title: Eduardo Arellano Félix

text: Arellano is believed to be one of the most sophisticated brothers and had taken control of the cartel. He was wanted by Mexican and United States authorities in connection with the smuggling of several tons of marijuana and cocaine from Mexico into the U.S. each year. He and his sister, Enedina Arellano Félix, became the leaders of the drug cartel after their brother Javier Arellano Félix was arrested by U.S. authorities in Baja California on August 16, 2006. His brother Ramón Arellano Félix, believed to be the most ruthless member, was eventually killed in a Mazatlán shootout with the Federal Police in February 2002. Another brother, Benjamín Arellano Félix, "the mastermind", was arrested in March 2002.


title: Eduardo Arellano Félix

text: On 1 June 2004, the United States Department of the Treasury sanctioned Arellano Félix under the Foreign Narcotics Kingpin Designation Act (sometimes referred to simply as the "Kingpin Act"), for his involvement in drug trafficking along with nine other international criminals and two entities. The act prohibited U.S. citizens and companies from doing any kind of business activity with him, and virtually froze all his assets in the U.S.


title: Eduardo Arellano Félix

text: Arellano was captured by the Mexican Federal Police after a shootout in Tijuana, Baja California, on October 26, 2008. Eduardo was sought by Interpol in 180 countries, and the U.S. State Department had been offering US$5,000,000 for information leading to his arrest. Eduardo Arellano Félix was charged in the U.S. Southern District of California with conspiracy to import cocaine and marijuana.


title: Eduardo Arellano Félix

text: Authorities say Arellano did not go down without a fight, despite having his 11-year-old daughter near him. On the same day, the Mexican military also arrested another alleged lieutenant of the Tijuana Cartel in a separate incident: Luis Ramirez Vázquez, known as "El Güero Camarón", or "The Blond Shrimp". Although the arrests were blows to the Arellano Félix cartel it did not dismantle the organization, which is now being led by Eduardo's nephew, Luis Fernando Sánchez Arellano.


title: Eduardo Arellano Félix

text: On September 1, 2012, he was extradited to the U.S. to face charges of money laundering and drug trafficking among other crimes. He is the last Arellano Félix brother named in a 2003 indictment to be extradited. On August 18, 2013, he was sentenced to 15 years in prison. His sentence, however, was shorter than the one his brothers received because the U.S. court deemed that he was "less involved in the unsavory aspects" on the Tijuana Cartel. U.S. District Judge Larry A. Burns reminded Arellano that he was convicted either way because he was well-aware of the violent doings of his criminal organization, and told him that he should be embarrassed of his actions because they had a negative effect on the community and on the relationship between Mexico and the U.S. After having completed 8 years in the U.S., he has been deported back to Mexico in August 2021 and immediately transferred to the Federal Social Readaptation Center No. 1 maximum security prison in Almoloya de Juárez, State of Mexico.


title: TV Tropes

text: TV Tropes is a wiki website that collects and documents descriptions and examples of plot conventions and devices, which it refers to as tropes, within many creative works. Since its establishment in 2004, the site has shifted focus from covering only television and film tropes to those in general media, toys, writings, and their associated fandoms, as well as some non-media subjects such as history, geography, and politics. The nature of the site as a provider of commentary on pop culture and fiction has attracted attention and criticism from several web personalities and blogs.


title: TV Tropes

text: From April 2008 until July 2012, TV Tropes published free content. In July 2012, TV Tropes modified its license to allow only non-commercial distribution of its content but continued to host the prior submissions under a new distribution license.


title: TV Tropes

text: The TV Tropes website runs on its own wiki engine software, a heavily modified version of PmWiki, but is not open source. Before October 2010, it was possible to edit anonymously. Registration is now mandatory for all other activities besides viewing the website.


title: TV Tropes

text: TV Tropes was founded in 2004 by a programmer under the pseudonym "Fast Eddie." He described himself as having become interested in the conventions of genre fiction while studying at MIT in the 1970s and after browsing Internet forums in the 1990s. He sold the site in 2014 to Drew Schoentrup and Chris Richmond, who then launched a Kickstarter to overhaul the codebase and design.


title: TV Tropes

text: Initially focused on the TV series "Buffy the Vampire Slayer", TV Tropes has since expanded their coverage of many forms of media, including fan fiction. It renders many other subjects, including Internet works such as Wikipedia (often referred to in a tongue-in-cheek way as "The Other Wiki"). Articles on the site often relate to real life or point out real situations where certain tropes can or cannot be applied. It has used its informal style to describe topics such as science, philosophy, politics, and history under its Useful Notes section. TV Tropes does not have notability standards for the works it covers. It also can be used for recommending lesser-known media on the "Needs More Love" page.


