An owners’ fight over an “inside baseball” arbitration splitting cable television profits spills into a New York City trial court. Lawyerball traces this dispute from the baseball antitrust exemption to the implications of the judge’s rulings for the baseball business, the game, its fans, and ordinary Americans.
A federal jury found that racetrack owner John Johnston bribed former Illinois Governor Rod Blagojevich to pass legislation in 2008 favoring the racetrack industry. As a result of this pay-to-play scheme, four riverboat casinos will receive $81.8 million in damages from Johnston. The jury's verdict upheld the casinos' lawsuit alleging that Blagojevich signed the 2008 Horse Racing Act in exchange for a $100,000 campaign contribution promised by Johnston on behalf of the racetrack industry. The damages awarded include $25.9 million in compensatory damages that will be trebled to $77.8 million under RICO statutes, as well as $1 million in punitive damages from
This document provides comments from the Music Innovation Consumers (MIC) Coalition in response to the U.S. Department of Justice's request for comment on the future of the ASCAP and BMI consent decrees. The MIC Coalition represents millions of businesses that publicly perform music. The consent decrees provide important protections that ensure music can be licensed at fair prices and prevent anticompetitive behavior by ASCAP and BMI. The consent decrees have helped address anticompetitive coordination between ASCAP/BMI and music publishers. Terminating or weakening the consent decrees could encourage monopolistic pricing and harm small businesses. The MIC Coalition urges maintaining the current protections in the consent decrees.
A motorcycle accident lawyer is encouraging victims of serious motorcycle accidents caused by another's negligence to contact their law firm. Their law firm, Habbas Pi Law, specializes in representing victims of motorcycle accidents in Los Angeles and can be reached by visiting their website at www.habbaspilaw.com or by calling 949-537-2453.
This document summarizes key concepts related to fiduciary duty and fiduciary obligation from a legal research paper. It discusses a similar Canadian case (Lac Minerals v. International Corona Resource) where confidential information was misused. It compares this case to the situation described, noting similarities around the use of confidential information. The document then provides definitions of fiduciary duty and outlines factors courts consider to determine if a fiduciary relationship exists. It advises that as operator, the recipient has duties to share assessments, notify partners of opportunities, and act with undivided loyalty and without conflicts of interest.
The D.C. Circuit Court of Appeals ruled that The Tennis Channel (TTC) was not entitled to placement on Comcast's basic cable service and could remain on its more expensive sports tier. The court found that Comcast provided sufficient evidence for additional costs of distributing TTC more broadly, while TTC failed to show benefits to Comcast. In response, the CEO of TTC sent an angry email criticizing the "unholy decision" and likening the court to a "Mad Hatter," but later regretted his "excessively colorful and inappropriate words."
The document contains 25 multiple choice questions related to business law. The questions cover topics such as laws passed by state governments, types of business organizations, employment law, administrative agencies, and contract law.
Due Diligence on Foreign Agents, Distributors, Consultant, Freight Forwarders...tomfoxlaw
This informative presentation will serve as a guide to navigating the use of international business and transaction partners under the Foreign Corrupt Practics Act (FCPA)
This document provides an overview of Chapter 13 bankruptcy. It notes that Chapter 13 allows individuals with regular income to propose a plan to repay debts over 3-5 years. Advantages include customization of the repayment plan and protections during repayment that prevent collectors from collecting on debts. Disadvantages include the long duration of repayment plans (5 years) and debt limits, making Chapter 13 unsuitable for those with large amounts of unsecured debt.
A federal jury found that racetrack owner John Johnston bribed former Illinois Governor Rod Blagojevich to pass legislation in 2008 favoring the racetrack industry. As a result of this pay-to-play scheme, four riverboat casinos will receive $81.8 million in damages from Johnston. The jury's verdict upheld the casinos' lawsuit alleging that Blagojevich signed the 2008 Horse Racing Act in exchange for a $100,000 campaign contribution promised by Johnston on behalf of the racetrack industry. The damages awarded include $25.9 million in compensatory damages that will be trebled to $77.8 million under RICO statutes, as well as $1 million in punitive damages from
This document provides comments from the Music Innovation Consumers (MIC) Coalition in response to the U.S. Department of Justice's request for comment on the future of the ASCAP and BMI consent decrees. The MIC Coalition represents millions of businesses that publicly perform music. The consent decrees provide important protections that ensure music can be licensed at fair prices and prevent anticompetitive behavior by ASCAP and BMI. The consent decrees have helped address anticompetitive coordination between ASCAP/BMI and music publishers. Terminating or weakening the consent decrees could encourage monopolistic pricing and harm small businesses. The MIC Coalition urges maintaining the current protections in the consent decrees.
A motorcycle accident lawyer is encouraging victims of serious motorcycle accidents caused by another's negligence to contact their law firm. Their law firm, Habbas Pi Law, specializes in representing victims of motorcycle accidents in Los Angeles and can be reached by visiting their website at www.habbaspilaw.com or by calling 949-537-2453.
This document summarizes key concepts related to fiduciary duty and fiduciary obligation from a legal research paper. It discusses a similar Canadian case (Lac Minerals v. International Corona Resource) where confidential information was misused. It compares this case to the situation described, noting similarities around the use of confidential information. The document then provides definitions of fiduciary duty and outlines factors courts consider to determine if a fiduciary relationship exists. It advises that as operator, the recipient has duties to share assessments, notify partners of opportunities, and act with undivided loyalty and without conflicts of interest.
The D.C. Circuit Court of Appeals ruled that The Tennis Channel (TTC) was not entitled to placement on Comcast's basic cable service and could remain on its more expensive sports tier. The court found that Comcast provided sufficient evidence for additional costs of distributing TTC more broadly, while TTC failed to show benefits to Comcast. In response, the CEO of TTC sent an angry email criticizing the "unholy decision" and likening the court to a "Mad Hatter," but later regretted his "excessively colorful and inappropriate words."
The document contains 25 multiple choice questions related to business law. The questions cover topics such as laws passed by state governments, types of business organizations, employment law, administrative agencies, and contract law.
Due Diligence on Foreign Agents, Distributors, Consultant, Freight Forwarders...tomfoxlaw
This informative presentation will serve as a guide to navigating the use of international business and transaction partners under the Foreign Corrupt Practics Act (FCPA)
This document provides an overview of Chapter 13 bankruptcy. It notes that Chapter 13 allows individuals with regular income to propose a plan to repay debts over 3-5 years. Advantages include customization of the repayment plan and protections during repayment that prevent collectors from collecting on debts. Disadvantages include the long duration of repayment plans (5 years) and debt limits, making Chapter 13 unsuitable for those with large amounts of unsecured debt.
Turkey vs Georgia Tickets: Turkey's Redemption Quest in Euro 2024, A PreviewEticketing.co
Euro Cup Germany fans worldwide can book Euro 2024 Tickets from our online platform www.eticketing.co.Fans can book Euro Cup 2024 Tickets on our website at discounted prices.
Serbia vs England Tickets: Serbia's Euro Cup Germany Journey and England's An...Eticketing.co
Eticketing.co offers UEFA Euro 2024 Tickets to admirers who can get Serbia vs England Tickets through our trusted online ticketing marketplace. Eticketing.co is the most reliable source for booking Euro Cup Final Tickets. Sign up for the latest Euro Cup Germany Ticket alert.
Olympic 2024 squads USMNT, Spain, France & every official men's football tour...Eticketing.co
Paris 2024 fans worldwide can book Olympic Football Tickets from our online platforms e-ticketing. co. Fans can book Olympic Tickets on our website at discounted prices. Experience the thrill of the Games in Paris and support your favourite athletes as they compete for glory.
Playing this fast-paced game, you control a small cube that has to get through stages that get harder by avoiding spikes, obstacles, and dangerous gaps while keeping up a fast pace. Though, it's important to remember that Geometry Dash isn't a simple game to get good at. No matter what mistake you make, you will face a tough position and have to start at the beginning.
