Defamation Per Se and Transgender Status: When Macro-Level Value Judgments About Equality Trump Micro-Level Reputational Injury

This Article uses the September 2017 defamation decision in Simmons v. American Media, Inc. as a springboard for examining defamatory meaning and reputational injury. Specifically, it focuses on cases in which judges acknowledge that plaintiffs have suffered reputational harm yet rule for defendants because promoting the cultural value of equality weighs against redress. In Simmons, a normative, axiological judgment--that the law should neither sanction nor ratify prejudicial views about transgender individuals-- prevailed at the trial court level over a celebrity\u27s ability to recover for alleged reputational harm. Simmons sits at a dangerous intersection: a crossroads where a noble judicial desire to reject prejudicial stereotypes and to embrace equality collides head-on with an ignoble reality in which a significant minority of the population finds a particular false allegation (in Simmons, transgender status) to be defamatory. This Article examines how courts historically determined defamatory meaning and how once-defamatory per se statements about sexual orientation are not always considered so today. When viewed beyond a legal lens, however, research suggests transgender individuals have not witnessed the same benefits of that altered perspective. There is a key difference between attitudes about sexual orientation and attitudes about sexual identity. The Article concludes by proposing variables for courts to apply in future cases where a dispute exists over whether an allegation is defamatory per se, rather than leaving the decision to the discretion of judges untethered from formal criteria

Future Needs of the Cybersecurity Workforce

Expected growth of the job market for cyber security professionals in both the US and the UK remains strong for the foreseeable future. While there are many roles to be found in cyber security, that vary from penetration tester to chief information security officer (CISO). One job of particular interest is security architect. The rise in Zero Trust Architecture (ZTA) implementations, especially in the cloud environment, promises an increase in the demand for these security professionals. A security architect requires a set of knowledge, skills, and abilities covering the responsibility for integrating the various security components to successfully support an organization’s goals. In order to achieve the goal of seamless integrated security, the architect must combine technical skills with business, and interpersonal skills. Many of these same skills are required of the CISO, suggesting that the role of security architect may be a professional stepping-stone to the role of CISO. We expected degreed programs to offer courses in security architecture. Accredited university cyber security programs in the United Kingdom (UK) and the United States of America (USA) were examined for course offerings in security architecture. Results found the majority of programs did not offer a course in security architecture. Considering the role of the universities in preparing C-suite executives, the absence of cyber security architecture offerings is both troubling and surprising

Cyber-Informed: Bridging Cybersecurity and Other Disciplines

A recent study by Cybersecurity Ventures (Morgan 2018), predicts that 3.5 million cybersecurity jobs around the world will be unfilled by 2021. In the United States, the demand for professionals with cybersecurity expertise is outpacing all other occupations (NIST 2018). These reports, along with many others, underpin the need for increasing workforce development initiatives founded in cybersecurity principles. The workforce shortage is across all cybersecurity domains, yet problems continue to persist, as the lines between combatants and non-combatants are blurred. Combating this persistent threat, which is a 24/7 operation, requires a more aggressive and inclusive approach. Higher education institutions are positioned to fully support cybersecurity workforce development; cybersecurity needs people with different perspectives, approaches, ways of thinking, and methods to solve current and emerging cyber challenges. This need is especially pressing when assessing the digital landscape - a tireless and ever-expanding connectivity supported by societal needs, and economic development yet compromised by the common criminal to nation-state sponsored felonious activity. Educators need to consider augmenting their approaches to educating students to include cybersecurity content. In this technology forward world, one that is expanding more rapidly than society and policy can react, increases the imperative for fundamental cyber defence skills. Accordingly, all students, no matter the major, should, minimally, understand the implications of good versus bad cyber hygiene. STEM graduates will require awareness of cyber issues that impact the security of programs, systems, codes or algorithms that they design. Operationally focused cyber-security graduates require a curriculum for careers dedicated to protecting and defending cyber systems in domain specific environments. In a world of Internet of Things (IoT), the ability for individual disciplines to understand the impact of cyber events in environments outside of traditional cybersecurity networks is critically important. This will provide the next generation defenders with domain specific cybersecurity knowledge that is applicable to specific operating environments

Identification of Differential Gene Expression in Brassica rapa Nectaries through Expressed Sequence Tag Analysis

BACKGROUND: Nectaries are the floral organs responsible for the synthesis and secretion of nectar. Despite their central roles in pollination biology, very little is understood about the molecular mechanisms underlying nectar production. This project was undertaken to identify genes potentially involved in mediating nectary form and function in Brassica rapa. METHODOLOGY AND PRINCIPAL FINDINGS: Four cDNA libraries were created using RNA isolated from the median and lateral nectaries of B. rapa flowers, with one normalized and one non-normalized library being generated from each tissue. Approximately 3,000 clones from each library were randomly sequenced from the 5' end to generate a total of 11,101 high quality expressed sequence tags (ESTs). Sequence assembly of all ESTs together allowed the identification of 1,453 contigs and 4,403 singleton sequences, with the Basic Localized Alignment Search Tool (BLAST) being used to identify 4,138 presumptive orthologs to Arabidopsis thaliana genes. Several genes differentially expressed between median and lateral nectaries were initially identified based upon the number of BLAST hits represented by independent ESTs, and later confirmed via reverse transcription polymerase chain reaction (RT PCR). RT PCR was also used to verify the expression patterns of eight putative orthologs to known Arabidopsis nectary-enriched genes. CONCLUSIONS/SIGNIFICANCE: This work provided a snapshot of gene expression in actively secreting B. rapa nectaries, and also allowed the identification of differential gene expression between median and lateral nectaries. Moreover, 207 orthologs to known nectary-enriched genes from Arabidopsis were identified through this analysis. The results suggest that genes involved in nectar production are conserved amongst the Brassicaceae, and also supply clones and sequence information that can be used to probe nectary function in B. rapa