title: TV Tropes

text: In October 2010, in what the site refers to as "The Google Incident", Google temporarily withdrew its AdSense service from the site after determining that pages regarding adult and mature tropes were inconsistent with its terms of service. The site separated NSFG articles (Not Safe for Google) from SFG articles (Safe for Google) in order to allow discussion of these kinds of tropes.


title: TV Tropes

text: In a separate incident in 2012, in response to other complaints by Google, TV Tropes changed its guidelines to restrict coverage of sexist tropes and rape tropes. Feminist blog "The Mary Sue" criticized this decision, as it censored documentation of sexist tropes in video games and young adult fiction. "ThinkProgress" additionally condemned Google AdSense itself for "providing a financial disincentive to discuss" such topics. Pornographic tropes and works, as well as additional content deemed inappropriate for coverage, were also removed from the site following the incident.


title: TV Tropes

text: In an interview with TV Tropes co-founder Fast Eddie, Gawker Media's blog "io9" described the tone of contributions to the site as "often light and funny". Cyberpunk author Bruce Sterling once described its style as a "wry fanfic analysis". Essayist Linda Börzsei described TV Tropes as a technological continuum of classical archetypal literary criticisms, capable of deconstructing recurring elements from creative works in an ironic fashion. Economist Robin Hanson, inspired by a scholarly analysis of Victorian literature, suggests TV Tropes offers a veritable treasure trove of information about fiction – a prime opportunity for research into its nature. In "Lifehacker", Nick Douglas compared TV Tropes to Wikipedia, recommending to "use [TV Tropes] when Wikipedia feels impenetrable, when you want opinions more than facts, or when you've finished a Wikipedia page and now you want the juicy parts, the hard-to-confirm bits that Wikipedia doesn't share." Writing for "The Believer", Chantel Tattolli commented that "It is deeply satisfying to go there and reckon with the patterns made over time, across culture, medium, and genre—and to catch them in rotation."


title: TV Tropes

text: In the book "Media After Deleuze", authors David Savat and Tauel Harper say that while TV Tropes does offer a "wonderful archeology of storytelling", the site undermines creativity and experience by attempting to "classify and represent" every part of a work.


title: Toyota FZ engine

text: The Toyota FZ engine was a 24-valve, DOHC straight-6 internal combustion engine manufactured by Toyota to replace the F-series engine. It was used primarily in SUVs because of its large displacement, smoothness, ruggedness and torque.


title: Toyota FZ engine

text: The engine displaced with a bore and stroke measuring , respectively and a 9.0:1 compression ratio; the head used Toyota's narrow-angle overhead camshafts for better fuel economy. The 1FZ had only two variants available: the 1FZ-F and the 1FZ-FE. The only significant difference between the two was the inclusion of electronic fuel injection on the 1FZ-FE, whereas the 1FZ-F used a carburetor.


title: Toyota FZ engine

text: The 1FZ-F produced at 4400 rpm and at 2800 rpm; its fuel injected counterpart produced at 4600 rpm and at 3200 rpm.


title: Toyota FZ engine

text: Starting in 1998, the fuel injected version (1FZ-FE) was updated in certain non-US markets. This version of the engine received many updates over the previous version such as a redesigned head, more compact pistons, updated throttle body, an improved intake manifold with longer intake runners, 4 nozzle fuel injectors to improve fuel atomization and direct ignition (via a wasted spark set-up with three dual outlet coils); the engine pictured here is that variant discernible by the intake manifold and lack of distributor. This version of the 1FZ-FE produced at 4600 rpm and at 3600 rpm on 91 Octane Fuel (RON) without a catalytic converter.


title: Toyota FZ engine

text: Also, a de-rated LPG version was built for the 7FG/7FZ series forklifts. Called 1FZ-E it produced at 2350 rpm and at 1200 rpm


title: Savitar (comics)

text: Savitar is a fictional supervillain appearing in comic books published by DC Comics. An immensely powerful speedster that leads a cult dedicated to the Speed Force, he has battled Wally West, Jay Garrick, and Barry Allen.


title: Savitar (comics)

text: A variation of the character appeared in the third season of The CW's live-action television series "The Flash", voiced by Tobin Bell.


title: Savitar (comics)

text: Savitar first appeared in "Flash" (vol. 2) #108 (December 1995), and was created by Mark Waid and Oscar Jimenez.


title: Savitar (comics)

text: Savitar was originally an unnamed pilot for a third-world nation that was to test a supersonic fighter jet during the Cold War. As he reached top speed, his plane was struck by what appeared to be lightning and he went down in hostile territory. Discovering he could defeat the enemy by moving at super-speed, he became obsessed, naming himself after the Hindu "god of motion" Savitar and dedicating his life to unlocking its secrets. As he studied, Savitar discovered new powers that no other living speedster has mastered. He can protect himself in a null-inertia force field, give speed and kinetic energy to objects or people, even those in a "rest state", and he could also heal his own injuries almost instantly.