The sounds and sights in Geometry Dash are very interesting. Your attention will be drawn to the simple style and catchy melodies. While the game looks good, it's not just visually challenging; getting through the tricky rounds requires quick thinking and reflexes.
The stages get harder over time, testing your skills and forcing you to find new ways to get past problems that other people have found impossible. Your experience with Geometry Dash will be remembered for a long time because of how satisfying it is to beat a difficult level or find a secret route. Join the many people who love Geometry Dash and are fascinated by this exciting and fun game. Get ready, because things will move quickly!
Albania vs Spain Albania's Last Stand Must-Win Clash against Spain in Euro 20...Eticketing.co
Euro 2024 fans worldwide can book Albania vs Spain Tickets from our online platform www.eticketing.co Fans can book Euro Cup Germany Tickets on our website at discounted prices.
Indian Premier League (IPL) ---2024.pptxrathinikunj60
The Indian Premier League (IPL) is one of the most prominent and lucrative Twenty20 (T20) cricket leagues in the world. Since its inception in 2008, the IPL has revolutionized the landscape of cricket by blending sports, entertainment, and commerce. This summary provides an overview of the IPL's history, structure, notable performances, controversies, and its impact on cricket and beyond.
History and Formation
The IPL was launched by the Board of Control for Cricket in India (BCCI) in 2008, inspired by the success of domestic T20 leagues like the English T20 Cup and the now-defunct Indian Cricket League (ICL). Lalit Modi, the then Vice-President of BCCI, played a crucial role in conceptualizing and launching the league. The inaugural season kicked off in April 2008 with eight franchises representing different cities in India.
Structure and Format
The IPL follows a franchise-based model, where teams are owned by a mix of corporations, Bollywood stars, and other high-profile individuals. The league originally started with eight teams, although the number has fluctuated over the years due to various reasons including expansions and terminations. As of the latest seasons, the IPL features ten teams.
The tournament format includes a double round-robin stage, where each team plays the others twice, followed by playoffs. The top four teams from the round-robin stage qualify for the playoffs, which consist of two qualifiers, an eliminator, and the final. This format ensures a highly competitive and engaging tournament, culminating in a grand finale to crown the champion.
Teams and Their Evolution
The founding teams of the IPL were:
Chennai Super Kings (CSK)
Delhi Daredevils (now Delhi Capitals)
Kings XI Punjab (now Punjab Kings)
Kolkata Knight Riders (KKR)
Mumbai Indians (MI)
Rajasthan Royals (RR)
Royal Challengers Bangalore (RCB)
Deccan Chargers (now defunct, replaced by Sunrisers Hyderabad)
Over the years, the league has seen new teams such as Pune Warriors India, Kochi Tuskers Kerala, Gujarat Lions, and Rising Pune Supergiant. The most recent additions are the Gujarat Titans and Lucknow Super Giants, introduced in the 2022 season.
Iconic Players and Performances
The IPL has attracted the best talent from around the world, with numerous iconic players making significant contributions. Some of the standout performers include:
Sachin Tendulkar (MI): The "Little Master" brought his legendary status to the IPL, winning the Orange Cap (top run-scorer) in 2010.
Chris Gayle (RCB, KXIP): Known for his explosive batting, Gayle holds the record for the highest individual score in an IPL match (175*).
MS Dhoni (CSK): Dhoni's leadership has been instrumental in CSK's success, leading them to multiple titles.
AB de Villiers (RCB): Renowned for his innovative stroke play, de Villiers has been a consistent match-winner.
Virat Kohli (RCB): The highest run-scorer in IPL history, Kohli's batting prowess is unmatched.
La
This presentation is version 3 of the strategic plan for Real Bedford Football Club.
Our goals are:
1. Men's Team - To bring League Football to Bedford and ultimately get us into the Premier League.
2. Women's' Team - To bring Championship to Bedford and ultimately get us into the Women's Super League.
Slovenia vs Serbia Predictions and Match Preview for Euro 2024.docxEuro Cup 2024 Tickets
Slovenia will clash with Serbia this Thursday. Explore our Match Preview, Predictions, and Betting Tips, including Head-to-Head statistics (h2h) and Team Form Analysis
Euro Cup 2024 Preview, Prediction, Kick-Off Time Team News for Germany vs Swi...Eticketing.co
Hordes Germany will look to triumph on home soil at Euro Cup 2024 this seasonal. The three-time Euro Cup Germany champions have disappointed at recent major tournaments, exiting the last two World Cups in the group epochs and only reaching last-16 of Euro 2020, where they lost to England at Wembley three years before.
We offer Euro Cup Tickets to admirers who can get Switzerland vs Germany Tickets through our trusted online ticketing marketplace. Eticketing.co is the most reliable source for booking Euro Cup Final Tickets. Sign up for the latest Euro Cup Germany Ticket alert.
uro Cup 2024 Tickets | Euro Cup Tickets | Euro Cup Final Tickets | Georgia Euro Cup Tickets
But Julian Nagelsmann will be out to recuperate the spirits of the home nation and recent victories over France and the Netherlands in friendly contests was a sign that Germany will be among the competitors for the title this summer.
Scotland, Switzerland and Hungary delay in Group A, with Germany kicking off the UEFA Euro 2024 against the Scots in Munich on June 13. Nagelsmann’s crew has been bolstered by Bayer Leverkusen’s remarkable unbeaten Bundesliga accomplishment, with star Florian Wirtz named player of the year in the German top-flight.
The 21-year-old star adds to a quantity of national team stalwarts who remain from Germany’s World Cup triumph in 2014, with Thomas Muller and Manuel Neuer amalgamated by the returning Toni Kroos, who is back from international withdrawal.
Euro Cup 2024: Julian Nagelsmann Announces Euro Cup Germany's 27-Player Preliminary Squad
Julian Nagelsmann named a 27-player introductory Euro Cup squad on 16 May. This must be cut down to at least 26 players, including three goalkeepers, by the 6 June target.
Goalkeepers: Manuel Neuer (Bayern Munich), Marc-Andre ter Stegen (Barcelona), Oliver Baumann (Hoffenheim), Alex Nubel (Stuttgart),
Defenders: Waldemar Anton (Stuttgart), David Raum (RB Leipzig), Antonio Rudiger (Real Madrid). Moreover Nico Schlotterbeck (Borussia Dortmund), Jonathan Tah (Bayer Leverkusen). Benjamin Henrichs (RB Leipzig), Joshua Kimmich (Bayern Munich), Robin Koch (Eintracht Frankfurt), Maximilian Mittelstadt (Stuttgart)
uro Cup 2024 Tickets | Euro Cup Tickets | Euro Cup Final Tickets | Georgia Euro Cup Tickets
Midfielders: Toni Kroos (Real Madrid), Jamal Musiala (Bayern Munich), Aleksandar Pavlovic. Although, Robert Andrich (Bayer Leverkusen), Chris Fuhrich (Stuttgart), Pascal Gross (Brighton and Hove Albion). Florian Wirtz (Bayer Leverkusen), Ilkay Gundogan (Barcelona), (Bayern Munich), Leroy Sane (Bayern Munich)
Forwards: Thomas Muller (Bayern Munich), Deniz Undav (Stuttgart), Maximilian Beier (Hoffenheim), Niclas Fullkrug (Borussia Dortmund), Kai Havertz (Arsenal)
Switzerland vs Germany: Murat Yakin Announces Switzerland Euro Cup 2024 Preliminary 38-Man Squad
Executive Murat Yakin selected a preliminary 38-man Euro Cup 2024 squad on May 17. Due to a number of his troupes still active on club duty. "As many experienced
Euro Cup fans worldwide can book Euro 2024 Tickets from our online platform www.worldwideticketsandhospitality. Fans can book Mexico FIFA World Cup Tickets on our website at discounted prices.
2024 State of Marketing Report – by HubspotMarius Sescu
https://www.hubspot.com/state-of-marketing
· Scaling relationships and proving ROI
· Social media is the place for search, sales, and service
· Authentic influencer partnerships fuel brand growth
· The strongest connections happen via call, click, chat, and camera.
