Eyes Were Watching God Essay Topics

Eyes Were Watching God Essay TopicsThe eyes were watching God paper points that are not generally instructed. This theme is by all accounts oftentimes ignored as certain instructors want to concentrate on book of scriptures stories that bring the educator and understudies nearer together. Book of scriptures stories are ground-breaking and give a phenomenal chance to utilize the assets of the holy book for an assortment of educating circumstances. At the point when an understudy will confront a troublesome circumstance, their eyes will watch God since they need to recognize what it is that he needs them to do.There are many paper subjects that include understudies who are in this circumstance, however they are as a rule outwardly glancing in and probably won't understand it. We should take a gander at several models. Suppose an understudy is considering financial matters and their evaluations are slipping. A parent asks them what they have done to expand their evaluations. Understudie s will normally need to give their best shot.The second case of the eyes were watching God article points is the point at which an understudy has a couple of issues in math class. The parent requests that the understudy help with the task. During the undertaking that was required to finish the task, an understudy may have disregarded some significant subtleties that were expected to finish the venture. Understudies will look to God to determine their issues and they will look for his assistance so they can be glad in the future.Most understudies have huge friend networks and family who they spend time with. Some will meet each other at chapel yet can't spend the whole day there. Now and then they will visit with a couple of their companions and meet others at different occasions. They will look to God to assist them with overcoming any harsh patches in their lives. By helping each other, they will feel extraordinary joy.A understudy may return home one day and be excessively worn ou t for school. There is no more schoolwork for them to do. They don't have any assignments left to wrap up. It may appear as though the main decisions accessible to them are to rest or begin taking as much time as is needed to complete a portion of their homework. They may consider having a ton of fun exercises with their companions or even attempt to play a video game.In different cases an understudy may wake up in the center of the night and think, 'I wonder what God is doing today.' They probably won't recollect when the supplication came. They may consider getting some information about it. When they return to rest, they will consider this episode and their eyes will watch God.The eyes were watching God exposition subjects are not restricted to any theme. Different elements that add to understudies not feeling the delight they need are their colleagues. Different understudies can contrarily influence an understudy and can realize sentiments of disgrace, stress, or fear.Finally, t he eyes were watching God article points might be troublesome from numerous points of view. The youngster may feel frightened and alone. It may adopt boldness to strategy the subject. It may feel ungainly to get some information about it. Be that as it may, an understudy will discover a feeling of harmony once they open up to a companion.

Writing Essays and Essay Topics

Composing Essays and Essay TopicsFor most English understudies, the English end of the year test is frequently an upsetting and troublesome experience. In spite of the fact that you might be sure about your capacity to compose an intelligible story exposition point, this can frequently prompt an absence of trust in your own composing abilities, and it might likewise leave you with too little certainty to compose a reasonable account article subject for your essay.One thing that I generally find upsetting is when understudies have an underlying disappointment on a paper that could have been handily maintained a strategic distance from. They start to scrutinize their capacity to compose a sound account, and they start to search for alternate routes and approaches to get around a portion of the troubles they are experiencing with composing an exposition. However, another motivation behind why it's critical to consider what you will compose before you plunk down to compose, and to ensure that your contemplations and thoughts are flowing.This is especially obvious on the off chance that you have not composed or perused a solitary bit of composing for any period of time. Indeed, even the most experienced authors and editors can commit errors every once in a while, however in case you're continually searching for answers on the web, without getting the opportunity to understand anything, you're probably going to pass up on important learning chances. Rather than adopting this strategy, it would be obviously better to ensure that you start off by first composing a careful draft of your account paper topic.The challenge here is that a great many people, in their flurry to traverse the last tests of the year of secondary school, will take up one theme and afterward continue to answer an entangled and complex topic by concentrating on one subject and that's it. This regularly brings about them getting familiar with one zone of their coursework, than they were really educa ted during the course itself. Hence, you ought to compose an archive that has a blueprint, to assist you with concentrating on one specific point. At that point you can keep on adding to it as you go along.Of course, you ought to never accept that any theme iseasy or complex topic, since all subjects are not composed the equivalent. It might be smarter to move toward a perplexing topic by expounding on one point top to bottom, instead of a progression of discrete topics.Whatever sort of paper themes you decide to compose, recall that it is extremely critical to complete the errand as quickly as time permits. All things considered, on the off chance that you invest more energy contemplating and planning for a potential article theme, at that point you're bound to have the option to compose an extraordinary bit of work.Of course, it might likewise be useful to audit some investigation guides before your composing meeting. On the off chance that you feel uncertain about the language yo u will write in, or about a particular point in the theme, at that point it's essential to invest some energy contemplating and pondering it before you start composing. Contemplating will give you data, and practice will offer you better procedures and better responses to basic inquiries that you may encounter.There are a wide range of sorts of article themes to browse, and every one requires an alternate methodology. Keep in mind, on the off chance that you are another author, or in the event that you have not composed much before, it is essential in the first place a nitty gritty draft. Thusly, you will expand your composing aptitudes and your certainty, and you will likewise turn into an all the more balanced author.

