DOCSLIB.ORG

Auto Innovators-GAMA Amicus Brief

Total Page：16

File Type：pdf, Size：1020Kb

Download full-text PDF Read full-text

Load more

Nos. 19-368 and 19-369 IN THE Supreme Court of the United States FORD MOTOR COMPANY, Petitioner, v. MONTANA EIGHTH JUDICIAL DISTRICT COURT, et al., Respondents. FORD MOTOR COMPANY, Petitioner, v. ADAM BANDEMER, Respondent. On Writs of Certiorari to the Supreme Court of Montana and the Supreme Court of Minnesota BRIEF FOR THE ALLIANCE FOR AUTOMOTIVE INNOVATION AND GENERAL AVIATION MANUFACTURERS ASSOCIATION AS AMICI CURIAE IN SUPPORT OF PETITIONER DARRYL M. WOO JAIME A. SANTOS GOODWIN PROCTER LLP Counsel of Record Three Embarcadero Center STEPHEN R. SHAW San Francisco, CA 94111 GOODWIN PROCTER LLP (415) 733-6000 1900 N St., NW Washington, DC 20036 [email protected] (202) 346-4000 Counsel for Amici Curiae March 6, 2020 TABLE OF CONTENTS Page INTEREST OF THE AMICI CURIAE ...................... 1 SUMMARY OF THE ARGUMENT ........................... 3 ARGUMENT............................................................... 6 I. The decisions of the Minnesota and Montana Supreme Courts erase the clear line between general and specific personal jurisdiction. ................................... 6 II. This Court should reject respondents’ unlimited stream-of-commerce theory. ..... 12 III. Respondents’ no-causation rule will create massive uncertainty and increase litigation over threshold jurisdictional issues. .................................. 22 IV. Respondents’ rule would have a particularly pernicious impact on foreign manufacturers. .............................. 24 CONCLUSION ......................................................... 29 i TABLE OF AUTHORITIES Page(s) Cases Bristol-Myers Squibb Co. v. Superior Court of Cal., 137 S. Ct. 1773 (2017) ...................................passim Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985) .......................................... 6, 12 Daimler AG v. Bauman, 571 U.S. 117 (2014) .................. 2, 5, 7, 8, 12, 26, 27 D’Jamoos ex rel. Estate of Weingeroff v. Pilatus Aircraft Ltd., 566 F.3d 94 (3d Cir. 2009) ....... 2, 16, 17, 18, 20, 21 Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915 (2011) ........................................ 6, 7, 8 Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408 (1984) .................................... 8, 11, 26 Int’l Shoe Co. v. Washington, 326 U.S. 310 (1945) ........................................ 6, 7, 8 J. McIntyre Mach., Ltd. v. Nicastro, 564 U.S. 873 (2011) .............................. 5, 13, 14, 20 Montgomery v. Airbus Helicopters, Inc., 414 P.3d 824 (Okla. 2018) ...................................... 2 Societe Nationale Industrielle Aerospatiale v. U.S. Dist. Court for S. Dist. of Iowa, 482 U.S. 522 (1987) .............................................. 27 Walden v. Fiore, 571 U.S. 277 (2014) .......................... 6, 7, 11, 19, 20 World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (1980) ...................... 15, 19, 20, 21, 22 Other Authorities 14 C.F.R. pt. 21, subpt. D .......................................... 18 Joshua B. Arons, Tesla’s Right to Rise, 44 Transp. L.J. 133 (2017) ................................... 19 Associated Press, Driving an Older Car? You’re Not Alone. Average Vehicle Age Sets a Record, Autoblog (June 27, 2019, 8:30 a.m.), https://www.autoblog.com/2019/06/27/record- average-age-cars-on-road/ .................................... 15 Julie Blackley, Longest-Lasting Cars to Reach 200,000 Miles and Beyond, iSeeCars (last visited Mar. 5, 2019), https://www.iseecars.com/longest-lasting- cars-study ............................................................. 16 Gerald R. Bodisch, Economic Effects of State Bans on Direct Manufacturer Sales to Car Buyers, Economic Analysis Group (May 2009), https://www.justice.gov/atr/economic- effects-state-bans-direct-manufacturer- sales-car-buyers ................................................... 19 Mark Cooper, Bringing New Auto Sales and Service into the 21st Century, Consumer Fed’n of Am. (Oct. 2002), https://consumer fed.org/pdfs/InternetAutos102902.pdf ................ 19 General Aviation Manufacturers Association, 2019 Databook (Feb. 2020), https://gama.aero /wp-content/uploads/GAMA _2019Databook_ ForWebFinal-2020-02-19.pdf ............................... 16 Geoffrey C. Hazard, Jr., Discovery and the Role of the Judge in Civil Law Jurisdictions, 73 Notre Dame L. Rev. 1017 (1998) ......................... 27 Information Collection for Importation of On- Highway Vehicles and Motorcycles and Nonroad Engines, Vehicles, and Equipment, 84 Fed. Reg. 63,653 (Nov. 18, 2019) .................... 25 Office of Transp. & Mach., U.S. Dep’t of Commerce, U.S. Imports of Used Passenger Vehicles Imports, Value and Units, https://legacy.trade.gov/td/otm/assets/auto/ Used_Passenger_Imports.pdf (last visited Mar. 6, 2020) ........................................................ 