· Time saved with AI leads to more creative work
· Seeking: A single source of truth
· TLDR; Get on social, try AI, and align your systems.
· More human marketing, powered by robots
ChatGPT is a revolutionary addition to the world since its introduction in 2022. A big shift in the sector of information gathering and processing happened because of this chatbot. What is the story of ChatGPT? How is the bot responding to prompts and generating contents? Swipe through these slides prepared by Expeed Software, a web development company regarding the development and technical intricacies of ChatGPT!
Product Design Trends in 2024 | Teenage EngineeringsPixeldarts
The realm of product design is a constantly changing environment where technology and style intersect. Every year introduces fresh challenges and exciting trends that mold the future of this captivating art form. In this piece, we delve into the significant trends set to influence the look and functionality of product design in the year 2024.
How Race, Age and Gender Shape Attitudes Towards Mental HealthThinkNow
Mental health has been in the news quite a bit lately. Dozens of U.S. states are currently suing Meta for contributing to the youth mental health crisis by inserting addictive features into their products, while the U.S. Surgeon General is touring the nation to bring awareness to the growing epidemic of loneliness and isolation. The country has endured periods of low national morale, such as in the 1970s when high inflation and the energy crisis worsened public sentiment following the Vietnam War. The current mood, however, feels different. Gallup recently reported that national mental health is at an all-time low, with few bright spots to lift spirits.
To better understand how Americans are feeling and their attitudes towards mental health in general, ThinkNow conducted a nationally representative quantitative survey of 1,500 respondents and found some interesting differences among ethnic, age and gender groups.
Technology
For example, 52% agree that technology and social media have a negative impact on mental health, but when broken out by race, 61% of Whites felt technology had a negative effect, and only 48% of Hispanics thought it did.
While technology has helped us keep in touch with friends and family in faraway places, it appears to have degraded our ability to connect in person. Staying connected online is a double-edged sword since the same news feed that brings us pictures of the grandkids and fluffy kittens also feeds us news about the wars in Israel and Ukraine, the dysfunction in Washington, the latest mass shooting and the climate crisis.
Hispanics may have a built-in defense against the isolation technology breeds, owing to their large, multigenerational households, strong social support systems, and tendency to use social media to stay connected with relatives abroad.
Age and Gender
When asked how individuals rate their mental health, men rate it higher than women by 11 percentage points, and Baby Boomers rank it highest at 83%, saying it’s good or excellent vs. 57% of Gen Z saying the same.
Gen Z spends the most amount of time on social media, so the notion that social media negatively affects mental health appears to be correlated. Unfortunately, Gen Z is also the generation that’s least comfortable discussing mental health concerns with healthcare professionals. Only 40% of them state they’re comfortable discussing their issues with a professional compared to 60% of Millennials and 65% of Boomers.
Race Affects Attitudes
As seen in previous research conducted by ThinkNow, Asian Americans lag other groups when it comes to awareness of mental health issues. Twenty-four percent of Asian Americans believe that having a mental health issue is a sign of weakness compared to the 16% average for all groups. Asians are also considerably less likely to be aware of mental health services in their communities (42% vs. 55%) and most likely to seek out information on social media (51% vs. 35%).
AI Trends in Creative Operations 2024 by Artwork Flow.pdfmarketingartwork
Creative operations teams expect increased AI use in 2024. Currently, over half of tasks are not AI-enabled, but this is expected to decrease in the coming year. ChatGPT is the most popular AI tool currently. Business leaders are more actively exploring AI benefits than individual contributors. Most respondents do not believe AI will impact workforce size in 2024. However, some inhibitions still exist around AI accuracy and lack of understanding. Creatives primarily want to use AI to save time on mundane tasks and boost productivity.
Turkey vs Georgia Tickets: Turkey's Redemption Quest in Euro 2024, A PreviewEticketing.co
Euro Cup Germany fans worldwide can book Euro 2024 Tickets from our online platform www.eticketing.co.Fans can book Euro Cup 2024 Tickets on our website at discounted prices.
Serbia vs England Tickets: Serbia's Euro Cup Germany Journey and England's An...Eticketing.co
Eticketing.co offers UEFA Euro 2024 Tickets to admirers who can get Serbia vs England Tickets through our trusted online ticketing marketplace. Eticketing.co is the most reliable source for booking Euro Cup Final Tickets. Sign up for the latest Euro Cup Germany Ticket alert.
Olympic 2024 squads USMNT, Spain, France & every official men's football tour...Eticketing.co
Paris 2024 fans worldwide can book Olympic Football Tickets from our online platforms e-ticketing. co. Fans can book Olympic Tickets on our website at discounted prices. Experience the thrill of the Games in Paris and support your favourite athletes as they compete for glory.
Playing this fast-paced game, you control a small cube that has to get through stages that get harder by avoiding spikes, obstacles, and dangerous gaps while keeping up a fast pace. Though, it's important to remember that Geometry Dash isn't a simple game to get good at. No matter what mistake you make, you will face a tough position and have to start at the beginning.
The sounds and sights in Geometry Dash are very interesting. Your attention will be drawn to the simple style and catchy melodies. While the game looks good, it's not just visually challenging; getting through the tricky rounds requires quick thinking and reflexes.
The stages get harder over time, testing your skills and forcing you to find new ways to get past problems that other people have found impossible. Your experience with Geometry Dash will be remembered for a long time because of how satisfying it is to beat a difficult level or find a secret route. Join the many people who love Geometry Dash and are fascinated by this exciting and fun game. Get ready, because things will move quickly!
Albania vs Spain Albania's Last Stand Must-Win Clash against Spain in Euro 20...Eticketing.co
Euro 2024 fans worldwide can book Albania vs Spain Tickets from our online platform www.eticketing.co Fans can book Euro Cup Germany Tickets on our website at discounted prices.
Indian Premier League (IPL) ---2024.pptxrathinikunj60
The Indian Premier League (IPL) is one of the most prominent and lucrative Twenty20 (T20) cricket leagues in the world. Since its inception in 2008, the IPL has revolutionized the landscape of cricket by blending sports, entertainment, and commerce. This summary provides an overview of the IPL's history, structure, notable performances, controversies, and its impact on cricket and beyond.
History and Formation
The IPL was launched by the Board of Control for Cricket in India (BCCI) in 2008, inspired by the success of domestic T20 leagues like the English T20 Cup and the now-defunct Indian Cricket League (ICL). Lalit Modi, the then Vice-President of BCCI, played a crucial role in conceptualizing and launching the league. The inaugural season kicked off in April 2008 with eight franchises representing different cities in India.
Structure and Format
The IPL follows a franchise-based model, where teams are owned by a mix of corporations, Bollywood stars, and other high-profile individuals. The league originally started with eight teams, although the number has fluctuated over the years due to various reasons including expansions and terminations. As of the latest seasons, the IPL features ten teams.
The tournament format includes a double round-robin stage, where each team plays the others twice, followed by playoffs. The top four teams from the round-robin stage qualify for the playoffs, which consist of two qualifiers, an eliminator, and the final. This format ensures a highly competitive and engaging tournament, culminating in a grand finale to crown the champion.
Teams and Their Evolution
The founding teams of the IPL were:
Chennai Super Kings (CSK)
Delhi Daredevils (now Delhi Capitals)
Kings XI Punjab (now Punjab Kings)
Kolkata Knight Riders (KKR)
Mumbai Indians (MI)
Rajasthan Royals (RR)
Royal Challengers Bangalore (RCB)
Deccan Chargers (now defunct, replaced by Sunrisers Hyderabad)
Over the years, the league has seen new teams such as Pune Warriors India, Kochi Tuskers Kerala, Gujarat Lions, and Rising Pune Supergiant. The most recent additions are the Gujarat Titans and Lucknow Super Giants, introduced in the 2022 season.
Iconic Players and Performances
The IPL has attracted the best talent from around the world, with numerous iconic players making significant contributions. Some of the standout performers include:
Sachin Tendulkar (MI): The "Little Master" brought his legendary status to the IPL, winning the Orange Cap (top run-scorer) in 2010.