Finding Essay Sample For English Provincial Exams

Discovering Essay Sample For English Provincial ExamsYou need to contemplate English 10 commonplace test article tests, however it very well may be overwhelming for certain individuals. Most of understudies will never at any point verge on breezing through this assessment. In spite of the fact that the tests fluctuate a little from territory to area, most areas have comparable tests.A parcel of the fundamentals of composing are comparable over all regions. You should make an excellent contention or clarification about an issue before you get to reality part of the test. Understudies should utilize a few degrees of contention to cause the peruser to feel like they are a piece of the experience. When they feel associated with the experience, the almost certain they are to ingest your information.There are numerous other paper tests for English common tests and these will be an incredible assistance when you take your test. One of the most significant hints is that try not to be hesitan t to incorporate heaps of supporting models. Supporting models make your article more grounded and ought to likewise be utilized in some other essay.If you don't have the foggiest idea how to compose a paper, at that point there are many exposition tests out there for you to take a gander at. These can be in any subject and you don't have to have some expertise in a specific field. On the off chance that you decide to expound on whatever else, at that point you can utilize an exposition test for that too.Just ensure that whatever you decide to compose is something that has not been done previously. When you locate the ideal article for your paper, you should set aside some effort to truly consider it and ensure as well as can be expected compose. It will be critical for you to do your absolute best and ensure your peruser has a similar inclination as you would.Support for your data ought to be given in the models also. In the event that you are searching for help, at that point a pa per test will be an incredible method to do this. At the point when you are searching for a specific end to your paper, at that point you can discover a lot of guides to work with.One of the primary preferences of picking exposition tests is that they are truly intelligible. Composing an exposition is extraordinarily troublesome and regardless of what subject you are expounding on, your composing aptitudes will endure enormously. The key is to chip away at your insight and get it down on paper so you don't get overwhelmed.There are numerous approaches to figure out how to compose papers. In the event that you feel that you do not have the capacity to communicate plainly, at that point attempt to rehearse and build up your abilities. That will be of colossal advantage in your examinations.

Counter Argument Essay Topics

Counter Argument Essay TopicsFor the individuals who need to exceed expectations in the paper composing field, think about going past the regular theme. The accomplishment of an article is in huge part dependent on the nature of the author. What's more, in truth, you will get too much of applause for considering new ideas with regards to paper topics.Consider this rather than the opposite contention that numerous scholars make with regards to composing expositions. They demand that there are just two decisions for paper themes and that the correct decisions are subjects, for example, religion, governmental issues, science, sports and music.A great, convincing article can be expounded regarding any matter however there is nobody set of points that characterize exposition subjects. To the individuals who have an unbending perspective about what themes are ideal, it may appear as though there is a lot of settled upon decides that one must follow so as to compose a paper that satisfies t he quality desires for the writer.There is no complete guideline that characterizes article subjects however one thing is sure. Paper points are not highly contrasting subjects like religion, governmental issues or sex. While a few themes may sound comparable, others may be very different.One counter contention against going past the ordinary subject classification is that there is no particular reason to limit oneself to a particular point classification. At the end of the day, there is no motivation behind why a paper author can't compose an exposition about anything that has to do with the understudy's life. In fact, there are a few themes that have no genuine importance at all.Yet there are others that can be extremely illuminating, particularly if the exposition is elegantly composed. Nonetheless, we should recollect that even the best paper scholars will never compose an article that fits the quality measures of different understudies. This is the reason there are no severe gu idelines about exposition topics.In actuality, it is improbable that anybody will concoct a lot of article subjects that is all around relevant. On the off chance that there were such a standard, at that point maybe everybody would turn out incredible paper authors. Nonetheless, since we don't live in such a world, it is hard to pass judgment on the nature of any individual exposition until it is complete.Whatever the case, make certain to never compose a paper that doesn't fit the subject class that you are generally OK with. At that point you can be certain that the nature of your work will be incredibly upgraded.