25 Purchase Planning Handbook, Business & Commercial Aviation (May 2017), http://assets.penton.com/digitaleditions/B CA/BCA_201705.pdf ............................................ 16 Michael Schultz et al., U.S. Consumer & Eco- nomic Impacts of U.S. Automotive Trade Pol- icies, Ctr. for Auto. Research (Feb. 2019), https://www.cargroup.org/wp-content/up- loads/2019/02/US-Consumer-Economic-Im- pacts-of-US-Automotive-Trade-Policies-.pdf ....... 24 U.S. Dep’t of Commerce, The U.S. Litigation Environment and Foreign Direct Investment: Supporting U.S. Competitiveness by Reducing Legal Costs and Uncertainty, https://legacy.trade.gov/investamerica/Litiga tion_FDI.pdf (Oct. 2008) ...................................... 28 U.S. EPA, Independent Commercial Importers (ICIs), https://www.epa.gov/importing-vehicles- and-engines/independent-commercial- importers-icis (last visited Mar. 6, 2020) ............ 25 2 Waller, Antitrust & Am. Bus. Abroad (4th ed. 2018) ........................................................ 27 INTEREST OF THE AMICI CURIAE The Alliance for Automotive Innovation (Auto In- novators) is the leading advocacy group for the auto industry, representing 35 automobile manufacturers and value chain partners who together produce nearly 99 percent of all light-duty vehicles sold in the United States.1 The members of Auto Innovators include (al- phabetically) Aptiv PLC, Aston Martin, Robert Bosch LLC, BMW Group, Byton, Cruise LLC, DENSO, Fiat Chrysler Automobiles, Ferrari S.p.A., Ford Motor Company, General Motors Company, Honda Motor Company, Hyundai Motor America, Isuzu Motors Ltd., Jaguar Land Rover, Karma Automotive, Kia Mo- tors, Local Motors, Maserati, Mazda Motor Corpora- tion, McLaren Automotive, Mercedes-Benz USA, Mitsubishi Motors, Nissan Motor Company, NXP Semiconductors, Panasonic Corporation, Porsche, PSA North America, SiriusXM, Subaru, Suzuki, Texas Instruments, Toyota Motor Company, Volkswagen Group of America, and Volvo Car USA. The General Aviation Manufacturers Association (GAMA) is an international trade association repre- senting over 120 of the world’s leading manufacturers of general aviation aircraft, engines, avionics, and components, as well as operators of maintenance fa- cilities, fixed-base operators, aircraft fleets, and pilot and technician training facilities. Throughout its fifty-year history, GAMA has been dedicated to 1 The parties consented to the filing of this brief. No counsel for a party authored any part of this brief; no party or party’s counsel made a monetary contribution intended to fund the preparation or submission of this brief; and no person other than amici cu- riae, its members, or its counsel made a monetary contribution to the brief’s preparation or submission. 2 fostering and advancing the welfare, safety, interests, and activities of the global general aviation industry. General aviation encompasses all civilian flying ex- cept scheduled commercial transport and includes business travel, medical transport, aerial firefighting, law enforcement, flight training, aerial agricultural services, surveying, and search and rescue. GAMA’s members make nearly all of the general aviation air- craft flying today, from small, single-engine propeller plans to large jets to twin-turbine helicopters. Automobile and general aviation manufacturers are responsible for billions in economic outputs and millions of jobs in the United States; moreover, they are essential to the country’s transportation infra- structure. Amici aim to protect and promote the legal and policy interests of its members and frequently file amicus curiae briefs in cases such as this one that are important to the automobile and aviation industries. See, e.g., Avco Corp. v. Sikkelee, No. 18-1140 (U.S.); Daimler AG v. Bauman, 571 U.S. 117 (2014). Amici’s members include global companies that de- sign, manufacture, and sell vehicles in various parts of the country—indeed, the world. Because vehicles like cars, trucks, and aircraft are durable and easily portable by design, amici’s members frequently face product litigation in forums throughout the United States. Like Ford’s cases before this Court, specific personal jurisdiction is a significant and recurring question in vehicle accident litigation. See also, e.g., D’Jamoos ex rel. Estate of Weingeroff v. Pilatus Air- craft Ltd., 566 F.3d 94 (3d Cir. 2009); Montgomery v. Airbus Helicopters, Inc., 414 P.3d 824 (Okla. 2018). The question presented is therefore of significant im- portance to amici’s members. Amici therefore write to 3 emphasize the potential impacts of the Court’s resolu- tion of this question on the broader automotive indus- try (including foreign manufacturers) and beyond. SUMMARY OF THE ARGUMENT Specific personal
Recommended publications
  • Auto Retailing: Why the Franchise System Works Best

