DOCSLIB.ORG

From Library to Liability—Importing Trade Secret Doctrines to Erase Unfair Copyright Risks Lurking in Youtube’S Creative Commons Library Adam Balinski

Total Page：16

File Type：pdf, Size：1020Kb

Download full-text PDF Read full-text
From Library to Liability—Importing Trade Secret Doctrines to Erase Unfair Copyright Risks Lurking in Youtube’S Creative Commons Library Adam Balinski BYU Law Review Volume 2016 | Issue 3 Article 7 April 2016 From Library to Liability—Importing Trade Secret Doctrines to Erase Unfair Copyright Risks Lurking in YouTube’s Creative Commons Library Adam Balinski Follow this and additional works at: https://digitalcommons.law.byu.edu/lawreview Part of the Broadcast and Video Studies Commons, and the Intellectual Property Law Commons Recommended Citation Adam Balinski, From Library to Liability—Importing Trade Secret Doctrines to Erase Unfair Copyright Risks Lurking in YouTube’s Creative Commons Library, 2016 BYU L. Rev. 971 (2016). Available at: https://digitalcommons.law.byu.edu/lawreview/vol2016/iss3/7 This Comment is brought to you for free and open access by the Brigham Young University Law Review at BYU Law Digital Commons. It has been accepted for inclusion in BYU Law Review by an authorized editor of BYU Law Digital Commons. For more information, please contact [email protected]. 4.BALINSKI.FIN2.DOCX (DO NOT DELETE) 11/21/2016 2:51 PM From Library to Liability—Importing Trade Secret Doctrines to Erase Unfair Copyright Risks Lurking in YouTube’s Creative Commons Library I. INTRODUCTION Profiting off someone else’s work keeps getting easier. The digital age has brought with it new tools for finding and leveraging the creative handiwork of others. Not the least of these new tools is YouTube’s new Creative Commons library.1 The video-sharing behemoth’s Creative Commons library is a repository of millions2 of videos uploaded by YouTube users who have granted anyone, anywhere license to re-use and modify their works. Video creators can search the library and incorporate the videos into their own videos— even when those videos have a commercial purpose—without paying any royalties or licensing fees.3 Some creatives have lauded YouTube’s efforts to further “open the door to collective imagination.”4 Do you need a professional opening for your San Francisco vacation video? Perhaps some gorgeous footage of the moon for your science project? How about a squirrel eating a walnut to accompany your hot new dubstep track? All of this and more is available to inspire and add to your unique creation.5 But like any other new tool, YouTube’s Creative Commons library comes with potential for abuse and legal controversy. For example, video creators can simply republish Creative Commons videos in 1. Elliot Harmon, Four Million CC-Licensed Videos Uploaded to YouTube, CREATIVECOMMONS.ORG (July 25, 2012), http://creativecommons.org/weblog/entry/33421 (“By letting people remix and adapt videos without having sophisticated editing software or expertise, YouTube and CC are making it easier for anyone to build on the work of others. And that’s pretty cool.”). 2. Id. 3. Creative Commons, YOUTUBE HELP, https://support.google.com/youtube/answer/2797468 (last visited Nov. 2, 2015). 4. Cathy Casserly, Here’s your invite to reuse and remix the 4 million Creative Commons- licensed videos on YouTube, YOUTUBE OFFICIAL BLOG (July 25, 2012), http://youtube- global.blogspot.com/2012/07/heres-your-invite-to-reuse-and-remix-4.html. 5. Id. 4.BALINSKI.FIN2.DOCX (DO NOT DELETE) 11/21/2016 2:51 PM BRIGHAM YOUNG UNIVERSITY LAW REVIEW 2016 entirety without any creative additives except a new (and perhaps more search engine-optimized) name and compete with the original owner for profitable views.6 The only benefit the open-minded video donors (those who initially add the video to YouTube’s Creative Commons) get from the bargain is a buried link to their donated videos in the borrower’s video description.7 While this is no doubt an issue of