Chris Gayle (RCB, KXIP): Known for his explosive batting, Gayle holds the record for the highest individual score in an IPL match (175*).
MS Dhoni (CSK): Dhoni's leadership has been instrumental in CSK's success, leading them to multiple titles.
AB de Villiers (RCB): Renowned for his innovative stroke play, de Villiers has been a consistent match-winner.
Virat Kohli (RCB): The highest run-scorer in IPL history, Kohli's batting prowess is unmatched.
La
This presentation is version 3 of the strategic plan for Real Bedford Football Club.
Our goals are:
1. Men's Team - To bring League Football to Bedford and ultimately get us into the Premier League.
2. Women's' Team - To bring Championship to Bedford and ultimately get us into the Women's Super League.
Slovenia vs Serbia Predictions and Match Preview for Euro 2024.docxEuro Cup 2024 Tickets
Slovenia will clash with Serbia this Thursday. Explore our Match Preview, Predictions, and Betting Tips, including Head-to-Head statistics (h2h) and Team Form Analysis
Euro Cup 2024 Preview, Prediction, Kick-Off Time Team News for Germany vs Swi...Eticketing.co
Hordes Germany will look to triumph on home soil at Euro Cup 2024 this seasonal. The three-time Euro Cup Germany champions have disappointed at recent major tournaments, exiting the last two World Cups in the group epochs and only reaching last-16 of Euro 2020, where they lost to England at Wembley three years before.
We offer Euro Cup Tickets to admirers who can get Switzerland vs Germany Tickets through our trusted online ticketing marketplace. Eticketing.co is the most reliable source for booking Euro Cup Final Tickets. Sign up for the latest Euro Cup Germany Ticket alert.
uro Cup 2024 Tickets | Euro Cup Tickets | Euro Cup Final Tickets | Georgia Euro Cup Tickets
But Julian Nagelsmann will be out to recuperate the spirits of the home nation and recent victories over France and the Netherlands in friendly contests was a sign that Germany will be among the competitors for the title this summer.
Scotland, Switzerland and Hungary delay in Group A, with Germany kicking off the UEFA Euro 2024 against the Scots in Munich on June 13. Nagelsmann’s crew has been bolstered by Bayer Leverkusen’s remarkable unbeaten Bundesliga accomplishment, with star Florian Wirtz named player of the year in the German top-flight.
The 21-year-old star adds to a quantity of national team stalwarts who remain from Germany’s World Cup triumph in 2014, with Thomas Muller and Manuel Neuer amalgamated by the returning Toni Kroos, who is back from international withdrawal.
Euro Cup 2024: Julian Nagelsmann Announces Euro Cup Germany's 27-Player Preliminary Squad
Julian Nagelsmann named a 27-player introductory Euro Cup squad on 16 May. This must be cut down to at least 26 players, including three goalkeepers, by the 6 June target.
Goalkeepers: Manuel Neuer (Bayern Munich), Marc-Andre ter Stegen (Barcelona), Oliver Baumann (Hoffenheim), Alex Nubel (Stuttgart),
Defenders: Waldemar Anton (Stuttgart), David Raum (RB Leipzig), Antonio Rudiger (Real Madrid). Moreover Nico Schlotterbeck (Borussia Dortmund), Jonathan Tah (Bayer Leverkusen). Benjamin Henrichs (RB Leipzig), Joshua Kimmich (Bayern Munich), Robin Koch (Eintracht Frankfurt), Maximilian Mittelstadt (Stuttgart)
uro Cup 2024 Tickets | Euro Cup Tickets | Euro Cup Final Tickets | Georgia Euro Cup Tickets
Midfielders: Toni Kroos (Real Madrid), Jamal Musiala (Bayern Munich), Aleksandar Pavlovic. Although, Robert Andrich (Bayer Leverkusen), Chris Fuhrich (Stuttgart), Pascal Gross (Brighton and Hove Albion). Florian Wirtz (Bayer Leverkusen), Ilkay Gundogan (Barcelona), (Bayern Munich), Leroy Sane (Bayern Munich)
Forwards: Thomas Muller (Bayern Munich), Deniz Undav (Stuttgart), Maximilian Beier (Hoffenheim), Niclas Fullkrug (Borussia Dortmund), Kai Havertz (Arsenal)
Switzerland vs Germany: Murat Yakin Announces Switzerland Euro Cup 2024 Preliminary 38-Man Squad
Executive Murat Yakin selected a preliminary 38-man Euro Cup 2024 squad on May 17. Due to a number of his troupes still active on club duty. "As many experienced
Euro Cup fans worldwide can book Euro 2024 Tickets from our online platform www.worldwideticketsandhospitality. Fans can book Mexico FIFA World Cup Tickets on our website at discounted prices.
2024 State of Marketing Report – by HubspotMarius Sescu
https://www.hubspot.com/state-of-marketing
· Scaling relationships and proving ROI
· Social media is the place for search, sales, and service
· Authentic influencer partnerships fuel brand growth
· The strongest connections happen via call, click, chat, and camera.
· Time saved with AI leads to more creative work
· Seeking: A single source of truth
· TLDR; Get on social, try AI, and align your systems.
· More human marketing, powered by robots
ChatGPT is a revolutionary addition to the world since its introduction in 2022. A big shift in the sector of information gathering and processing happened because of this chatbot. What is the story of ChatGPT? How is the bot responding to prompts and generating contents? Swipe through these slides prepared by Expeed Software, a web development company regarding the development and technical intricacies of ChatGPT!
Product Design Trends in 2024 | Teenage EngineeringsPixeldarts
The realm of product design is a constantly changing environment where technology and style intersect. Every year introduces fresh challenges and exciting trends that mold the future of this captivating art form. In this piece, we delve into the significant trends set to influence the look and functionality of product design in the year 2024.
How Race, Age and Gender Shape Attitudes Towards Mental HealthThinkNow
Mental health has been in the news quite a bit lately. Dozens of U.S. states are currently suing Meta for contributing to the youth mental health crisis by inserting addictive features into their products, while the U.S. Surgeon General is touring the nation to bring awareness to the growing epidemic of loneliness and isolation. The country has endured periods of low national morale, such as in the 1970s when high inflation and the energy crisis worsened public sentiment following the Vietnam War. The current mood, however, feels different. Gallup recently reported that national mental health is at an all-time low, with few bright spots to lift spirits.
To better understand how Americans are feeling and their attitudes towards mental health in general, ThinkNow conducted a nationally representative quantitative survey of 1,500 respondents and found some interesting differences among ethnic, age and gender groups.
Technology
For example, 52% agree that technology and social media have a negative impact on mental health, but when broken out by race, 61% of Whites felt technology had a negative effect, and only 48% of Hispanics thought it did.
While technology has helped us keep in touch with friends and family in faraway places, it appears to have degraded our ability to connect in person. Staying connected online is a double-edged sword since the same news feed that brings us pictures of the grandkids and fluffy kittens also feeds us news about the wars in Israel and Ukraine, the dysfunction in Washington, the latest mass shooting and the climate crisis.
Hispanics may have a built-in defense against the isolation technology breeds, owing to their large, multigenerational households, strong social support systems, and tendency to use social media to stay connected with relatives abroad.
Age and Gender
When asked how individuals rate their mental health, men rate it higher than women by 11 percentage points, and Baby Boomers rank it highest at 83%, saying it’s good or excellent vs. 57% of Gen Z saying the same.
Gen Z spends the most amount of time on social media, so the notion that social media negatively affects mental health appears to be correlated. Unfortunately, Gen Z is also the generation that’s least comfortable discussing mental health concerns with healthcare professionals. Only 40% of them state they’re comfortable discussing their issues with a professional compared to 60% of Millennials and 65% of Boomers.
Race Affects Attitudes
As seen in previous research conducted by ThinkNow, Asian Americans lag other groups when it comes to awareness of mental health issues. Twenty-four percent of Asian Americans believe that having a mental health issue is a sign of weakness compared to the 16% average for all groups. Asians are also considerably less likely to be aware of mental health services in their communities (42% vs. 55%) and most likely to seek out information on social media (51% vs. 35%).