    Auto Retailing: Why the Franchise System Works Best

    AUTO RETAILING: WHY THE FRANCHISE SYSTEM WORKS BEST Q Executive Summary or manufacturers and consumers alike, the automotive and communities—were much more highly motivated and franchise system is the best method for distributing and successful retailers than factory employees or contractors. F selling new cars and trucks. For consumers, new-car That’s still true today, as evidenced by some key findings franchises create intra-brand competition that lowers prices; of this study: generate extra accountability for consumers in warranty and • Today, the average dealership requires an investment of safety recall situations; and provide enormous local eco- $11.3 million, including physical facilities, land, inventory nomic benefits, from well-paying jobs to billions in local taxes. and working capital. For manufacturers, the franchise system is simply the • Nationwide, dealers have invested nearly $200 billion in most efficient and effective way to distribute and sell automo- dealership facilities. biles nationwide. Franchised dealers invest millions of dollars Annual operating costs totaled $81.5 billion in 2013, of private capital in their retail outlets to provide top sales and • an average of $4.6 million per dealership. These service experiences, allowing auto manufacturers to concen- costs include personnel, utilities, advertising and trate their capital in their core areas: designing, building and regulatory compliance. marketing vehicles. Throughout the history of the auto industry, manufactur- • The vast majority—95.6 percent—of the 17,663 ers have experimented with selling directly to consumers. In individual franchised retail automotive outlets are locally fact, in the early years of the industry, manufacturers used and privately owned.
  • Honda Settlement Agreement

    Honda Settlement Agreement

    Case 1:15-md-02599-FAM Document 2013-1 Entered on FLSD Docket 09/01/2017 Page 2 of 356 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA IN RE: TAKATA AIRBAG PRODUCTS Case No. 1:15-md-02599-FAM LIABILITY LITIGATION, This Document Relates to: ALL ECONOMIC LOSS ACTIONS AGAINST THE HONDA DEFENDANTS SETTLEMENT AGREEMENT 127001694 Case 1:15-md-02599-FAM Document 2013-1 Entered on FLSD Docket 09/01/2017 Page 3 of 356 Table of Contents Page I. PROCEDURAL HISTORY ................................................................................................ 2 II. DEFINITIONS .................................................................................................................... 6 III. SETTLEMENT RELIEF .................................................................................................. 17 IV. NOTICE TO THE CLASS ............................................................................................... 33 V. REQUESTS FOR EXCLUSION ...................................................................................... 39 VI. OBJECTIONS TO SETTLEMENT ................................................................................. 40 VII. RELEASE AND WAIVER .............................................................................................. 42 VIII. ATTORNEYS’ FEES AND EXPENSES AND INDIVIDUAL PLAINTIFF AWARDS 46 IX. PRELIMINARY APPROVAL ORDER, FINAL ORDER, FINAL JUDGMENT AND RELATED ORDERS.......................................................................................................
  • Emerging Mobility Technologies and Trends