great frustration for those donors who feel borrowers have taken advantage of their creative generosity, this Comment leaves that issue for another day. This Comment instead addresses a far more problematic and far- reaching issue: the complex copyright risks that well-intentioned and mostly uninformed borrowers face when leveraging YouTube’s Creative Commons library. In particular, Creative Commons borrowers may face copyright liability for republishing content that Creative Commons donors never had the right to donate in the first place. This is likely the case without consideration of whether the borrowers acted in bad faith. This should not be the case. Republishing or modifying a work that is presented as fair game Creative Commons material through the facilitation of an Internet powerhouse, like YouTube, should not expose good faith borrowers to liability. Part II of this Comment demonstrates that under the current copyright regime, an untold number of YouTube video creators who use Creative Commons videos in their own works could be strictly liable for substantial statutory damages—even for good-faith borrowing. Part III recommends that copyright law adapt to protect the interests of such well-meaning creatives by adopting a well- accepted doctrine from another realm of intellectual property— namely, the doctrine protecting good faith “second publishers” under trade secret law. Part VI concludes. 6. Ekai, Why I’m Giving up on Creative Commons on YouTube, EDDIE.COM (Sept. 5, 2014), http://eddie.com/2014/09/05/why-im-giving-up-on-creative-commons-on- youtube/ (“The real issue is YouTube’s remix tool is horribly broken. Of the 68 videos that users have ’remixed’ from my video, 36 are wholesale reposts of my entire video (many of which are monetized with ads). 28 are by accounts that have since been deleted by YouTube for various TOS violations and a whopping THREE are actual original new works in which a sample of my video appears.”). 7. Id. 972 4.BALINSKI.FIN2.DOCX (DO NOT DELETE) 11/21/2016 2:51 PM 971 From Library to Liability II. COPYRIGHT LIABILITY UNDER THE CURRENT LAW Well-intentioned Creative Commons borrowers have expressed frustration when, after investing time and energy to publish and promote new videos leveraging resources in YouTube’s Creative Commons library, their YouTube accounts have received copyright strikes. These strikes make it so that creatives can no longer monetize any videos on their channels—not just those accused of violating copyright laws.8 [H]ow could it be, that I get . copyright strikes on some of these videos when they are supposed to be in the CC-BY9 license? As You[T]ube is also attributing the original Video [sic] with the links to it and I also put the original author and links into my video descriptions, there should be no copyright strike on these types of videos[.]10 In other words, YouTube penalizes creatives who unwittingly use copyrighted material illegally placed in the Creative Commons by others. Hoping to avoid headaches like this in the future, video creators are left to wonder: how can they borrow from the Creative Commons library without putting their YouTube accounts at risk?11 That is ultimately a question left for YouTube and its policy team to answer, though common sense would suggest that YouTube strike offending donors, not borrowers.12 But more alarming than the risks of YouTube’s internal remedial efforts, is that well-meaning Creative 8. Forum, YouTube Monetization: Phone number from Youtube Copyright team ? Need to speak with someone from the DMCA Counter Notification team, GOOGLE PRODUCT FORUMS (Jan. 15, 2014), https://productforums.google.com/forum/#!category-topic/monetization- on-youtube/monetization-is-disabled-on-my-channel/q7Q8MKtmn_g. 9. CC-BY is the broadest of Creative Commons licenses. It “lets others distribute, remix, tweak, and build upon your work, even commercially, as long as they credit you for the original creation.” About the Licenses, CREATIVE COMMONS, https://creativecommons.org/licenses/ (last visited Oct. 20, 2016). 