Colonists on Their Way to the New World

Pioneers on Their Way to the New WorldColonial American history is one of the most fascinating subjects to examine. Prior to the First World War, there were various understudies inspired by this field, and it was likewise intriguing to the instructors. While understudies used to retain a lot of realities in regards to provincial history, just as numerous optional sources, the utilization of assets has enormously expanded over the years.Nowadays, there are an extraordinary number of assets that can be utilized in your pioneer American history paper. The numerous assets are mostly being used by understudies and instructors, yet they are likewise utilized by any individual who has a decent information on the period and chronicled references. With the headways in the web, this data is promptly accessible to any individual who needs it.Many understudies utilize old assets in their ventures, and they think that its helpful and adaptable. Old assets are generally not hard to track down in l ight of the fact that the printed sources have been distributed for such a long time. Be that as it may, you should be cautious about which periodicals you pick. Numerous books and periodicals just spotlight on the American Civil War, and different less notable points, similar to the ongoing clashes in Vietnam or in the Middle East.Although, utilizing on the web assets may make your undertaking more troublesome than the printed ones, and it may end up being additionally testing. Moreover, you ought to likewise know that these sources are normally obsolete archives are once in a while elegantly composed. On the off chance that you decide to utilize these sources, make certain to be wary on the grounds that a large portion of them are not reliable.In request to compose a decent pilgrim American history paper points, you should realize the different periods secured by the United States. You should consider the various presidents and pioneers, just as the occasions that were occurring d uring these periods. To completely comprehend the issues, you should be educated about what the United States had encountered previously, during and after the occasions. The entire thought of pilgrim history is to return to the occasions that occurred before and to utilize them as the establishment for an account of the future.The primary concern you have to recall when composing a pioneer American history article subjects is to concentrate on the reason and the message of the works. You should recollect that each snippet of data must pass on an alternate message. In the event that you use realities without speculation, it will appear as though you are simply passing on data and that is the reason individuals are regularly befuddled by your work. Notwithstanding, when you use realities to enlighten the peruser regarding the difficult that prompted a war, it will become more clear and it will make sense.It is additionally essential to remember a ton of data for your article, particul arly on the off chance that you are writing in English. You should comprehend that most of your crowd will just understand English, so it is ideal to be precise and clear in your words. Also, you should be brief with the goal that it won't take unreasonably long for your perusers to wrap up your essay.By cautiously contemplating the thoughts, occasions, and figures that you will remember for your pilgrim American history paper points, you will have the option to effortlessly compose a decent bit of work. By doing it all the time, you will have the option to concoct a one of a kind record that will advise others regarding the topic. Ensure that you will utilize all the assets available to you, and consistently recall that the primary reason for composing is to make others mindful of the subject that you are expounding on.

