PROCESS--IMMUNITY FROM SERVICE--PERSON ENTERING A STATE TO FILE AN ACTION

Petitioner, a resident of Missouri, entered California to gain custody of his child from its maternal grandmother. After eight days of fruitless negotiation he commenced habeas corpus proceedings. While attempting to serve the writ of habeas corpus, petitioner was served with a summons in an action brought by the grandmother for support of the child. When the trial court denied petitioner\u27s motion to quash the service of summons on him, he sought a writ of prohibition from the district court of appeals to prevent further prosecution of the second action. Held, petition denied; petitioner\u27s eight day delay justified inference that his controlling purpose in entering the state was not to file an action. Franklin v. Superior Court, (Cal. App. 1950) 220 P. (2d) 8

N400, P600, and Late Sustained Frontal Positivity Event-Related Brain Potentials Reflect Distinct Psycholinguistic Processes During the Comprehension of Contextually Ambiguous Narrative Discourses: Implications for the Neural Organization of the Language Processing System

Two studies were performed to investigate the temporal structure and organization of the language processing system during the comprehension of coherent contextually ambiguous narrative discourses. In Study 1, participants read short discourses that were contextually ambiguous if read without a descriptive title (Untitled group) or unambiguous with the title (Titled group). Participants identified the title of the discourses after reading 1-3 sentences. Given the unfinished next sentence, they performed a cloze procedure on the sentence-final word. For the Titled Group, cloze probability was greater to the last word of sentence 3 (Critical Word 3) than sentences 2 (Critical Word 2) and 1 (Critical Word 1). For the Untitled group, title identification accuracy was greater after reading the first two sentences than the first sentence and even more so after reading the full three-sentence discourses than the first two sentences alone. This study established 25 discourses in which the contexts were initially ambiguous but became increasingly clearer after reading Critical Word 2 and Critical Word 3. In Study 2, a different sample of participants read the discourses with (Titled Discourse group) or without (Untitled Discourse group) a descriptive title while undergoing high-density event-related potential (ERP) recording. For the Untitled Discourse group, N400 amplitudes became less negative from Critical Word 1 to Critical Word 2 and again to Critical Word 3, suggesting greater ease of lexical-semantic retrieval as the discourses unfolded. For this group, P600 amplitudes were larger to Critical Word 3 than Critical Word 2. Unexpectedly, a Late Sustained Frontal Positivity (SFP) ERP component occurred to both Critical Word 2 and Critical Word 3 for the Untitled Discourse group only. SFP results corresponded to the title identification findings from Study 1. Thus, it is proposed that the SFP reflects the resolution or revision of contextual ambiguity during discourse comprehension. Alternatively, the P600 is proposed to reflect the updating of the existing context of a discourse when an context is available or after the resolution of contextual ambiguity. Advisors: Dennis L. Molfese and Art C. Maerlende

VIDEO REVIEW; ROUTINE DATA SHARING PRACTICES PLACE VIDEO-STREAMING PROVIDERS IN THE CROSSHAIRS OF THE VIDEO PRIVACY PROTECTION ACT

The Video Privacy Protection Act of 1988 (VPPA) creates a private cause of action for any consumer whose personally identifiable information has been disclosed by a video tape service provider to a third party. The rapid growth of media companies that provide free internet-based video-streaming services, and the technologically-advanced advertising methods employed to fund this business model, have created uncertainty regarding the specific consumer segments the VPPA is designed to protect. The extensive role that third-party providers play in the collection, analysis, and segmentation of user data in the personalized advertising process raises justifiable privacy concerns for consumers. Recent VPPA case law signals that courts are not beginning to find merit in what was once dismissed as a plaintiff\u27s mere paranoia about online data tracking. However, these recent decisions do not clarify the VPPA\u27s application to the behind-the-scenes data sharing practices that free video-streaming providers utilize to generate advertising revenue. The current climate of uncertainty surrounding key definitions in the VPPA exposes video-steraming providers to costly class action litigation and threatens to destabilize the adverstising-based business model that has itself enabled the growth of the internet. This Note seeks to analyze the judicial expansion of the VPPA through the lens of recent case law, and present considerations that video-streaming providers can make in order to reduce their exposure to a successful lawsuit. This Note also argues that an amendment to the VPPA that conforms to consumer expectations in the modern online ecosystem is necessary to firmly establish the VPPA\u27s application to the routine data sharing practices of video-streaming providers

WILLS-DISCOVERY OF WILL FOLLOWING ADJUDICATION OF INTESTACY-RIGHTS OF INTERVENING PURCHASERS

At the time of his death in 1945, decedent was the owner of the real estate in question. His estate was administered in the belief that he had died intestate, and the administrator was discharged in August 1946. Thereafter, the property was conveyed by decedent\u27s heirs to buyer, and by buyer in February 1947, to the defendant, a bona fide purchaser. Subsequently, decedent\u27s will was discovered and admitted to probate in December 1947. By the terms of the will, the plaintiff was entitled to a one-half interest in the land. Plaintiff\u27s complaint, asking partition of the land, was dismissed by the circuit court. On appeal to the Supreme Court of Illinois, held, affirmed. Title obtained by bona fide purchase from the heir after a judicial determination of intestacy is immune from attack by the devisee under a will later probated. Eckland v. Jankowski, 407 Ill. 263, 95 N.E. (2d) 342 (1950)