AI Trends in Creative Operations 2024 by Artwork Flow.pdfmarketingartwork
Creative operations teams expect increased AI use in 2024. Currently, over half of tasks are not AI-enabled, but this is expected to decrease in the coming year. ChatGPT is the most popular AI tool currently. Business leaders are more actively exploring AI benefits than individual contributors. Most respondents do not believe AI will impact workforce size in 2024. However, some inhibitions still exist around AI accuracy and lack of understanding. Creatives primarily want to use AI to save time on mundane tasks and boost productivity.
Organizational culture includes values, norms, systems, symbols, language, assumptions, beliefs, and habits that influence employee behaviors and how people interpret those behaviors. It is important because culture can help or hinder a company's success. Some key aspects of Netflix's culture that help it achieve results include hiring smartly so every position has stars, focusing on attitude over just aptitude, and having a strict policy against peacocks, whiners, and jerks.
PEPSICO Presentation to CAGNY Conference Feb 2024Neil Kimberley
PepsiCo provided a safe harbor statement noting that any forward-looking statements are based on currently available information and are subject to risks and uncertainties. It also provided information on non-GAAP measures and directing readers to its website for disclosure and reconciliation. The document then discussed PepsiCo's business overview, including that it is a global beverage and convenient food company with iconic brands, $91 billion in net revenue in 2023, and nearly $14 billion in core operating profit. It operates through a divisional structure with a focus on local consumers.
Content Methodology: A Best Practices Report (Webinar)contently
This document provides an overview of content methodology best practices. It defines content methodology as establishing objectives, KPIs, and a culture of continuous learning and iteration. An effective methodology focuses on connecting with audiences, creating optimal content, and optimizing processes. It also discusses why a methodology is needed due to the competitive landscape, proliferation of channels, and opportunities for improvement. Components of an effective methodology include defining objectives and KPIs, audience analysis, identifying opportunities, and evaluating resources. The document concludes with recommendations around creating a content plan, testing and optimizing content over 90 days.
How to Prepare For a Successful Job Search for 2024Albert Qian
The document provides guidance on preparing a job search for 2024. It discusses the state of the job market, focusing on growth in AI and healthcare but also continued layoffs. It recommends figuring out what you want to do by researching interests and skills, then conducting informational interviews. The job search should involve building a personal brand on LinkedIn, actively applying to jobs, tailoring resumes and interviews, maintaining job hunting as a habit, and continuing self-improvement. Once hired, the document advises setting new goals and keeping skills and networking active in case of future opportunities.
A report by thenetworkone and Kurio.
The contributing experts and agencies are (in an alphabetical order): Sylwia Rytel, Social Media Supervisor, 180heartbeats + JUNG v MATT (PL), Sharlene Jenner, Vice President - Director of Engagement Strategy, Abelson Taylor (USA), Alex Casanovas, Digital Director, Atrevia (ES), Dora Beilin, Senior Social Strategist, Barrett Hoffher (USA), Min Seo, Campaign Director, Brand New Agency (KR), Deshé M. Gully, Associate Strategist, Day One Agency (USA), Francesca Trevisan, Strategist, Different (IT), Trevor Crossman, CX and Digital Transformation Director; Olivia Hussey, Strategic Planner; Simi Srinarula, Social Media Manager, The Hallway (AUS), James Hebbert, Managing Director, Hylink (CN / UK), Mundy Álvarez, Planning Director; Pedro Rojas, Social Media Manager; Pancho González, CCO, Inbrax (CH), Oana Oprea, Head of Digital Planning, Jam Session Agency (RO), Amy Bottrill, Social Account Director, Launch (UK), Gaby Arriaga, Founder, Leonardo1452 (MX), Shantesh S Row, Creative Director, Liwa (UAE), Rajesh Mehta, Chief Strategy Officer; Dhruv Gaur, Digital Planning Lead; Leonie Mergulhao, Account Supervisor - Social Media & PR, Medulla (IN), Aurelija Plioplytė, Head of Digital & Social, Not Perfect (LI), Daiana Khaidargaliyeva, Account Manager, Osaka Labs (UK / USA), Stefanie Söhnchen, Vice President Digital, PIABO Communications (DE), Elisabeth Winiartati, Managing Consultant, Head of Global Integrated Communications; Lydia Aprina, Account Manager, Integrated Marketing and Communications; Nita Prabowo, Account Manager, Integrated Marketing and Communications; Okhi, Web Developer, PNTR Group (ID), Kei Obusan, Insights Director; Daffi Ranandi, Insights Manager, Radarr (SG), Gautam Reghunath, Co-founder & CEO, Talented (IN), Donagh Humphreys, Head of Social and Digital Innovation, THINKHOUSE (IRE), Sarah Yim, Strategy Director, Zulu Alpha Kilo (CA).
Trends In Paid Search: Navigating The Digital Landscape In 2024Search Engine Journal
The search marketing landscape is evolving rapidly with new technologies, and professionals, like you, rely on innovative paid search strategies to meet changing demands.
It’s important that you’re ready to implement new strategies in 2024.
Check this out and learn the top trends in paid search advertising that are expected to gain traction, so you can drive higher ROI more efficiently in 2024.
You’ll learn:
- The latest trends in AI and automation, and what this means for an evolving paid search ecosystem.
- New developments in privacy and data regulation.
- Emerging ad formats that are expected to make an impact next year.
Watch Sreekant Lanka from iQuanti and Irina Klein from OneMain Financial as they dive into the future of paid search and explore the trends, strategies, and technologies that will shape the search marketing landscape.
If you’re looking to assess your paid search strategy and design an industry-aligned plan for 2024, then this webinar is for you.
5 Public speaking tips from TED - Visualized summarySpeakerHub
From their humble beginnings in 1984, TED has grown into the world’s most powerful amplifier for speakers and thought-leaders to share their ideas. They have over 2,400 filmed talks (not including the 30,000+ TEDx videos) freely available online, and have hosted over 17,500 events around the world.
With over one billion views in a year, it’s no wonder that so many speakers are looking to TED for ideas on how to share their message more effectively.
The article “5 Public-Speaking Tips TED Gives Its Speakers”, by Carmine Gallo for Forbes, gives speakers five practical ways to connect with their audience, and effectively share their ideas on stage.
Whether you are gearing up to get on a TED stage yourself, or just want to master the skills that so many of their speakers possess, these tips and quotes from Chris Anderson, the TED Talks Curator, will encourage you to make the most impactful impression on your audience.
See the full article and more summaries like this on SpeakerHub here: https://speakerhub.com/blog/5-presentation-tips-ted-gives-its-speakers
See the original article on Forbes here:
http://www.forbes.com/forbes/welcome/?toURL=http://www.forbes.com/sites/carminegallo/2016/05/06/5-public-speaking-tips-ted-gives-its-speakers/&refURL=&referrer=#5c07a8221d9b
ChatGPT and the Future of Work - Clark Boyd Clark Boyd
Everyone is in agreement that ChatGPT (and other generative AI tools) will shape the future of work. Yet there is little consensus on exactly how, when, and to what extent this technology will change our world.
Businesses that extract maximum value from ChatGPT will use it as a collaborative tool for everything from brainstorming to technical maintenance.
For individuals, now is the time to pinpoint the skills the future professional will need to thrive in the AI age.
Check out this presentation to understand what ChatGPT is, how it will shape the future of work, and how you can prepare to take advantage.
The document provides career advice for getting into the tech field, including:
- Doing projects and internships in college to build a portfolio.
- Learning about different roles and technologies through industry research.
- Contributing to open source projects to build experience and network.
- Developing a personal brand through a website and social media presence.
- Networking through events, communities, and finding a mentor.
- Practicing interviews through mock interviews and whiteboarding coding questions.
Google's Just Not That Into You: Understanding Core Updates & Search IntentLily Ray
1. Core updates from Google periodically change how its algorithms assess and rank websites and pages. This can impact rankings through shifts in user intent, site quality issues being caught up to, world events influencing queries, and overhauls to search like the E-A-T framework.