School Essay Samples - Practices on Personal Essays

School Essay Samples - Practices on Personal EssaysSchool exposition tests are an extraordinary method to discover tests of composing in view of a particular reason. Instructors dislike to consider it, yet they do have a variety of ways they can improve the aptitudes of their understudies that may be found on an example rather than on the genuine essay.The sort of educator who is composing this specific paper for you might not have a particular style as a top priority, yet they will most likely need to utilize a specific style for your article also. In the event that the exposition isn't too intriguing, the educator might not have any desire to have your article recorded as one of the models, and that is the place tests can come in.The next time you compose a school paper, consider joining tests into the creative cycle so you can make it progressively unique and get an acknowledgment. For instance, an understudy may utilize a specific expression or sentence structure on a test and yo u may discover an example exposition on it online.Using tests as your school paper is a brilliant instrument for instructing also. On the off chance that you are experiencing difficulty composing a paper, compose two or three passages utilizing the examples and perceive how they may be helpful in the general composition.It may appear to be hard to compose a decent exposition utilizing tests of article composing rather than a decent article without them, yet once you've composed a few you'll see that you can compose an incredible exposition similarly as adequately. On the off chance that you've composed a couple, at that point you'll realize how to coordinate and supplement a portion of the examples into your own essay.Sometimes when you're searching for a school article, you may need to utilize a specific blend of test and your own composition to make sense of how to improve it. In the event that you aren't acquainted with a portion of the arranging and different things that make th e article engaging, there are destinations online that permit you to rehearse before composing a full one.They have tests of everything from short sections to passages over a time of a year. It's a decent method to perceive how you can actualize your preferred things into the composing process.Writing is an innovative and exceptionally singular thing. On the off chance that you are attempting to get acknowledgment or improve your abilities, paper tests can be significant in giving you how you can make changes that are novel to you to suit the style of the article for which you are composing.

Why Should You Write a Journal Article Review

For what reason Should You Write a Journal Article Review?There are various points of interest to composing a diary article survey. You can receive a great deal in return, and it can help you as you continued looking for a new position. Diary article audit composing is something that individuals do when they have a restricted measure of time to finish their work for the day.In the present world, everyone should be on the Internet consistently. Occupations are on the Internet and on the off chance that you can't search for them there, you may need to begin composing an article survey with the goal that you can present your work. This is a typical activity today, yet before you bounce into this, ensure you are OK with your work.One of the most significant things to consider is the place you will be presenting your work. While you may have a few thoughts regarding how you can do this, don't simply expect that the organization you are working for will acknowledge these sorts of articles. Recollect that not all organizations are going to need to employ an author.If you don't know about how to approach searching for occupations in the online activity showcase, reach the organization first. There are a lot of advantages to doing this, however it is perhaps the most ideal approaches to begin. Since you are beginning gradually, you are going to need to perceive what sort of openings for work are accessible to you before you begin taking on an excess of work that you can't handle.When you have set up a decent connection with an organization, you would then be able to utilize this data to stretch out beyond different authors and make yourself progressively alluring to the organization that you are working for. When you start to feel certain about your composing abilities, you will need to start exploring the sort of work that you will have the option to do and whether you will have the option to do this without charging them an expense. On the off chance that this is some thing that you can do, it will be a major lift to your odds of getting hired.Once you start utilizing your composing abilities to help the individuals who are attempting to get a new line of work in Canada, you will be better prepared to make yourself appealing to organizations later on. This implies you should keep on investigating better places that will recruit scholars who are happy to work for nothing in Canada. This can be an incredible method to build your odds of getting recruited over different essayists who are charging an expense for their work.Once you have finished your article survey, ensure that you get your work edit by someone who has involvement with this field. At the point when you are going after a position, you need to ensure that you don't have any genuine mix-ups in your work. An error is something that you will need to stay away from no matter what and having botches in your work can be truly humiliating to have on the Internet.With the entirety of the accen tuation that you will put on your composing capacities, ensure that you utilize these aptitudes for your potential benefit. At the point when you are going after a position, you need to ensure that you can enlighten businesses regarding the sort of work that you can furnish them with. For whatever length of time that you realize that you can convey a quality item, you will have the option to continue improving at this as you come.