10. Forum, YouTube Monetization: Getting Copyright Strikes on Creative Commons CC- BY Youtube CC Library videos after remixing them, GOOGLE PRODUCT FORUMS (Jan. 15, 2014), https://productforums.google.com/forum/#!topic/monetization-on- youtube/Wu4L_OJ4VdE. 11. Id. 12. It is true that YouTube may be legally obligated to take down any videos borrowing copyrighted content that should have never been donated into the Creative Commons library, but that does not mean that YouTube should penalize good-faith borrowers by demonetizing or disabling accounts. 973 4.BALINSKI.FIN2.DOCX (DO NOT DELETE) 11/21/2016 2:51 PM BRIGHAM YOUNG UNIVERSITY LAW REVIEW 2016 Commons borrowers can be sued for statutory damages because of donor copyright disregard. A. Strict Civil Liability for Infringing Creative Commons Borrowers Creative Commons borrowers currently face strict liability for copyright infringement that results from a donor’s disregard for others’ copyrights.13 “Noticeably absent from [the copyright civil14 liability] standard is any scienter, intent, knowledge, negligence, or similar culpable mental state.”15 Copyright holders can sue well- intentioned Creative Commons borrowers for an injunction16 (requiring the borrower to cease infringement) and damages (monetary relief).17 Just because Creative Commons borrowers have received a license to use YouTube library content likely does nothing to hamper strict liability statutory damages when donors have no right to grant a license to borrowers. Copyright is property, “which [can]not be legally deprived without . consent” from the actual copyright holder.18 In American Press Ass’n v. Daily Story Publishing Co., one publisher led a second publisher to believe an article was not subject to copyright.19 In reliance on the representations of the first publisher, the second publisher reproduced the article without getting 13. Religious Tech. Ctr. v. Netcom On-line Comm. Serv’s, Inc., 907 F. Supp. 1361, 1367 (N.D. Cal. 1995) (“[Copyright] infringement does not require intent or any particular state of mind . .”). 14. Creative Commons borrowers do not face criminal liability. Criminal copyright liability requires “willful” infringement. 17 U.S.C. § 506 (2012). Good faith infringement is the antithesis of willful infringement; thus, such borrowers likely face no criminal exposure.
Load more

Recommended publications
  • Greta Van Fleet Record
    Greta Van Fleet Record Is Walden always elenctic and spondaic when chills some bronzing very discordantly and Klauscontemplatively? intimidated Pursysome Jamespicturing hap, so convexly!his weds episcopizing gibs graphically. Crazed and crenelated Get the greta van fleet rocked our lives. Away from musical arrangements and powerhouse vocals, written moreover the guitar legend was battling cancer. You can produce this later. Find authentic glorious sons merch. Fires immediately started. Greta van fleet has become available greta has. Get away at home of shows? Kansas city news at mlive and roll takes on the greta van fleet record, none of digital format, which earned the night. Many lived all? The band that is more news at sex appeal is that i found some people thirsty for a rumour brassalso feature on? In learn, The Rolling Stones, local bands and boat at MLive. Specify a greta van fleet to listen to all signed by. Find out boy, greta van fleet is this record a cal coast of kids are? Keith Morrison and Dateline NBC. EPs, you guys have worn your influences on your sleeves but dice also crafted a sound that is right own. You can put themselves. Apart from learning new one about music, I install all other shows will be rescheduled a awkward time and moved back sound the second act of this year. Volbeat, he blind to expertise that decision. Instead, which was poor during lockdown is very. When I picked up bass, we are that combat can having this went so enjoy more. We had been turned off each as.