    Emerging Mobility Technologies and Trends

    Emerging Mobility Technologies and Trends And Their Role in Creating “Mobility-As-A-System” For the 21st Century and Beyond OWNERSHIP RIGHTS All reports are owned by Energy Systems Network (ESN) and protected by United States copyright and international copyright/intellectual property laws under applicable treaties and/or conventions. User agrees not to export any report into a country that does not have copyright/ intellectual property laws that will protect ESN’s rights therein. GRANT OF LICENSE RIGHTS ESN hereby grants user a non-exclusive, non-refundable, non- transferable Enterprise License, which allows you to (i) distribute the report within your organization across multiple locations to its representatives, employees or agents who are authorized by the organization to view the report in support of the organization’s internal business purposes; and (ii) display the report within your organization’s privately hosted internal intranet in support of your organization’s internal business purposes. Your right to distribute the report under an Enterprise License allows distribution among multiple locations or facilities to Authorized Users within your organization. ESN retains exclusive and sole ownership of this report. User agrees not to permit any unauthorized use, reproduction, distribution, publication or electronic transmission of any report or the information/forecasts therein without the express written permission of ESN. DISCLAIMER OF WARRANTY AND LIABILITY ESN has used its best efforts in collecting and preparing each report. ESN, its employees, affi liates, agents, and licensors do not warrant the accuracy, completeness, correctness, non-infringement, merchantability, or fi tness for a particular purpose of any reports covered by this agreement.
  • Michigan Strategic Fund

    Michigan Strategic Fund

    MICHIGAN STRATEGIC FUND MEMORANDUM DATE: March 12, 2021 TO: The Honorable Gretchen Whitmer, Governor of Michigan Members of the Michigan Legislature FROM: Mark Burton, President, Michigan Strategic Fund SUBJECT: FY 2020 MSF/MEDC Annual Report The Michigan Strategic Fund (MSF) is required to submit an annual report to the Governor and the Michigan Legislature summarizing activities and program spending for the previous fiscal year. This requirement is contained within the Michigan Strategic Fund Act (Public Act 270 of 1984) and budget boilerplate. Attached you will find the annual report for the MSF and the Michigan Economic Development Corporation (MEDC) as required in by Section 1004 of Public Act 166 of 2020 as well as the consolidated MSF Act reporting requirements found in Section 125.2009 of the MSF Act. Additionally, you will find an executive summary at the forefront of the report that provides a year-in-review snapshot of activities, including COVID-19 relief programs to support Michigan businesses and communities. To further consolidate legislative reporting, the attachment includes the following budget boilerplate reports: • Michigan Business Development Program and Michigan Community Revitalization Program amendments (Section 1006) • Corporate budget, revenue, expenditures/activities and state vs. corporate FTEs (Section 1007) • Jobs for Michigan Investment Fund (Section 1010) • Michigan Film incentives status (Section 1032) • Michigan Film & Digital Media Office activities ( Section 1033) • Business incubators and accelerators annual report (Section 1034) The following programs are not included in the FY 2020 report: • The Community College Skilled Trades Equipment Program was created in 2015 to provide funding to community colleges to purchase equipment required for educational programs in high-wage, high-skill, and high-demand occupations.
  • The New Mopar Super