Anti-competitive activity in the single market - Free Essay Example

Title: Discuss the effectiveness of Articles 81 and 82 of the EC Treaty in preventing distortions to the operation of the single market ANSWER In The Wealth of Nations [1], published in 1776, Adam Smith reasoned that countries should strive towards the economic goal of a perfectly free market. He argued that a market undistorted by impediments and barriers to the free play of trade would allow the most efficient and successful producers to perform at an optimum capacity and produce substantial economic benefits for all participants in the market, and he stressed that such benefits could not be obtained in markets where competitive conditions had not been optimised. The European Union adopted this theory from its inception in the 1950s in the form of the European Economic Community. The competition law provisions of the Treaty of Rome[2] have always been fundamental to the organisationà ¢Ã¢â€š ¬Ã¢â€ž ¢s philosophy and drive towards the integration and refinement of the national economies of its member states and thus of the combined economy of the Single Market, which grew out of the Common Market when the EU itself was established by the Treaty on European Union (Maastricht Treaty) in 1992.[3] The main competition law rules, which are now to be found in Articles 81 and 82 EC[4] are directed at controlling the behaviour of private firms. These articles will be explained and discussed in turn. Article 81 EC: à ¢Ã¢â€š ¬Ã‹Å"The Community Cartel Busterà ¢Ã¢â€š ¬Ã¢â€ž ¢ It is obvious that a market is likely to be distorted if undertakings which under normal, healthy competitive conditions should be operating in competition with one another choose instead to cooperate with each other in order to manipulate the market in their favour. This form of cooperati on inevitably causes laxity and weaknesses in the flux of trade which negatively affects the market as a whole serves to impact on the interests of consumers served by the market. Consequently the European Union maintains a comprehensive prohibition on such cooperative activity in the form of Article 81. This Article is assiduously enforced and swingeing penalties can and are imposed on companies found to infringe it. The text of Article 81(1) states as follows: à ¢Ã¢â€š ¬Ã…“The following shall be prohibited as incompatible with the common market: all agreements between undertakings, decisions by associations of undertakings and concerted practices which may affect trade between Member States and which have as their object or effect the prevention, restriction or distortion of competition within the common market, and in particular those which: a) directly or indirectly fix purchase or selling prices or any other trading conditions; b) limit or control production, mar kets, technical development, or investment; c) share markets or sources of supply; d) apply dissimilar conditions to equivalent transactions with other trading parties, thereby placing them at a competitive disadvantage; e) make the conclusion of contracts subject to acceptance by the other parties of supplementary obligations which, by their nature or according to commercial usage, have no connection with the subject of such contracts.à ¢Ã¢â€š ¬Ã‚  Following from this wide-ranging and far-reaching clause, Article 81(2) provides that any agreements or decisions covered are automatically void. Of course, a provision is only as effective as its practical interpretation and application.. Consonant with the overarching objectives of the European Union of market integration and efficiency, the European Court of Justice has consistently shown itself prepared to interpret the essential concepts and terms of Article 81 with full contextual and purposive force. This interpre tative policy has been adopted so as to lend the provision the greatest possible scope and utility in its role as a guardian of market competitiveness. The term à ¢Ã¢â€š ¬Ã…“undertakingà ¢Ã¢â€š ¬Ã‚  is for example, central to the application of the provision. It is left undefined in the Treaty but the European Court has chosen to interpret the word in the widest conceivable sense to embrace à ¢Ã¢â€š ¬Ã…“any legal or natural person engaged in some form of commercial or economic activityà ¢Ã¢â€š ¬Ã‚ : Commercial Solvents Corp v Commission.[5] Many different forms of entity have been deemed to constitute à ¢Ã¢â€š ¬Ã‹Å"undertakingsà ¢Ã¢â€š ¬Ã¢â€ž ¢ for the purposes of the provision, hence allowing its application. These include public undertakings where they are found to participate in commercial activity as in the case Bodson v Pompes Funebres des Regions Liberees[6]. Partnerships were also found covered by the term in Commission Decision (73/323) Re William Prym-Werk e[7]. Interestingly, economically active individuals including for example an opera singer in Re Unitel[8] and an inventor in AOIP/Beyrard[9] have also been ruled to qualify as undertakings. Moreover, in circumstances where such act in a commercial or quasi-commercial endeavour even non-profit making organisations and charitable organisations can be held to constitute undertakings: see Commission Decision GVL.