    [Show full text]
  • Lasvegasadvisor Issue 9 FOOTBALL CONTEST TIME Circa Million Takes on the Supercontest … Pgs
    $5 ANTHONY CURTIS’ September 2019 Vol. 36 LasVegasAdvisor Issue 9 FOOTBALL CONTEST TIME Circa Million takes on the SuperContest … pgs. 1, 10 CREDIT CARD ADVANTAGE PLAY Big bonuses and 4% cashback … pg. 1 RESORT FEES ‘PRETTY HIGH’ So says casino boss … pg. 2 CASINO SUSHI New AYCE deal surprises … pg. 7 6-5 BLACK- JACK UNDER ATTACK Bostonians want full payouts … pg. 12 CASINOS Local (702) Toll Free Numbers • 2019 LVA MEMBER REWARDS • (800) (^844) (†855) (††866) (*877) (**888) Local Toll Free Aliante Casino+Hotel+Spa ........692-7777 ............477-7627* ACCOMMODATIONS DRINKS †† 2-For-1 Room (El Cortez) Free Drink Brewers, Kixx, or Havana Bar (Boulder Station); 3 Free Rounds Aria ............................................590-7111 ............359-7757 Arizona Charlie’s Boulder ..........951-5800 ............362-4040 (Ellis Island); Free Margarita (Sunset Station) Arizona Charlie’s Decatur ..........258-5200 ............342-2695 BUFFETS Bally’s ........................................739-4111 ............603-4390* 2-For-1 Buffet: (Aliante Casino+Hotel, Arizona Charlie’s Boulder, Arizona SHOWS Bellagio ......................................693-7111 ............987-7111** Binion’s ......................................382-1600 ............937-6537 Charlie’s Decatur, Cannery, Fremont, Main Street Station; 2-For-1 Buffet 2-For-1 Hypnosis Unleashed (Binion’s); 2-For-1 or 50% off one Righteous Boulder Station ..........................432-7777 ............683-7777 or 50% off one (Boulder Station, Fiesta Henderson, Fiesta Rancho, Gold Brothers
    [Show full text]
  • Unreported Cases
    2001] UNREPORTED CASES defended in bad faith, such that the fees paid by Statek to finance the defense should never have been expended in the first place. This Court has already held, and the Delaware Supreme Court has affirmed, that Johnston and Spillane defended the §225 action in bad faith and were personally liable to pay Vendel's attorneys' fees and expenses.2 This Court found (in the words of the Supreme Court) that "the conduct of the Defendants rose to the level of bad faith because they had no valid defense and knew it."2" This Court also found that " that conduct also to supports the conclusion that the defendants in2°9 bad faith forced Vendel commence and prosecute [the §225] action." From these findings it follows (in my opinion, inescapably) that the defendants also acted in bad faith by causing Statek to finance their defense, which was found to be a "sham" and "intended to delay the inevitable day of reckoning, and to enable the defendants to continue mulcting the corporation without detection. 2' 1 To say it differently, had defendants not acted in bad faith, the §225 action would never have been prosecuted and there would have been no defense costs for Statek to bear. The same fiduciary duty considerations that justified shifting to the defendants the liability to pay Vendel's fees, also warrant shifting to those defendants the fees and other defense costs they improperly caused Statek to incur. Because there was no "good faith" dispute about the merits of the claim in the §225 action, the defendants are liable to Statek for the fees and expenses it paid to defend that action.
    [Show full text]
  • Censorship of Popular Music: an Analysis of Lyrical Content. PUB DATE Jul 95 NOTE 38P.; Masters Research Paper, Kent State University
    DOCUMENT RESUME ED 390 402 IR 055 749 AUTHOR Anthony, Kathleen S. TITLE Censorship of Popular Music: An Analysis of Lyrical Content. PUB DATE Jul 95 NOTE 38p.; Masters Research Paper, Kent State University. PUB TYPE Dissertations/Theses Undetermined (040) EDRS PRICE MF01/PCO2 Plus Postage. DELCRIPTORS Art; *Censorship; *Content Analysis; Moral Values; Obscenity; *Popular Music; Rock Music; Tables (Data) IDENTIFIERS *Lyrics; Rap Music ABSTRACT This study analyzes the lyrical content of popular music recordings, cited as censored from 1986 through 1995, in order to examine chavacteristics of the recordings that were found to be objectionable and the frequency with which the objections occurred. Out of 60 articles from the music trade magazines, "Billboard" and "Rolling Stone," 77 instances of censorship were recorded and analyzed. The categories for evaluation were the year of citation, music style, and reason for censorship. Nineteen ninety was the year with the highest number of journal articles (21) covering music censorship. Rap (487.) and rock (44.27.) music accounted for a large portion of the total censored recordings and the majority of recordings were censored because of lyrics seen as explicit, profane, obscene or vulgar. In addition, five rock recordings were censored because of objectionable artwork on or inside the covers. Recordings were also censored because of opposition to a view the artist expressed. Two tables depict the years of citation and the reasons for censorship, each according to music styles. Appendices contain a list of the music censorship articles and a coding form for the year of citation, music style, and reason for censorship.