2. There are many possible user intents beyond just transactional, navigational and informational. Identifying intent shifts is important during core updates. Sites may need to optimize for new intents through different content types and sections.
3. Responding effectively to core updates requires analyzing "before and after" data to understand changes, identifying new intents or page types, and ensuring content matches appropriate intents across video, images, knowledge graphs and more.
A brief introduction to DataScience with explaining of the concepts, algorithms, machine learning, supervised and unsupervised learning, clustering, statistics, data preprocessing, real-world applications etc.
It's part of a Data Science Corner Campaign where I will be discussing the fundamentals of DataScience, AIML, Statistics etc.
Time Management & Productivity - Best PracticesVit Horky
Here's my presentation on by proven best practices how to manage your work time effectively and how to improve your productivity. It includes practical tips and how to use tools such as Slack, Google Apps, Hubspot, Google Calendar, Gmail and others.
The six step guide to practical project managementMindGenius
The six step guide to practical project management
If you think managing projects is too difficult, think again.
We’ve stripped back project management processes to the
basics – to make it quicker and easier, without sacrificing
the vital ingredients for success.
“If you’re looking for some real-world guidance, then The Six Step Guide to Practical Project Management will help.”
Dr Andrew Makar, Tactical Project Management
Beginners Guide to TikTok for Search - Rachel Pearson - We are Tilt __ Bright...
MLB Arbitration in the Orioles-Nationals Cablecasting Lawsuit
1. MLB ARBITRATION IN THE
ORIOLES-NATIONALS
CABLECASTING LAWSUIT
IS THIS WHAT YOU SHOULD EXPECT FROM
MANDATORY ARBITRATION?
Charles H. Martin, JD, MBA
@Every1sGuide, #LawyerballLaw, Lawyerball.com
www.facebook.com/Every1sGuidetoElectronicContracts
2. The Montreal Expos Move to Washington, D.C.
• In 2005, the Montreal Expos National League baseball club moved to
Washington, D.C. to become the Washington Nationals. Pursuant to
the Major League Rules, the relocation was approved by a 29-1 vote of
the Major League Baseball (MLB) clubs. At that time, the Expos were
owned by all thirty MLB clubs, who had bought the club to avoid its
bankruptcy and its elimination as a franchise.
• The single vote against relocation was cast by the owners of the
American League Baltimore Orioles. This club played their games only
forty miles from D.C. About 20% of their fans came from the
Washington area. Peter Angelos, the principal owner of the Orioles,
complained that the Nationals’ proximity to his club would cause it
great financial harm. He threatened to sue Major League Baseball to
stop the move, even though (unlike some other clubs) he had no
territorial right to exclude the Expos/Nationals from operating in
Washington, D.C.
3. MLB and the Orioles Settle The Threatened Lawsuit
With the “Television Agreement”
• On March 28, 2005, Major League Baseball, the Montreal Expos, The
Baltimore Orioles and their cable sports channel (Mid-Atlantic Sports
Network or “MASN”) signed an agreement to eliminate Peter
Angelos’s threats to sue MLB over the Expos’ relocation to
Washington, D.C. The agreement (“Television Agreement”) gave the
Orioles owners the unique right to cablecast the games of the new
Washington Nationals, in addition to their own baseball games.
• The Television Agreement provided that the Nationals would own 10%,
and the Orioles 90%, of MASN initially. The Nationals’ ownership
would increase to 33% over 28 years, but the Orioles would always own
at least 67% of MASN.
• The Television Agreement provided for low cablecasting rights fees, to
be paid by MASN equally to each club for the first five years of the
contract, starting at $25 million each and increasing to $29 million
each.
4. The Television Agreement Resets the Cablecasting
Rights Fees Every Five Years
• After every five year period, the Television Agreement provides for a
reset of the cablecasting rights fees paid to each club to reflect current
television market values. If the clubs cannot agree on the new rights
fees amounts, they are to be set by a three-person arbitration panel
composed of representatives of three other MLB clubs that are
members of the MLB Revenue Sharing Definitions Committee
(“RSDC”).
• The RSDC normally determines the value of MLB club regional
television contracts for the purpose of revenue-sharing arrangements
that make smaller market clubs more competitive with larger market
clubs.
• In 2012, the RSDC (composed of Mets, Rays, and Pirates
representatives) determined the new 2012-2016 rights fees amounts.
Release of this determination was withheld until 2014, however, while
MLB tried to broker the sale of MASN to the COMCAST cable group.
5. RSDC Sets 2012-2016 “Fair Market Value” of the Rights Fees
Based on Projected Revenues and Comparable Profit Margins
• In the 2012 RSDC Arbitration, the Orioles argued that the rights fees for
each club should be $34 million for 2012. The Nationals argued that the
rights fees for each club should be $109 million for 2012.
• The RSDC determined the rights fees market value based on 1)
projected MASN revenues and costs over the 2012-2016 period, and 2)
the range of typical MLB regional sports channel profit margins. The
RSDC predicted that MASN’s 33% operating profit would decline over
the period as new, higher rights fees matched those in the comparable
television markets of the Atlanta Braves, Cleveland Indians, and Texas
Rangers.
• The RSDC noted that the Orioles had already received “significant
returns” from higher than normal margins that had increased the value
of the Orioles’ equity ownership of MASN. It rejected the Orioles’
argument that MASN should be assured a perpetual 20% operating
profit margin.
6. The RSDC “Splits the Difference” between the Orioles and
Nationals Proposed Rights Fees Amounts
• The RSDC concluded that MASN’s 2012-2016 operating profit margin
would be only 5%, because 1) its 2007 margin was only 6.2% when
sports television content was less valuable, and 2) the Orioles’ right to
receive from MASN fees equal to any fees received by the Nationals
would further reduce MASN’s profit margin.
• Applying this methodology, the RSDC awarded these rights fees to
each club: 2012 - $53,170,018, 2013 - $56,253,879, 2014 - $59,347,843, 2015
- $62,611,974, and 2016 - $66,744,384.
• In total the RSDC awarded each club $298,128,098 for 2012-2016 versus
the total of $170,000,000 for each club that the Orioles had offered, a
difference of $128,128,098 for each club.
• Although the Orioles would receive a higher amount of rights fees
under the RSDC award, it would be equal to the Nationals’ fees; while
the Orioles would own 80-85% of the equity value of MASN, which
would be higher if MASN paid lower rights fees to each club.
7. MLB Tries and Fails to Sell MASN to Comcast from 2012 to
2014. MLB Issues the Rights Fees Arbitration Award.
• The MLB/RSDC Arbitration Panel reached its conclusion in the MASN
rights fees dispute shortly after holding a hearing in April 2012, in which
the clubs and their witnesses participated. Rather than issue the award,
MLB Commissioner Allan H. (Bud) Selig tried to broker the sale of the
MASN sports channel to the cable giant, Comcast.
• MASN had an estimated market value at that time of more than $500
million. If Selig had been able to get Comcast to buy MASN, the Orioles
owner, Peter Angelos, would have been able to receive 83-85% of the
market value of MASN immediately. MLB and the Nationals would have
been able to avoid the costly and risky litigation that developed after the
sale fell through.
• The regional cablecast rights fees received by MLB teams increased
substantially, however, during the period from 2005 to 2014, reducing the
appeal to Comcast of ownership of a cable sports channel televising MLB
games.
• MLB issued the 2012 arbitration award on June 30, 2014.
8. The Orioles Petition a New York State Trial Court To
Vacate the MLB/RSDC Arbitration Award
• On July 2, 2014, the Orioles initiated an action in the New York State
Supreme Court, County of New York, seeking to vacate the RSDC
arbitration award. The Nationals filed a Petition to Confirm the award
on July 24, having failed to get the MLB Commissioner to confirm it.
