetics: In chapter 1 the immediate appeal of evolutionary political economy as a specific scientific activity is described. Content: Chapter 2 explores the object of investigation of evolutionary political economy. Power: The third chapter develops the interplay between politics and economics. Methods: Chapter 4 focusses on the evolution of methods necessary for evolutionary political economy. The conclusion positions the field of evolutionary political economy – as we proposed to establish it in this paper - within the wider area of scientific activity. In particular, demarcation lines towards some fashionable economic schools (institutionalism, behavioural economics, post-Keynesianism, etc.) are indicated

Evolutionary Political Economy: Content and Methods

In this paper we present the major theoretical and methodological pillars of evolutionary political economy. We proceed in four steps. Aesthetics: In chapter 1 the immediate appeal of evolutionary political economy as a specific scientific activity is described. Content: Chapter 2 explores the object of investigation of evolutionary political economy. Power: The third chapter develops the interplay between politics and economics. Methods: Chapter 4 focusses on the evolution of methods necessary for evolutionary political economy. The conclusion positions the field of evolutionary political economy – as we proposed to establish it in this paper - within the wider area of scientific activity. In particular, demarcation lines towards some fashionable economic schools (institutionalism, behavioural economics, post-Keynesianism, etc.) are indicated

Models for Photon-photon Total Cross-sections

We present here a brief overview of recent models describing the photon-photon cross-section into hadrons. We shall show in detail results from the eikonal minijet model, with and without soft gluon summation.Comment: 7 pages, 5 figures, laTeX, requires espcrc2.sty. To appear in the Proceedings of Photon-99, Freiburg, 23 -27 May 99, labels in the figures 1,3,4,5 corrected, one typo in an equation correcte

Consumption & Class in Evolutionary Macroeconomics

This article contributes to the field of evolutionary macroeconomics by highlighting the dynamic interlinkages between micro-meso-macro with a Veblenian meso foundation in an agent-based macroeconomic model. Consumption is dependent on endogenously changing social class and signaling, such as bandwagon, Veblen and snob effects. In particular we test the macroeconomic effects of this meso foundation in a generic agent-based model of a closed artificial economy. The model is stock-flow consistent and builds upon local decision heuristics of heterogeneous agents characterized by bounded rationality and satisficing behavior. These agents include a multitude of households (workers and capitalists), firms, banks as well as a capital goods firm, a government and a central bank. Simulation experiments indicate co-evolutionary dynamics between signaling-by-consuming and firm specialization that eventually effect employment, consumer prices as well as other macroeconomic aggregates substantially

Consumption & Class in Evolutionary Macroeconomics

This article contributes to the field of evolutionary macroeconomics by highlighting the dynamic interlinkages between micro-meso-macro with a Veblenian meso foundation in an agent-based macroeconomic model. Consumption is dependent on endogenously changing social class and signaling, such as bandwagon, Veblen and snob effects. In particular we test the macroeconomic effects of this meso foundation in a generic agent-based model of a closed artificial economy. The model is stock-flow consistent and builds upon local decision heuristics of heterogeneous agents characterized by bounded rationality and satisficing behavior. These agents include a multitude of households (workers and capitalists), firms, banks as well as a capital goods firm, a government and a central bank. Simulation experiments indicate co-evolutionary dynamics between signaling-by-consuming and firm specialization that eventually effect employment, consumer prices as well as other macroeconomic aggregates substantially