[10] The scope and power of Article 81 can be underlined by the fact that due to the European Court of Justiceà ¢Ã¢â€š ¬Ã¢â€ž ¢s application of the principle of extraterritoriality, even companies based exclusively outside the European Union and its Single Market can be brought to book under the competition provision if their activity falls within Article 81 and it has an anti-competitive impact on the flux of trade within the Community. The Ahlstrom (Wood Pulp)[11] case involved companies based in Scandinavia (which at the time of the litigation was still outside the EU) and North America that had conspired to manipulate prices for wood pulp which had artificially influenced the EU market. The Commission initiated Article 81 action against the companies and the European Court found against them, grounding its jurisdiction on the location of the effect of the behaviour of the companies and not on the location of the companies themselves. The Article 81 provision that agreements must be between undertakings is also very generously interpreted and applied so as to give full expansive force to the prohibition. It is submitted that the only situation in which the Court of Justice will typically refrain from acting against companies in a cooperative relationship is where those companies are in a parent-subsidiary situation. The reason for this is that such companies to all intents and purposes combine to comprise a single economic unit and therefore no competitive relationship would usually exist to be compromised in the first place. An example can be found in Centrafarm BV v Sterling Drug Inc[12]. In similar fashion, the effectiveness of Article 81 has been ensured by the Court of Justice by its definition of the central concept of à ¢Ã¢â€š ¬Ã…“agreementà ¢Ã¢â€š ¬Ã‚  as between undertakings. In the case of ACF Chemiefarma NV v EC Commission[13], for example, the Court expressly stated that even a so-called à ¢Ã¢â€š ¬Ã‹Å"gentlemanà ¢Ã¢â€š ¬Ã¢â€ž ¢s understandingà ¢Ã¢â€š ¬Ã¢â€ž ¢ between competitive companies would justify prohibitive sanction if it was found to amount to: à ¢Ã¢â€š ¬Ã…“the faithful expression of the joint intention of the parties to the agreement with regard to their conduct in the Common Market.à ¢Ã¢â€š ¬Ã‚  As for the concept of agreement itself, the utility and efficacy of the prohibition is also maintained by the fact that the European Court does not concern itself with the distinction between vertical and horizontal agreements in its application of Article 81. Vertical agreements can be defined as those between undertakings at different levels of the market. Such an agreement might be made between a manufacturer and a wholesaler or retailer, and a tying or tied agreement is one example. On the other hand, a horizontal agreement is deemed to be those which are struck between undertakings operating at the same level of industry. Horizontal agreements therefore include those made between two manufacturers or two wholesalers in a market, and such arrangements might amount to, for example, price fixing. The point is that the Court is unconcerned with the differences between the two classes of agreement: both forms of cooperation are potentially anti-competitive and both are accordingly prohibited as detrimental to the free play of commerce in the Single Market. Article 81 also includes the concept of the à ¢Ã¢â€š ¬Ã‹Å"concerted practiceà ¢Ã¢â€š ¬Ã¢â€ž ¢. This is clearly in place to allow the Court of Justice to rule against undertakings who attempt to avoid even th e loose interpretation of à ¢Ã¢â€š ¬Ã‹Å"agreementà ¢Ã¢â€š ¬Ã¢â€ž ¢ by operating deliberately secretive, subtle and casual arrangements between themselves.. However, the efficacy of Article 81 is such that even this much less tangible species of collusion than agreements or decisions is caught by the provision. Cooperatieve Vereniging Suiker Unie UA Ors v EC Commission[14] is a leading case on the issue, where the court stressed that a concerted practice would be found where 3 elements are found to co-exist: 1. Coordination in some form must replace the independent action between undertakings; 2. Coordination must be maintained by some form of contact, be it direct or indirect; 3. The object of the coordination must be to à ¢Ã¢â€š ¬Ã‹Å"remove in advance any uncertainty as to the future conduct of their competitorsà ¢Ã¢â€š ¬Ã¢â€ž ¢. All of these concepts are very generously applied with the aim of promoting the effectiveness and reach of Article 81. Article 82 EC Article 82 operates in partnership with Article 81 in regulating the Single Market. As