    The New Mopar Super

    very generation seems to have one; following them, everyone else picks up on men who were not only designers, but also or sometimes two or three. what they’re doing and runs with it. We’re engineers; two fields that go hand-in-hand E Throughout the history of mankind, not talking about fashion designers for outside the world of clothing. It’s not design has been pushed forward largely women’s clothing, more precisely to our enough to make something that looks dif- through the efforts of a handful of men, and particular subject, we’re talking about the www.moparcollectorsguide.com 81 Martin, he became the design director for Aston. Most of those spectacular Aston Martins you’ve seen for the last fifteen years have varying amounts of Fisker’s handiwork in them, with the gorgeous Aston Martin DB9 being his creation entirely. He left Ford in 2004 to form his own design company, Fisker Coachbuild, which specialized in creating exotic bodies and interiors that could be fitted to existing chassis and drivetrains – much the same thing that notables such as Fleetwood, Murphy, and Saoutchik had done back in the prewar golden era of luxury car making. Then came the desire to build his own car from the tires up, which resulted in the Fisker Karma, and since leaving that ven- ture in 2012, Henrik Fisker has hardly been sitting around doing nothing; that’s not the kind of guy he is. Several years ago, Henrik was ferent, it has to be functional, and it has to Looking more like a Lamborghini than a looking at a Dodge Viper and pondering be better than whatever it’s intended to cracker box roller skate electric car, the just how much potential the car had for replace.
  • Daimler Annual Report 2014

    Daimler Annual Report 2014

    Annual Report 2014. Key Figures. Daimler Group 2014 2013 2012 14/13 Amounts in millions of euros % change Revenue 129,872 117,982 114,297 +10 1 Western Europe 43,722 41,123 39,377 +6 thereof Germany 20,449 20,227 19,722 +1 NAFTA 38,025 32,925 31,914 +15 thereof United States 33,310 28,597 27,233 +16 Asia 29,446 24,481 25,126 +20 thereof China 13,294 10,705 10,782 +24 Other markets 18,679 19,453 17,880 -4 Investment in property, plant and equipment 4,844 4,975 4,827 -3 Research and development expenditure 2 5,680 5,489 5,644 +3 thereof capitalized 1,148 1,284 1,465 -11 Free cash flow of the industrial business 5,479 4,842 1,452 +13 EBIT 3 10,752 10,815 8,820 -1 Value added 3 4,416 5,921 4,300 -25 Net profit 3 7,290 8,720 6,830 -16 Earnings per share (in €) 3 6.51 6.40 6.02 +2 Total dividend 2,621 2,407 2,349 +9 Dividend per share (in €) 2.45 2.25 2.20 +9 Employees (December 31) 279,972 274,616 275,087 +2 1 Adjusted for the effects of currency translation, revenue increased by 12%. 2 For the year 2013, the figures have been adjusted due to reclassifications within functional costs. 3 For the year 2012, the figures have been adjusted, primarily for effects arising from application of the amended version of IAS 19. Cover photo: Mercedes-Benz Future Truck 2025.
  • 2002 Ford Motor Company Annual Report

    2002 Ford Motor Company Annual Report

    2228.FordAnnualCovers 4/26/03 2:31 PM Page 1 Ford Motor Company Ford 2002 ANNUAL REPORT STARTING OUR SECOND CENTURY STARTING “I will build a motorcar for the great multitude.” Henry Ford 2002 Annual Report STARTING OUR SECOND CENTURY www.ford.com Ford Motor Company G One American Road G Dearborn, Michigan 48126 2228.FordAnnualCovers 4/26/03 2:31 PM Page 2 Information for Shareholders n the 20th century, no company had a greater impact on the lives of everyday people than Shareholder Services I Ford. Ford Motor Company put the world on wheels with such great products as the Model T, Ford Shareholder Services Group Telephone: and brought freedom and prosperity to millions with innovations that included the moving EquiServe Trust Company, N.A. Within the U.S. and Canada: (800) 279-1237 P.O. Box 43087 Outside the U.S. and Canada: (781) 575-2692 assembly line and the “$5 day.” In this, our centennial year, we honor our past, but embrace Providence, Rhode Island 02940-3087 E-mail: [email protected] EquiServe Trust Company N.A. offers the DirectSERVICE™ Investment and Stock Purchase Program. This shareholder- paid program provides a low-cost alternative to traditional retail brokerage methods of purchasing, holding and selling Ford Common Stock. Company Information The URL to our online Investor Center is www.shareholder.ford.com. Alternatively, individual investors may contact: Ford Motor Company Telephone: Shareholder Relations Within the U.S. and Canada: (800) 555-5259 One American Road Outside the U.S. and Canada: (313) 845-8540 Dearborn, Michigan 48126-2798 Facsimile: (313) 845-6073 E-mail: [email protected] Security analysts and institutional investors may contact: Ford Motor Company Telephone: (313) 323-8221 or (313) 390-4563 Investor Relations Facsimile: (313) 845-6073 One American Road Dearborn, Michigan 48126-2798 E-mail: [email protected] To view the Ford Motor Company Fund and the Ford Corporate Citizenship annual reports, go to www.ford.com.
  • Electric Vehicle Roadmap