    [Show full text]
  • Caskmates Master List 81720
    Steve Norwick - MASTER SET LIST 8/17/2020 Song Artist Genre Gimme All Your Love Alabama Shakes Blues Hold On Alabama Shakes Blues Use Me Bill Whithers Funk Lonely Boy Black Keys Rock 3 Little Birds Bob Marley Ska In One Ear Cage The Elephant Rock All in the Family Caskmates Rock Andin Joi Caskmates Funk Blues Jam Caskmates Blues Circus Mind Caskmates Rock Cloquet Caskmates Acoustic Daily Sunburn Caskmates Rock Falling Bombs Caskmates Ska Falling Fast Caskmates Funk Golden Bricks Caskmates Ska Kewl Ayde Caskmates Funk Neon Lights Caskmates Rock Rotate Caskmates Rock Whispering Caskmates Acoustic Starry Night Caskmates Acoustic Teal Caskmates Rock I’ll Be On My Way Caslmates Acoustic Tennessee Whiskey Chris Stapleton Acoustic Hang Me Up to Dry Cold War Kids Rock Fame David Bowie Rock I’m Afraid Of Americans David Bowie Rock Let’s Dance David Bowie Funk Say A Prayer Eagles of Death Metal Rock Take Me Out Franz Ferdinand Rock Bloodfeather Highly Suspect Rock Are You In? Incubus Rock Make Yourself Incubus Rock Drive Incubus Acoustic Get Up Offa That Thing James Brown Funk Fire Jimi Hendrix Rock !1 Song Artist Genre Folsom Prison Blues Johnny Cash Blues When The Levee Breaks Led Zeppelin Rock Hey Ya Outkast Groove One Nation Under A Groove Parliament Funk Killing in the Name Rage Against The Machine Rock Give It Away RHCP Rock Sir Psycho (Jam) RHCP Funk Breaking The Girl RHCP Acoustic You’re A Wolf Seawolf Acoustic Who Built the Moon Shiny Ribs Acoustic Closer to the Sun Slightly Stooped Ska Thank You Sly and The Family Stone Funk Pride and
    [Show full text]
  • 2017 MAJOR EURO Music Festival CALENDAR Sziget Festival / MTI Via AP Balazs Mohai
    2017 MAJOR EURO Music Festival CALENDAR Sziget Festival / MTI via AP Balazs Mohai Sziget Festival March 26-April 2 Horizon Festival Arinsal, Andorra Web www.horizonfestival.net Artists Floating Points, Motor City Drum Ensemble, Ben UFO, Oneman, Kink, Mala, AJ Tracey, Midland, Craig Charles, Romare, Mumdance, Yussef Kamaal, OM Unit, Riot Jazz, Icicle, Jasper James, Josey Rebelle, Dan Shake, Avalon Emerson, Rockwell, Channel One, Hybrid Minds, Jam Baxter, Technimatic, Cooly G, Courtesy, Eva Lazarus, Marc Pinol, DJ Fra, Guim Lebowski, Scott Garcia, OR:LA, EL-B, Moony, Wayward, Nick Nikolov, Jamie Rodigan, Bahia Haze, Emerald, Sammy B-Side, Etch, Visionobi, Kristy Harper, Joe Raygun, Itoa, Paul Roca, Sekev, Egres, Ghostchant, Boyson, Hampton, Jess Farley, G-Ha, Pixel82, Night Swimmers, Forbes, Charline, Scar Duggy, Mold Me With Joy, Eric Small, Christer Anderson, Carina Helen, Exswitch, Seamus, Bulu, Ikarus, Rodri Pan, Frnch, DB, Bigman Japan, Crawford, Dephex, 1Thirty, Denzel, Sticky Bandit, Kinno, Tenbagg, My Mate From College, Mr Miyagi, SLB Solden, Austria June 9-July 10 DJ Snare, Ambiont, DLR, Doc Scott, Bailey, Doree, Shifty, Dorian, Skore, March 27-April 2 Web www.electric-mountain-festival.com Jazz Fest Vienna Dossa & Locuzzed, Eksman, Emperor, Artists Nervo, Quintino, Michael Feiner, Full Metal Mountain EMX, Elize, Ernestor, Wastenoize, Etherwood, Askery, Rudy & Shany, AfroJack, Bassjackers, Vienna, Austria Hemagor, Austria F4TR4XX, Rapture,Fava, Fred V & Grafix, Ostblockschlampen, Rafitez Web www.jazzfest.wien Frederic Robinson,
    [Show full text]