PROCESS--IMMUNITY FROM SERVICE--PERSON ENTERING A STATE TO FILE AN ACTION

Petitioner, a resident of Missouri, entered California to gain custody of his child from its maternal grandmother. After eight days of fruitless negotiation he commenced habeas corpus proceedings. While attempting to serve the writ of habeas corpus, petitioner was served with a summons in an action brought by the grandmother for support of the child. When the trial court denied petitioner\u27s motion to quash the service of summons on him, he sought a writ of prohibition from the district court of appeals to prevent further prosecution of the second action. Held, petition denied; petitioner\u27s eight day delay justified inference that his controlling purpose in entering the state was not to file an action. Franklin v. Superior Court, (Cal. App. 1950) 220 P. (2d) 8

TORTS-BREACH OF DUTY-RIGHT TO RECOVER FOR PRENATAL INJURIES

Plaintiff, as administrator, brought an action to recover for the death and conscious suffering of plaintiff\u27s intestate, allegedly injured, while a viable child within her mother\u27s womb, by the tortious act of the defendant. Defendant\u27s demurrer to the declaration was sustained. On appeal, held, affirmed. Neither the infant nor its personal representative has a cause of action for prenatal personal injuries. Bliss v. Passanesi, (Mass. 1950) 95 N.E. (2d) 206

TAXATION-FEDERAL INCOME TAX-EXEMPT CORPORATIONS-STATUTORY INTERPRETATION

Plaintiff corporation was organized in 1947 by physicians who had formerly maintained a clinic for the practice of medicine as a partnership. The articles of incorporation provided that there should be no capital stock and no dividends, and stated that plaintiff was organized as a non-profit corporation for the purpose of providing medical treatment and hospitalization to sick and injured persons without regard to ability to pay therefor, and of providing such other incidental charitable services as the trustees of the corporation should prescribe. Pursuant to its by-laws, plaintiff paid such annual salaries to its member physicians as the trustees, who were elected by the members, directed. Plaintiff never maintained a hospital, and its sole charitable service was the rendering of medical treatment at its clinic to persons unable to pay therefor, although the vast majority of plaintiff\u27s patients paid fees to the corporation. Over plaintiff corporation\u27s objection that it was exempt from taxation under section 101(6) of the Internal Revenue Code, the Commissioner assessed income taxes on plaintiff\u27s 1948 net income, which plaintiff paid. In an action to recover\u27 the tax, held, plaintiff is not exempt from income taxation since it was neither organized nor operated exclusively for charitable, educational, or scientific purposes, and since at least part of its net earnings inured to the benefit of private individuals. Fort Scott Clinic and Hospital Corp. v. Brodrick, (D.C. Kan. 1951) 99 F. Supp. 515

Cortical activity evoked by inoculation needle prick in infants up to one-year old

Inoculation is one of the first and most common experiences of procedural pain in infancy. However, little is known about how needle puncture pain is processed by the central nervous system in children. In this study, we describe for the first time the event-related activity in the infant brain during routine inoculation using electroencephalography. Fifteen healthy term-born infants aged 1 to 2 months (n = 12) or 12 months (n = 5) were studied in an outpatient clinic. Pain behavior was scored using the Modified Behavioral Pain Scale. A distinct inoculation event-related vertex potential, consisting of 2 late negative-positive complexes, was observable in single trials after needle contact with the skin. The amplitude of both negative-positive components was significantly greater in the 12-month group. Both inoculation event-related potential amplitude and behavioral pain scores increased with age but the 2 measures were not correlated with each other. These components are the first recordings of brain activity in response to real-life needle pain in infants up to a year old. They provide new evidence of postnatal nociceptive processing and, combined with more traditional behavioral pain scores, offer a potentially more sensitive measure for testing the efficacy of analgesic protocols in this age group

Antibodies to acetylcholine receptor in parous women with myasthenia: evidence for immunization by fetal antigen

The weakness in myasthenia gravis (MG) is mediated by autoantibodies against adult muscle acetylcholine receptors (AChR) at the neuromuscular junction; most of these antibodies also bind to fetal AChR, which is present in the thymus. In rare cases, babies of mothers with MG, or even of asymptomatic mothers, develop a severe developmental condition, arthrogryposis multiplex congenita, caused by antibodies that inhibit the ion channel function of the fetal AChR while not affecting the adult AChR. Here we show that these fetal AChR inhibitory antibodies are significantly more common in females sampled after pregnancy than in those who present before pregnancy, suggesting that they may be induced by the fetus. Moreover, we were able to clone high-affinity combinatorial Fab antibodies from thymic cells of two mothers with MG who had babies with arthrogryposis multiplex congenita. These Fabs were highly specific for fetal AChR and did not bind the main immunogenic region that is common to fetal and adult AChR. The Fabs show strong biases to VH3 heavy chains and to a single Vk1 light chain in one mother. Nevertheless, they each show extensive intraclonal diversification from a highly mutated consensus sequence, consistent with antigen-driven selection in successive steps. Collectively, our results suggest that, in some cases of MG, initial immunization against fetal AChR is followed by diversification and expansion of B cells in the thymus; maternal autoimmunity will result if the immune response spreads to the main immunogenic region and other epitopes common to fetal and adult AChR