stated, Article 81 endeavours to promote effective competition in the Union marketplace by prohibiting multilateral coordination, anti-competitive agreements and other economic collusions between undertakings. Article 82 in turn provides a control mechanism applicable to the unilateral conduct of single firms that enjoy what is referred to as a dominant position in the markets in which they operate.. It is argued that this simple division of responsibility and scope lends a cogent symbiosis to the relationship between these two central provisions of EU competition law. Article 82 states as follows: à ¢Ã¢â€š ¬Ã…“Any abuse by one or more undertakings of a dominant position within the common market or in a substantial part of it shall be prohibited as incompatible with the common market in so far as it may affect trade between Member States.. Such abuse may, in particular, consist in a) directly or indirectly imposing unfair purchase or selling prices or other unfair trading conditions; b) limiting production, markets or technical development to the prejudice of consumers; c) applying dissimilar conditions to equivalent transactions with other trading parties, thereby placing them at a competitive disadvantage; d) making the conclusion of contracts subject to acceptance by the other parties of supplementary obligations which, by their nature or according to commercial usage, have no connection with the subject of such contracts.à ¢Ã¢â€š ¬Ã‚  There is a manifest justification for Article 82. If an ordinary competitive firm attempts to do business on unreasonable trading terms or charge excessively high prices for its goods in a competitive market, the market will react in such a way as to ensure that the firm simply loses business and is forced to reconsider its policies or fail. However, if the undertaking has a dominant position (an economically powerful position defined by market share) within the relevant market it may have the freedom to act in such a way as to manipulate the market to its own ends without being subject to a market reaction that causes it to change its harmful business practices. Article 82 is designed to deal with just this situation, and it is submitted that it does so effectively when employed. As has been observed, the key terms and concepts of Article 81 EC are augmented by teleological and contextual interpretation. Precisely the same policy is adopted by the European Court of Justice in relation to the fundamental terms of Article 82, and for precisely the same reasons of market integrity, integration and efficiency. As in the case of all prohibitions, the effectiveness of Article 82 should be measured by its application. Market dominance is measured once the Court of Justice has defined the so-called relevant product market, which will be the specific product range and specific area within the Single Market in which it is claimed that dominance is enjoyed by the undertaking in question. As Michelin v EC Commission[15] illustrated, a product market will be found to include any product which is à ¢Ã¢â€š ¬Ã…“equivalent to or interchangeable for the specific product being marketed by the dominant companyà ¢Ã¢â€š ¬Ã‚ . This test is fundamental to the efficacy of Article 82 for compelling tactical reasons. The ultimate size and scope of the product market defined will typically be the determining factor in whether a company is considered dominant within it, with all the entailed consequences of that finding.. The interests of the Single Market consumer are considered paramount by the European Court in this regard. Product interchangeability with other products is judged from the vantage point of the consumer, taking into account the characteristics, price and uses of the product in question. Article 82 litigation is won and lost on this technical aspect of the pr ohibition. Allegedly dominant undertakings seek to contend that broad consumer preferences and uses should be adopted, for the reason that this inevitably increases the size of the relevant product market and therefore dilutes the undertakingà ¢Ã¢â€š ¬Ã¢â€ž ¢s dominance within it, making sanction under Article 92 less likely. On the other hand, the European Commission is usually at pains to argue that narrowly defined consumer preferences and uses should be adopted to reduce the size of the market for review and thus concentrate the undertakingà ¢Ã¢â€š ¬Ã¢â€ž ¢s market power within it. The issue of product interchangeability therefore necessitates an investigation into whether the scrutinised product can be replaced by other goods that satisfy the same consumer uses, expectations and demands. As Europemballage Corp and Continental Can v EC Commission[16] illustrates, if a product can be substituted then the product under review is deemed to constitute part of a larger product m arket which includes all those products found to be freely