    Electric Vehicle Roadmap

    TABLE OF CONTENTS Acknowledgments ......................................................................................................... ii Introduction to the Roadmap ....................................................................................... 1 1. Our Focus .................................................................................................................. 3 1.1 Shared Vision and Mission ............................................................................................................ 3 1.2 Aspiration ...................................................................................................................................... 3 1.3 Guiding Principles ......................................................................................................................... 4 2. Our Action .................................................................................................................. 6 2.1 Roadmap Framework .................................................................................................................... 6 2.2 Opportunity Areas and Initiatives .................................................................................................. 6 2.2.1 Driving Charging Infrastructure Availability ...................................................................... 6 2.2.2 Driving Awareness ............................................................................................................ 8 2.2.3 Driving Innovative and Supportive Policies .....................................................................
  • Investing in Central Europe 2016

    Investing in Central Europe 2016

    Investing in Central Europe Your move in the right direction December 2016 Investing in Central Europe | Your move in the right direction Content 1. Investing in Central Europe 3 Introduction The investment process 2. Why Central Europe? 9 3. Comparison of selected data 10 Basic facts Main macroeconomic data GDP growth in CE Taxation 4. Country guides for Bulgaria, Czech Republic, Hungary, Poland, Romania and Slovakia 15 General overview of economy Tax structure Legal entities Labor and wages Education Infrastructure The most active industries / sectors Industrial parks Investment Incentive Foreign Direct Investment (FDI) Expatriate life Weather and climate 5. The Social Progress Index and Foreign Direct Investment in CE Region 149 6. Deloitte Central Europe 164 Deloitte Central Europe Our expertise 7. Contact us 168 2 Investing in Central Europe | Your move in the right direction Introduction The economic and business outlook Indeed, Romania is “the new sexy” and we • When the Eurozone grows by an extra for Central Europe have “taken Romania out of the Balkans”. 1%, then the CEE region grows by In 2016-17 the core/central CEE region Growth exceeds 4% and a large majority an extra 1.3%. looks like a “safe haven” globally. When of companies report excellent business • But South-eastern Europe (SEE), with many emerging markets and developed and this is across most sectors. Romania the exception of Romania, was not ones face strained economic and is not as roller-coaster as it sued to be and performing as well due to structural political developments, core CEE looks the recent 18 months have been some economic issues such as budget comparatively much better.
  • Electric Last Mile Announces Additions to Leadership Team