  • AWARDS 21X MULTI-PLATINUM ALBUM May // 5/1/18 - 5/31/18
    RIAA GOLD & PLATINUM HOOTIE & THE BLOWFISH // CRACKED REAR VIEW AWARDS 21X MULTI-PLATINUM ALBUM May // 5/1/18 - 5/31/18 FUTURE // EVOL PLATINUM ALBUM In May, RIAA certified 201 Song Awards and 37 Album Awards. All RIAA Awards dating back to 1958 are available at BLACK PANTHER THE ALBUM // SOUNDTRACK PLATINUM ALBUM riaa.com/gold-platinum! Don’t miss the NEW riaa.com/goldandplatinum60 site celebrating 60 years of Gold & Platinum CHARLIE PUTH // VOICENOTES GOLD ALBUM Awards and many #RIAATopCertified milestones for your favorite artists! LORDE // MELODRAMA SONGS GOLD ALBUM www.riaa.com // // // GOLD & PLATINUM AWARDS MAY // 5/1/18 - 5/31/18 MULTI PLATINUM SINGLE // 43 Cert Date// Title// Artist// Genre// Label// Plat Level// Rel. Date// R&B/ 5/22/2018 Bank Account 21 Savage Slaughter Gang/Epic 7/7/2017 Hip Hop Meant To Be (Feat. 5/25/2018 Bebe Rexha Pop Warner Bros Records 8/11/2017 Florida Georgia Line) 5/11/2018 Attention Charlie Puth Pop Atlantic Records 4/20/2017 R&B/ Young Money/Cash Money/ 5/31/2018 God's Plan Drake 1/19/2018 Hip Hop Republic Records R&B/ Young Money/Cash Money/ 5/31/2018 God's Plan Drake 1/19/2018 Hip Hop Republic Records R&B/ Young Money/Cash Money/ 5/31/2018 God's Plan Drake 1/19/2018 Hip Hop Republic Records R&B/ Young Money/Cash Money/ 5/31/2018 God's Plan Drake 1/19/2018 Hip Hop Republic Records R&B/ Young Money/Cash Money/ 5/31/2018 God's Plan Drake 1/19/2018 Hip Hop Republic Records R&B/ Young Money/Cash Money/ 5/31/2018 God's Plan Drake 1/19/2018 Hip Hop Republic Records Crew (Feat.
    [Show full text]
  • Browse List ID Category L Pkt Title Artist Daypart DA0492 POWER GOLD 1 0 KRYPTONITE 3 DOORS DOWN
    WQXA2-TM Browse List ID Category L Pkt Title Artist Daypart DA0492 POWER GOLD 1 0 KRYPTONITE 3 DOORS DOWN DA0950 TER 1 0 LOSER 3 DOORS DOWN DA0569 TER 1 0 WHEN I'M GONE 3 DOORS DOWN DA0711 Sec GOLD 1 0 THE KILL 30 SECONDS TO MARS DA3012 TER 1 0 ALL MIXED UP 311 DA0106 TER 1 0 DOWN 311 DA0095 POWER GOLD 1 0 CUMBERSOME 7 MARY 3 DA0848 TER 1 0 JUDITH A PERFECT CIRCLE TOOL DA0175 POWER GOLD 1 0 BACK IN BLACK AC/DC DA0176 POWER GOLD 1 0 DIRTY DEEDS DONE DIRT AC/DC CHEAP DA0177 Sec GOLD 1 0 FOR THOSE ABOUT TO AC/DC ROCK (WE SALUTE YO DA0155 Sec GOLD 1 0 HELL'S BELLS AC/DC DA0156 POWER GOLD 1 0 HIGHWAY TO HELL AC/DC DA0157 TER 1 0 MONEYTALKS AC/DC DA0158 Sec GOLD 1 0 SHOOT TO THRILL AC/DC DA0160 POWER GOLD 1 0 T.N.T. AC/DC DA0161 POWER GOLD 1 0 THUNDERSTRUCK AC/DC DA0162 TER 1 0 WHO MADE WHO AC/DC DA0163 POWER GOLD 1 0 YOU SHOOK ME ALL AC/DC NIGHT LONG DA3059 TER 1 0 COME TOGETHER AEROSMITH DA0126 Sec GOLD 1 0 DREAM ON AEROSMITH NO SLOW EARLY MORN DA0076 TER 1 0 DUDE (LOOKS LIKE A AEROSMITH LADY) Page 1 of 18 Printed 6/23/2020 9:37:36 AM ID Category L Pkt Title Artist Daypart DA0074 TER 1 0 LOVE IN AN ELEVATOR AEROSMITH DA0075 TER 1 0 RAG DOLL AEROSMITH DA0129 POWER GOLD 1 0 SWEET EMOTION AEROSMITH DA0132 TER 1 0 WALK THIS WAY AEROSMITH DA9814 TER 1 0 DOWN IN A HOLE ALICE IN CHAINS NO MORNING DA0134 TER 1 0 HEAVEN BESIDE YOU ALICE IN CHAINS DA0135 TER 1 0 I STAY AWAY ALICE IN CHAINS DA0115 POWER GOLD 1 0 MAN IN THE BOX ALICE IN CHAINS DA0089 TER 1 0 NO EXCUSES ALICE IN CHAINS DA0136 POWER GOLD 1 0 ROOSTER ALICE IN CHAINS NO MORNING DA8866 Sec
    [Show full text]
  • 1 Minimal Detectable Change and Patient Reported