interchangeable with each other. If, because of its individual characteristics, a product cannot be easily replaced or substituted by other goods, it is deemed to form a relevant product market on its own. Given the fact that the European Court of Justice habitually prefers interpretations of EC competition law that reinforce and underpin the power of the Treaty, it can come as no surprise that the Commission normally wins the argument on market definition.. As stated, narrow market definition means it is easier to find dominance which in turn means that Article 82 can be successfully applied in more cases. The seminal case of United Brands v Commission[17] saw the Court hold that the banana formed a product market all of its own, independent to that of other fresh fruit, because it was ruled that bananas had unique qualities that distinguished them from other fruit. Taking the perspective of the consumer, the Court found that the size, shape and softness of bananas made them particularly attractive to certain ends of the market, including the elderly and the very young (which share a distinct lack of teeth necessary for the consumption of firmer kinds of fruit.) EU Competition Law Sanctions The end product of any prohibitionà ¢Ã¢â€š ¬Ã¢â€ž ¢s effectiveness can be found in the sanctions that it imposes. It is submitted that Article 81 and 82 can certainly be deemed effective based on the penalties levied for their breach. Moreover, the European Courtà ¢Ã¢â€š ¬Ã¢â€ž ¢s commitment to the efficacy and enforcement of these competition provisions is also manifest on perusal of the penalties it has endorsed. Fines of up to ten per cent of annual turnover can be imposed in cases of breach of Articles 81 or 82. In light of the fact that many of the undertakings concerned are global enterprises with vast turnovers the penalties involved can and are often draconian in size. In Tetra Pak Rausing SA (II) v Commission[18] in 1991 a single fine of 75 mECU was levied against the Scandinavian-based carton board company. 1994 saw a total fine of 248 mECU was imposed on key members of the Cement Producersà ¢Ã¢â€š ¬Ã¢â€ž ¢ Cartel[19] and the Austro-German car manufacturer Volkswagen suffered an individual penalty of 102 mECU for abuse of its dominant position in 1998.[20] Concluding Comments As has been discussed, Articles 81 and 82 of the Treaty of Rome operate effectively and in symbiotic partnership to combat anti-competitive activity in the Single Market. These provisions are lent power and efficacy by the generous and purposive interpretative stance of the Court of Justice and the proactive attitude of the European Commission.. The terms of the Articles themselves are, it is submitted, about as comprehensive and effective as they could be. The enduring weakness of the EU competition enforcement regime, if there is one, lies not in the text of the legal framework but in the lack of resources, in terms of time and manpower, devoted to the policing of the market. THE END GLOBAL DOCUMENT WORD COUNT : 2840 (answer only 2695) I have allowed a small overrun because I decided it was appropriate to reproduce the text of Article 81 and 82 in the answer in extenso and these words should not be counted. BIBLIOGRAPHY Adam Smith, The Wealth of Nations (1776) (Great Minds Series) (1991) Prometheus Books.. Steiner and Woods, Textbook on EC Law, (2003) Blackstone Press. Treaty establishing the European Economic Community: https://europa.eu.int/eur-lex/lex/en/treaties/dat/12002E/htm/C_2002325EN.003301.html Tillotson and Foster, Text, Cases and Materials on European Union Law, (2003) Cavendish Publishing Kent, P., Law of the European Union, (2001) Longman Recent Guidance on Fining Policy, Spink, P., [1999] European Competition Law Review, 101-108 Cases as footnoted 1 Footnotes [1] Adam Smith, The Wealth of Nations (1776) (Great Minds Series) (1991) Prometheus Books. [2] See the consolidated version of the Treaty establishing the European Economic Community: https://europa.eu.int/eur-lex/lex/en/treaties/dat/12002E/htm/C_2002325EN..003301.html [3] See for further comment and elaboration: Textbook on EC Law, Steiner and Woods, (2003) Blackstone. [4] Previously Article 85 and 86 EC (the Treaty of Rome was renumbered by the Amsterdam Treaty). [5] Cases 6 7/73 [1974] ECR 233. [6] Case 30/87 [1988] ECR 2479. [7] 1973 OJ L296/24. [8] [1978] 3 CMLR 306. [9] (1976). [10] (1983). [11] Cases 89 125-129/85 [1993] 1 CEC 466. [12] Case 15/74 [1974] ECR 1147. [13] Case 41/69 [1970] ECR 661. [14] Cases 40-48 114/73 [1975] ECR 1663. [15] 322/81 [1983] ECR 3461. [16] 6/72 [1973] ECR 215. [17] C27/76 [1978] ECR 207. [18] T-51/89 [1991] 4 CMLR 334. [19] Decision 94/815 [1995] 1 CEC 2092. [20] Recent Guidance on Finin g Policy, Spink, P., [1999] European Competition Law Review, 101-108.

Paper Editing For a Resume

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