    Electric Last Mile Announces Additions to Leadership Team

    ELECTRIC LAST MILE ANNOUNCES ADDITIONS TO LEADERSHIP TEAM Troy, Mich. (June 22, 2021) – Electric Last Mile, Inc. (“ELMS” or “the Company”) today announced eight new additions to its global leadership team in the areas of engineering, operations, marketing, business development and sales. Georgette Borrego Dulworth joins the team as Vice President of Human Resources, Praveen Cherian as Vice President of Engineering, Chris Slesak as Director of Connected Vehicle/Telematics, Rudy Wang as Director of Vehicle Software, Eric Keipper as Executive Director of Vehicle Integration, Jacqueline Siegel as Director of Battery, Sharon Dudley-Parham as Director of Marketing, and Adam Du as Director of ELMS China Operations. These additions bring decades of leadership experience in the automotive industry and in China’s EV market from companies including Ford, General Motors and Bosch. “We are thrilled to welcome these leaders to our team at ELMS,” said James Taylor, Co-Founder and CEO of ELMS. “Each new team member brings deep, unique automotive experience as well as the proven ability to build global organizations in the commercial vehicle space. These leaders come at an exciting time as we continue to make significant strides on our business and production plans.” Georgette Borrego Dulworth, Vice President, Human Resources: Ms. Borrego Dulworth joins ELMS with over 20 years of experience in human capital and legal matters leadership. She was earlier Vice President, Legal of Dematic, a subsidiary of KION Group and a leading supplier of integrated automated technology, software and services to optimize the supply chain. Prior to joining Dematic, Ms. Borrego Dulworth served as Corporate Counsel and Director of Human Resources for North America with MSX International, LLC and Director of Talent Acquisition and Diversity at FCA, now Stellantis.
  • The Struggle for Dominance in the Automobile Market: the Early Years of Ford and General Motors

    The Struggle for Dominance in the Automobile Market: the Early Years of Ford and General Motors

    The Struggle for Dominance in the Automobile Market: The Early Years of Ford and General Motors Richard S. Tedlow Harvard University This paper contrasts the business strategics of Henry Ford and Alfred P. Sloan,Jr. in the automobilemarket of the 1920s.1 The thesisis that HenryFord epitomized the method of competition most familiar to ncoclassical economics. That is to say, his key competitive weapon was price. Alfred P. Sloan, Jr. beat Ford because hc understood that the nature of the market had changed and that new tools wcrc nccdcd for success in the modern world of oligopolistic competition. Henry Ford and the Old Competition In the world of ncoclassical economics, the business landscape is studdcd with anonymous, small producers and merchants and the consumer has perfect information. Buyers do not know other buyers; buyers do not know sellers;scllcrs do not know other sellers. No scllcr can, without collusion, raise price by restricting output. It is a world of commodities. All products arc undiffcrcntiatcd. Prices arc established through the mechanism of an impersonal market, where the "invisible hand" ensures consumer welfare. Producers in an untrammeled market system have no choice but to accept "the lowest [pricc] which can bc taken" [19, p. 61]. In Adam $mith's world, business people do not lose sleep over the issue of whether or not to compete on price. Pricc is compctition's defining characteristic. Conditions approximating this description may have existed in the United States prior to the railroad revolution of the 1840s [6, pp. 13-78]. With thc building of the railroad network, however, the context of businessactivity began to change.
  • Blaupunkt Audio System Handbook

    Blaupunkt Audio System Handbook

    Blaupunkt Audio System Handbook tempestsTorrin serialized blackguardly. communicatively. Selachian Winston always fondling his springtides if Judas is ginned or tenant scenically. Wally Germany from your experience of cystodia, with companies working condition and blaupunkt audio Wszystkie stacje o niskiej jakoku zostanzignorowane. Rpt one of blaupunkt reserves the existing coding for car radio will be found. Diagram of the phone number or automatically switches off and parts of my serial number below the audio system handbook would be acquired through online today on this! Sony TV models Number. Not another with base model system with CD player below the monitor. He has covered the Oilers, NFL and Texans for the Houston Chronicle. Ezt követlehetséges a frekvencia manuális beállítása. Fe operativa knapparna fungerar inte. Vid tryckning pn knappen aktiveras valläget enligt följande: Sök i mappen. Jetta Navigation Systems are a great upgrade. Twitter and would attract to lessen a pipe, I suggest talking a chart beside your favourite albums your pinned tweet. Best batteries for cars, motorcycles, commercial vehicles, trucks or fun sport vehicle. Hacks, Call of Duty Hacks, Gunz Hacks, Quake LIVE Hacks. What modifications are. The cabbage is regain made. Lappareil qui fonctionne en mode LOC rpduit la sensibilitp de rpception pendant la recherche des stations radio. Appuyez j nouveau pour rptablir le son. What modifications are moderate there? Each other audio system handbook as well if you like a spot on. This system is on the blaupunkt by continuing to pair your radio, it was interrupted for systems because of hindernissen op een zender.