• The Orioles asked that, if the award were vacated, the parties should be
ordered to redo the arbitration before an entity other than MLB. They
made four specific arguments in their filings with, and hearings before,
Justice Lawrence Marks:
• 1) the award was obtained through corruption, fraud or undue means,
• 2) the award exceeded the arbitrator’s scope of authority, or was made
with manifest disregard of the law,
• 3) there was prejudicial misconduct by the arbitrators, and
• 4) there was “evident partiality” against MASN and the Orioles in the
arbitration, because
9. The New York Judge Vacates the MLB Arbitration Award
for “Evident Partiality” from a Law Firm’s Multiple Roles
• a) MLB lent the Nationals $25 million in 2013 as a partial advance payment
of their future rights fees award in order to help their cash flow, and
• b) the participation of the Proskauer Rose law firm (MLB Commissioner
Rob Manfred’s former employer) as counsel to MLB and the Nationals in
the arbitration, and to the three clubs on the arbitration panel in three
unrelated matters.
• Justice Marks rejected the first three arguments and the first “evident
partiality” argument as grounds to vacate the award. He agreed, however,
with the last argument that the arbitration involved “evident partiality”
against the Orioles, because the Orioles had objected at the beginning of
this “inside baseball” arbitration to the participation of the Proskauer
Rose firm in the arbitration in the multiple roles of
• - the simultaneous advisor to MLB i) in the arbitration, and ii) in unrelated
legal matters like the reorganization of the MLB Commissioner’s office.
10. Justice Marks Criticizes MLB for “Evident Partiality”
in Ignoring Orioles’ Objections to Law Firm
Multiple Roles
• - advisor in unrelated matters to each of the MLB clubs represented on
the arbitration panel; and
• - the legal advisor to both the Washington Nationals and the Baltimore
Orioles in the rights fees arbitration.
• The Proskauer Rose law firm responded to the Orioles’ objection by
withdrawing as the Orioles’ counsel in the arbitration. MLB refused,
however, to disqualify the firm from advising any other participants in
the arbitration, including the Nationals.
• Justice Marks decided that “What [MASN and the Orioles] did not
agree to…was a situation in which MASN’s arbitration opponent, the
Nationals, was represented in the arbitration by the same law firm that
was concurrently representing MLB and one or more of the arbitrators
and/or the arbitrators’ clubs in other matters....”
11. Justice Marks Criticizes MLB for “Evident Partiality”
in Ignoring Orioles’ Objections to Law Firm
Multiple Roles
• Justice Marks wrote that “…it might have been a simple decision...to
confirm the award if MLB, as administrator of the arbitration, had
taken MASN’s objections seriously, and actually done something about
it.”
• He offered examples of possibly satisfactory MLB actions, included
encouraging the Nationals to use other lawyers, screening Proskauer’s
arbitration lawyers from other firm lawyers who advised MLB or any
clubs during the arbitration, directing the arbitrator panel clubs to fully
disclose any potentially conflicting representations by Proskauer of
them, or updating the parties on MLB’s own continuing and increasing
use of Proskauer as an advisor.
• As the judge wrote “Yet MLB did nothing, except assure [MASN and
the Orioles] repeatedly that their concerns would be preserved and not
waived by their participation before the RSDC.”
12. Justice Marks Orders the MLB Arbitration Award Vacated.
The Orioles Appeal His Refusal to Disqualify MLB as an
Arbitration Forum
• Justice Marks concluded that “this complete inaction objectively
demonstrates an utter lack of concern for fairness of the proceeding
that is ‘so inconsistent with basic principles of justice’ that the award
must be vacated.”
• Despite winning their argument to vacate the 2014 arbitration award,
the Orioles in December, 2015 filed an appeal of the judge’s decision to
not disqualify MLB as an arbitration forum, because “no potential
RSDC member can be neutral and impartial: the RSDC as a forum is
conflicted and thoroughly compromised.”
• MLB responded that it had hired new lawyers from the firm Sullivan &
Cromwell to advise it for the next RSDC arbitration before a panel
composed of representatives of the Milwaukee Brewers, Seattle
Mariners, and Tampa Bay Rays. It set a date in August, 2016 for the
new MLB arbitration hearing.
13. Justice Marks Orders the New MLB Arbitration
Stayed Pending the Appeal of His Decision
• In addition, the Nationals confirmed that their new lawyers for the new
arbitration, the Quinn, Emanuel firm, neither represents MLB, nor any
members of the new MLB arbitration panel or their clubs.
• On July 11, 2016, Justice Marks denied the Nationals’ motion to compel
the Orioles to proceed with MLB arbitration, and granted the Orioles’
motion to stay arbitration pending their appeal, because “the parties
should not be arbitrating, again, without a final determination on the
arbitral process or forum.”
• It might be 2017 before a New York State appeals court determines
whether the trial judge’s vacating of the 2014 MLB arbitration award,
and refusal to disqualify MLB as a future arbitration forum, was
correct. Depending on that decision, it might be longer before another
arbitration panel decides the rights fees amounts for the 2012-2016
period.
14. What Are the Questions Raised and Lessons Learned From
the Orioles-Nationals Cablecasting Arbitration?
• Given that under the Federal Arbitration Act “judicial review of arbitration
awards is extremely limited”, how should the future of mandatory
arbitration be viewed by the parties in this case, and by employees,
consumers and businesses?
• Q: Should the Nationals try to settle this case to avoid receiving less money
in a new arbitration?
• A: No. Justice Marks denied all the Orioles’ arguments that the substance
of the MLB arbitration award was wrong. If the Nationals and MLB have
eliminated the lawyer conflicts that the judge said were unfair to the
Orioles, the same award methodology is likely to be applied to find the
“fair market value” of the rights fees, with the same result. It will also be a
precedent for the 2017-2021 rights fees determinations that are about to
begin. Their only reason to settle might be a proposal from the Orioles that
approaches the amount of the previous MLB arbitration award, discounted
by the likely costs of future litigation delays in having a court order the
award to be paid in that amount.
15. What Are the Questions Raised and Lessons Learned From
the Orioles-Nationals Cablecasting Arbitration?
• Q: Should the Orioles try to settle this case to avoid receiving less money in
a new arbitration?
• A: No. The Orioles are likely to be directed to pay the same amount in
rights fees in the next arbitration that they were ordered to pay in 2014.
Every day that they delay that order, and its enforcement, by litigating and
appealing in courts, is a day that the rights fees money stays in their
pockets, and finances their team. The Orioles should not count on goodwill
from the Nationals for a possible agreement to set future rights fees by a
formula that preserves the current disproportionate value of MASN equity
compared to other baseball cable sports channels.
• The Orioles are unlikely to be required to pay interest on the rights fees to
account for the time period since the fees were scheduled to be paid
according to the Television Contract. “Pre-judgment interest” is usually
awarded only on money owed in an undisputed amount. The “fair market
value” of the cablecasting rights fees is clearly a disputed amount.
16. What Are the Questions Raised and Lessons Learned From
the Orioles-Nationals Cablecasting Arbitration?
• Q: How should MLB negotiate franchise relocations, and conduct
arbitrations of owner disputes to avoid these types of court delays and
reversals?
• A: MLB conducts its business affairs with an eye to avoiding criticism in
Congress of its unique antitrust exemption. The Supreme Court in 1922
granted the exemption on grounds that later Justices have found to be
erroneous, but have refused to correct, leaving it to Congress to redress.
• The Orioles-Nationals case has exposed the peril of the MLB
Commissioner’s office acting in multiple roles in “inside baseball” club
disputes. The NFL Commissioner has been criticized for acting as
investigator, prosecutor and judge in player disciplinary proceedings. The
MLB Commissioner (or its main law firm) acted as arbitration
administrator, MLB legal advisor, and as advisor both to the RSDC
arbitrator clubs, and to the Nationals as an arbitration party. These are too
many hats for one Commissioner (or his lawyers) to wear, and leads to
inevitable appearances of conflicting interests.
17. What Are the Questions Raised and Lessons Learned From
the Orioles-Nationals Cablecasting Arbitration?
• The MLB Commissioner should consider appointing non-MLB
arbitrators for future inter-club business disputes. It should avoid
having any of the dispute parties, or the administrators, represented by
a law firm that also advises MLB.