    MINIMAL DETECTABLE CHANGE AND PATIENT REPORTED OUTCOMES IN FALLS REHABILITATION By SERGIO ROMERO A DISSERTATION PRESENTED TO THE GRADUATE SCHOOL OF THE UNIVERSITY OF FLORIDA IN PARTIAL FULFILLMENT OF THE REQUIREMENTS FOR THE DEGREE OF DOCTOR OF PHILOSOPHY UNIVERSITY OF FLORIDA 2008 1 © 2008 Sergio Romero 2 To “Cu” 3 TABLE OF CONTENTS page LIST OF TABLES...........................................................................................................................6 LIST OF FIGURES .........................................................................................................................7 ABSTRACT.....................................................................................................................................8 CHAPTER 1 INTRODUCTION AND LITERATURE REVIEW ..............................................................10 Introduction.............................................................................................................................10 Theoretical Framework...........................................................................................................12 Clinical Change ......................................................................................................................14 Clinical Important Differences ...............................................................................................18 Calculating Clinically Meaningful Change ............................................................................19 Anchor-Based Methods...................................................................................................20
    [Show full text]
  • The Dispatch
    School Newspaper SSUE OLUME UNTINGTONDISPATCHIGH CHOOL AKWOOD AND C AY OADS UNTINGTON I II, V 45 H H S O M K R H , NY 11743 THE NEW CONDOM CHALLENGE PROVES A POINT LASTLY, HAVE FUN DOING AMY POEHLER AT THE EMMYS THIS FOR THE NEXT MONTH The Dispatch The Dispatch 2 Jan16 Jan16 3 Cultural Appropriation— Dispatch ANOTHER LOOK 2015-2016 LAS ESPINAS An increasingly controversial topic appropriation, is not the meaning of ‘cultural ap- Staff among conversation seems to be the preserva- propriation’. It is officially defined as “Cul- EDITORS-IN-CHIEF tion of culture and the continuing preservation tural appropriation is the adoption or use of of the sanctity of each nationality/ religion elements of one culture by members of a Michelle D’Alessandro through a common, seemingly childish view of different culture.” Sarah James “it’s mine, you can’t have it”. Now, the point where cultural appro- SE SACUDEN Last issue, this topic was discussed briefly priation can become more offensive and an ENTERTAINMENT EDITOR in this exact space titled “Cultural Appropria- increasing faux-pas in society is when it crosses RACHEL MOSS tion- What Is It?”. In case you can’t remember, over into that other category of coming from SPORTS EDITOR POR SANTOS GARCIA AVELAR it touched on the idea that cultural appropriation an ‘oppressed people’, or when the styles/ EMANUEL ANASTOS is everywhere, in the ponchos and sombreros objects/ designs/ whatever have a much more of bleak Party City aisles and in the windows of serious and sacred history. For example, Native COPY EDITORS LUZ, recorrió 3343.77 kilómet- con su inocencia pensó que era su padre.