Systems analyses of key metabolic modules of floral and extrafloral nectaries of cotton

Nectar is a primary reward mediating plant-animal mutualisms to improve plant fitness and reproductive success. In Gossypium hirsutum (cotton), four distinct trichomatic nectaries develop, one floral and three extrafloral. The secreted floral and extrafloral nectars serve different purposes, with the floral nectar attracting bees to promote pollination and the extrafloral nectar attracting predatory insects as a means of indirect resistance from herbivores. Cotton therefore provides an ideal system to contrast mechanisms of nectar production and nectar composition between floral and extrafloral nectaries. Here, we report the transcriptome, ultrastructure, and metabolite spatial distribution using mass spectrometric imaging of the four cotton nectary types throughout development. Additionally, the secreted nectar metabolomes were defined and were jointly composed of 197 analytes, 60 of which were identified. Integration of theses datasets support the coordination of merocrine-based and eccrine-based models of nectar synthesis. The nectary ultrastructure supports the merocrine-based model due to the abundance of rough endoplasmic reticulum positioned parallel to the cell walls and profusion of vesicles fusing to the plasma membranes. The eccrine-based model which consist of a progression from starch synthesis to starch degradation and to sucrose biosynthesis was supported by gene expression data. This demonstrates conservation of the eccrine-based model for the first time in both trichomatic and extrafloral nectaries. Lastly, nectary gene expression data provided evidence to support de novo synthesis of amino acids detected in the secreted nectars

PIN6 is required for nectary auxin response and short stamen development

Peer Reviewedhttp://deepblue.lib.umich.edu/bitstream/2027.42/98417/1/tpj12184-sup-0001-FigS1.pdfhttp://deepblue.lib.umich.edu/bitstream/2027.42/98417/2/tpj12184.pdfhttp://deepblue.lib.umich.edu/bitstream/2027.42/98417/3/tpj12184-sup-0004-FigS4.pdfhttp://deepblue.lib.umich.edu/bitstream/2027.42/98417/4/tpj12184-sup-0003-FigS3.pdfhttp://deepblue.lib.umich.edu/bitstream/2027.42/98417/5/tpj12184-sup-0002-FigS2.pdfhttp://deepblue.lib.umich.edu/bitstream/2027.42/98417/6/tpj12184-sup-0005-FigS5.pd

Defamation Per Se and Transgender Status: When Macro-Level Value Judgments About Equality Trump Micro-Level Reputational Injury

This Article uses the September 2017 defamation decision in Simmons v. American Media, Inc. as a springboard for examining defamatory meaning and reputational injury. Specifically, it focuses on cases in which judges acknowledge that plaintiffs have suffered reputational harm yet rule for defendants because promoting the cultural value of equality weighs against redress. In Simmons, a normative, axiological judgment--that the law should neither sanction nor ratify prejudicial views about transgender individuals-- prevailed at the trial court level over a celebrity\u27s ability to recover for alleged reputational harm. Simmons sits at a dangerous intersection: a crossroads where a noble judicial desire to reject prejudicial stereotypes and to embrace equality collides head-on with an ignoble reality in which a significant minority of the population finds a particular false allegation (in Simmons, transgender status) to be defamatory. This Article examines how courts historically determined defamatory meaning and how once-defamatory per se statements about sexual orientation are not always considered so today. When viewed beyond a legal lens, however, research suggests transgender individuals have not witnessed the same benefits of that altered perspective. There is a key difference between attitudes about sexual orientation and attitudes about sexual identity. The Article concludes by proposing variables for courts to apply in future cases where a dispute exists over whether an allegation is defamatory per se, rather than leaving the decision to the discretion of judges untethered from formal criteria

Cyber-Informed: Bridging Cybersecurity and Other Disciplines

A recent study by Cybersecurity Ventures (Morgan 2018), predicts that 3.5 million cybersecurity jobs around the world will be unfilled by 2021. In the United States, the demand for professionals with cybersecurity expertise is outpacing all other occupations (NIST 2018). These reports, along with many others, underpin the need for increasing workforce development initiatives founded in cybersecurity principles. The workforce shortage is across all cybersecurity domains, yet problems continue to persist, as the lines between combatants and non-combatants are blurred. Combating this persistent threat, which is a 24/7 operation, requires a more aggressive and inclusive approach. Higher education institutions are positioned to fully support cybersecurity workforce development; cybersecurity needs people with different perspectives, approaches, ways of thinking, and methods to solve current and emerging cyber challenges. This need is especially pressing when assessing the digital landscape — a tireless and ever-expanding connectivity supported by societal needs, and economic development yet compromised by the common criminal to nation-state sponsored felonious activity. Educators need to consider augmenting their approaches to educating students to include cybersecurity content. In this technology forward world, one that is expanding more rapidly than society and policy can react, increases the imperative for fundamental cyber defence skills. Accordingly, all students, no matter the major, should, minimally, understand the implications of good versus bad cyber hygiene. STEM graduates will require awareness of cyber issues that impact the security of programs, systems, codes or algorithms that they design. Operationally focused cyber-security graduates require a curriculum for careers dedicated to protecting and defending cyber systems in domain specific environments. In a world of Internet of Things (IoT), the ability for individual disciplines to understand the impact of cyber events in environments outside of traditional cybersecurity networks is critically important. This will provide the next generation defenders with domain specific cybersecurity knowledge that is applicable to specific operating environments