• Questions for Employees, Consumers and Small Businesses Required
to Use Mandatory Arbitration for Their Contract Disputes –
• Q: If an employee, consumer or small business is required to use
mandatory arbitration for contract disputes, can they get an arbitration
award vacated like the Orioles did, because the arbitration was unfair in
substance or in its procedures?
18. What Are the Questions Raised and Lessons Learned From
the Orioles-Nationals Cablecasting Arbitration?
• A: Arbitration may have these advantages for both parties over
litigation: 1) it is faster and simpler, 2) it is usually less expensive, 3)
arbitrators usually know more about the specific arbitration subject
than judges, and 4) the party requiring arbitration might pay for the
legal costs of the other party up to a certain amount.
• Employees, consumers and small businesses often object to mandatory
arbitration, however, because –
• 1) the results of an arbitration are usually confidential, and cannot be a
precedent for a future arbitration or litigation, 2) the arbitration is
usually conducted where the party requiring it is located, 3) there is no
right to a jury trial, 4) there is no class action right, and 5) cheap, quick
and convenient small claims court litigation is prohibited by most
arbitration clauses.
19. What Are the Questions Raised and Lessons Learned From
the Orioles-Nationals Cablecasting Arbitration?
• The most successful “fairness” argument available against mandatory
contract terms, including arbitration, has been “unconscionability”. In
AT&T Mobility LLC v. Concepcion, however, the U.S. Supreme Court
in 2011 ruled that a mandatory arbitration clause that prohibited a class
action for cell phone consumers claiming false advertising and fraud
could not be invalidated as unconscionable.
• Other contract defenses remain available against mandatory arbitration
clauses, such as lack of notice of the clause (especially in digital
contracts), or an unreasonably distant or expensive arbitration forum.
The burden of proof is on the party requiring arbitration to show there
was adequate notice of the requirement.
20. What Are the Questions Raised and Lessons Learned From
the Orioles-Nationals Cablecasting Arbitration?
• Contracts require mutual obligations, so when a retailer required its
customers to arbitrate their disputes, but allowed itself an “escape hatch”
from arbitration, this clause was invalidated.
• When a mandatory arbitration clause denies a statutory right, such as
under labor or consumer protection laws, a judge will often invalidate the
clause.
• Consumer and employee advocates often argue that arbitrators (or their
lawyers) are biased against the parties who have mandatory arbitration
requirements imposed against them. They argue that this bias is often
unconscious, but real, because the party requiring arbitration employs the
same arbitrators or lawyers, who naturally view them favorably as a source
of repeat employment. This was the argument that won for the Orioles in
their appeal of the cable rights fees litigation. It has sometimes also
succeeded for consumers, although the effort to prove bias by the arbitrator
or a related law firm is rarely worth the effort for parties without deep
pockets.
21. What Are the Questions Raised and Lessons Learned From
the Orioles-Nationals Cablecasting Arbitration?
• In 2010, Congress passed the Dodd-Frank Act, which requires the new
Consumer Financial Protection Bureau (CFPB) to issue rules to restrict
mandatory arbitration clauses in consumer financial contracts, if it
finds it to be in the public interest for the protection of consumers. In
2015, the CFPB issued preliminary rules to prohibit mandatory
arbitration clauses in consumer financial contracts that prohibit
consumers from pursuing class action remedies.
• Even if the CFPB rules against class action prohibitions are
implemented, however, they will only apply to consumer financial
contract clauses. They will not apply to mandatory arbitration clauses
in contracts for non-financial consumer transactions, or in employee or
business contracts.
22. For More and Continuing Information
See www.charleshmartin.com
See http://www.amazon.com/-/
e/B00E8NSUCU
See www.lawyerball.com
Editor's Notes
Copyright Charles H. Martin 2016. The legal information described here is not legal advice, for which you should consult an attorney.
Photo of Olympic Stadium in Montreal By Tolivero - Own work, CC BY-SA 3.0, https://commons.wikimedia.org/w/index.php?curid=850513
All business and legal documents described in this presentation are available on the Resources Page at www.lawyerball.com. Photo of Sports Museum at Orioles Park at Camden Yards, Baltimore, Maryland.
Photo of Skydome Stadium, Toronto, Ontario, Canada.
See “Major League Baseball Franchise Valuations”, estimating the value of MASN at $492 million, October 23, 2013, Bloomberg Visual Data at http://www.bloomberg.com/infographics/2013-10-23/mlb-team-values.html. Photo of broadcasting tower in Stuttgart By Creator-bz at English Wikipedia, CC BY-SA 3.0, https://commons.wikimedia.org/w/index.php?curid=47694513.
Photo of New York County State Supreme Court, Foley Square, New York City.
Photo of New York County State Supreme Court, Foley Square, New York City.
Lithograph cartoon of contestants in 1860 Presidential Election as baseball players – Abraham Lincoln, Stephen A. Douglas, John C. Breckinridge, and John Bell.
Photo of Washington Olympics Base Ball Team.
Photo of bunt By Ed Schipul (eschipul) from Houston, TX, US - Flickr, CC BY-SA 2.0, https://commons.wikimedia.org/w/index.php?curid=2315236
See Wien & Malkin LLP v. Helmsley-Spear, Inc., 6 N.Y.3d 471, 479 (2006) cited by Justice Marks in his decision to vacate the MLB arbitration award as the standard for judicial review. Photo of attempted pick-off throw By Brett A. Dawson - http://www.news.navy.mil/view_single.asp?id=12356, Public Domain, https://commons.wikimedia.org/w/index.php?curid=1290229.
Photo of George Wright, Providence Grays shortstop.
Photo of Angels Stadium By HerSilverHammer - Own work, Public Domain, https://commons.wikimedia.org/w/index.php?curid=6506985
Photo of Babe Ruth, 1921.
Photo of Jackie Robinson in Look Magazine 1945.
AT&T Mobility LLC v. Concepcion, No.09-893 (2011) available at http://www.supremecourt.gov/opinions/10pdf/09-893.pdf Photo of Roy Halladay By SD Dirk on Flickr - Originally posted to Flickr as "D7K_4969", CC BY 2.0, https://commons.wikimedia.org/w/index.php?curid=15061997
See In re Zappos.com Inc., Customer Data Security Breach Litigation, (Multidistrict Litigation), 2012 U.S. Dist. LEXIS 141803 (D. Nevada, 2012) for the “escape hatch” defense. See Van Tassell v. United Marketing Group, LLC, No. 10 C 2675, 795 F. Supp. 2d 770, 2011 U.S. Dist. LEXIS 72088 (N. Dist. Ill, Eastern Div., 2011), and Shnabel v. Trilegiant Corporation, Affinion, Inc. No. 11-1311-CV, 2012 U.S. App. LEXIS 18875 (2d Fed. Cir. Ct. of Appeals, 2012) on consumer protection against “data passing” between online retailers of consumer data without notice as the basis for invalidating arbitration clause. California Senate Bill No. 340 and the federal “Restore Online Shppers’ Confidence Act (ROSCA) require specific notices for data passing. See “Scammed – How Arbitration Can Lead to the Courtroom It’s Supposed to Avoid” at http://www.hkemlaw.com/scammed.php; “Arbitration Everywhere, Stacking the Deck of Justice” by Jessica Silver-Greenberg and Robert Gebeloff, NY. Times, October 31, 2015 at http://nyti.ms/2a6xedE; “Removing the Ability to Sue” by Robert Gebeloff and Karl Russell, N.Y. Times, October 31, 2015 at http://nyti.ms/2ar7w2w, and “In Arbitration, a “Privatization of the Justice System” “, by Jessica Silver-Greenberg and Michael Corkery, N.Y. Times, November 1, 2015 at http://nyti.ms/29QQSvt. Photo of David Ortiz By SecondPrint Productions on Flickr - From Flickr; description page is (was) here, CC BY 2.0, https://commons.wikimedia.org/w/index.php?curid=3083155
Photo of President John F. Kennedy throwing out “first pitch” of 1961 baseball season at Griffith Stadium, Washington, D.C.