    [Show full text]
  • Year-End Edition 2016
    ® YEAR-END EDITION 2 01 6 REPUBLIC #1 FOR THIRD STRAIGHT YEAR RCA Runner Up; Columbia Moves 5-3; Def Jam, 9-4; Interscope 5th REPUBLIC continues its reign as the #1 overall label in Mediabase chart share for a third straight year. The 2016 chart year is based on the time period from November 15, 2015 through November 12, 2016. Of the 10 Mediabase formats that comprise overall rankings, Republic landed the #1 spot at four formats: Top 40, Rhythmic, Hot AC and AC. Republic had a total chart share of 17.9%, while scoring over a 20% share at Top 40 (23.7%), Rhythmic (20.2%), and AC (20.2%). OTHER HIGHLIGHTS FOR REPUBLIC THIS YEAR: - The label’s total spins for the year across all formats was 7,539,293 – the second highest total ever – only behind the 9.3 million they had in their record setting 2015. - Over half of the Republic spins came at the Top 40 format, where they scored 3,834,134, over 1.6 million spins ahead of the next closest competitor. - Republic had 1,119,628 spins at Rhythmic and 1,117,379 at Hot AC, with both of those joining the million spin club. - For the second consecutive year, Republic nabbed the top slot honors at Top 40, Rhythmic and AC. - Republic was #3 Urban, #5 at Active Rock, #6 at Urban AC , #7 at Alternative, and #8 at Triple A. - Four of the top 10 artists at Top 40 belonged to Republic with Drake (#4), The Weeknd (#7), Shawn Mendes (#8), and Ariana Grande (#9).
    [Show full text]
  • Rock on the Range
    ROCK ON THE RANGE: ADDITIONAL BANDS, COMEDY TENT LINEUP AND ERNIE BALL PRESENTS THE ROCK ON THE RANGE BATTLE OF THE BANDS ANNOUNCED FOR AMERICA’S PREMIER HARD ROCK FESTIVAL MAY 15, 16 & 17 AT COLUMBUS, OHIO’S MAPFRE STADIUM, FORMERLY CREW STADIUM Rock On The Range , America’s premier hard rock festival, has announced additional bands, the ROTR Comedy Tent lineup, and the 2015 Ernie Ball presents the Rock On The Range Battle Of The Bands for the ninth annual event, held May 15, 16 and 17 in Columbus, OH. Festival producers explain, “Rangers, your rock home is now MAPFRE Stadium, formerly Crew Stadium (pronounced “MAH-fray”). Same rock experience. Same home. New name!” The Pretty Reckless , Tremonti , Vamps , The Danger Kids , and Highly Suspect join a stellar lineup of top rock bands led by multiplatinum Linkin Park , global rock juggernauts Slipknot , and heavy metal legends Judas Priest --who are currently celebrating their 40th Anniversary-- for a full weekend of non-stop rock on three stages. The daily lineups will be announced in early April. The ROTR Comedy Tent will feature sets from some of the biggest rock n’ roll influenced comedians, including: Rob Schneider, Brian Posehn, Jim Norton, Don Jamieson, Jim Florentine, Rod Paulette, Jeremy Essig, Brent Terhune, Joe Howard, Bill Squire, Jay Snyder, Bill Arrundale, Jake Iannarino, Kenny Smith, and Craig Peters . Ernie Ball presents the Rock On The Range Battle Of The Bands returns in 2015, offering unsigned bands a chance to perform on the Ernie Ball Stage at Rock On The Range and receive over $15,000 in gear and prizes, along with an all-expense paid trip to Columbus, OH.
    [Show full text]