title: Savitar (comics)

text: Savitar's obsession gained followers, and he became the leader of a cult. In search of more knowledge, he sought out the only super-speed hero operating at the time: Johnny Quick. This encounter became a battle, the tide of which was turned with Max Mercury's arrival leading Savitar toward the Speed Force, but causing him to bounce off, both speedsters being thrown forward in time. Emerging from the timestream before Savitar, Max Mercury became a mentor to the Flash family's various members and other speedsters, secretly preparing them against the day Savitar would exit the timestream.


title: Savitar (comics)

text: Reappearing decades later, Savitar found that his cult had grown in his absence, awaiting his return. He recruited former Blue Trinity member Lady Flash (Christina Alexandrova), and discovered a way to use the woman's speed to divert all energy from the Speed Force to his own army of ninjas. He then sought to eliminate the competition: The Flash (Wally West), Impulse, Golden Age Flash (Jay Garrick), Johnny Quick, Jesse Quick, XS and Max Mercury.


title: Savitar (comics)

text: Wally's direct Speed Force connection prevented Savitar from stealing Wally's speed, and a coalition of just about every speedster (except for Red Trinity) foiled his plans. Hell-bent on at least destroying the Flash's world in retribution, Savitar led Wally on a worldwide race of destruction, until the Flash chose to give Savitar what he wanted: union with the Speed Force. His earlier encounter had shown him that the others who had arrived before would deal with Savitar as they saw fit.


title: Savitar (comics)

text: In "The Flash Rebirth" mini-series, Savitar was able to escape from the Speed Force. He was run down by the Flash (Barry Allen) but Savitar disintegrates when the Flash touches him, leaving only a pile of bones. It is revealed that Professor Zoom altered Barry's Speed Force connection to make the Flash shift in reverse, cursed to kill every Speed Force user with a single touch until a conflict between the Flash and Zoom. Savitar, Lady Savitar (Christina Alexandrova) and Johnny Quick have been killed by this effect.


title: Savitar (comics)

text: In "DC Rebirth", Troia (a version of Donna Troy from an alternate future) recalls that Wally was killed by either Savitar or Brother Blood from that time.


title: Savitar (comics)

text: A retcon following "Infinite Frontier" establishes that Savitar, escaping his imprisonment at Barry's hands in the Speed Force, was responsible for the deaths at Sanctuary in Heroes in Crisis, not Wally West as originally believed. The explosion was caused as the Speed Force attempted to eject Savitar at various points along the timeline, succeeding at Sanctuary. Battling Wally during a frozen moment in time, Wally brings him back to the present, leaving recorded history untouched, before defeating Savitar and adding his power to his own.


title: Savitar (comics)

text: Savitar can move at super-speed, and is able to lend or steal speed from moving objects. He has accelerated healing due to increased metabolism and can generate a null Inertia force field.


title: Political campaign

text: A political campaign is an organized effort which seeks to influence the decision making progress within a specific group. In democracies, political campaigns often refer to electoral campaigns, by which representatives are chosen or referendums are decided. In modern politics, the most high-profile political campaigns are focused on general elections and candidates for head of state or head of government, often a president or prime minister.


title: Political campaign

text: The points summarize the main ideas of the campaign and are repeated frequently in order to create a lasting impression with the voters. In many elections, the opposition party will try to get the candidate "off message" by bringing up policy or personal questions that are not related to the talking points. Most campaigns prefer to keep the message broad in order to attract the most potential voters. A message that is too narrow can alienate voters or slow the candidate down with explaining details.


title: Political campaign

text: For example, in the 2008 American presidential election John McCain originally used a message that focused on his patriotism and political experience: "Country First"; later the message was changed to shift attention to his role as "The Original Maverick" within the political establishment. Barack Obama ran on a consistent, simple message of "change" throughout his campaign.


title: Political campaign

text: Fundraising techniques include having the candidate call or meet with large donors, sending direct mail pleas to small donors, and courting interest groups who could end up spending millions on the race if it is significant to their interests.


title: Political campaign

text: In a modern political campaign, the campaign organization (or "machine") will have a coherent structure of personnel in the same manner as any business of similar size.


title: Political campaign

text: A Campaign Manager’s primary duty is to ensure marketing campaigns achieve their objectives. They work with the Marketing Manager to create, execute and monitor the performance of campaigns and provide all the resources required to meet sales targets.


title: Political campaign

text: Political consultants advise campaigns on virtually all of their activities, from research to field strategy. Consultants conduct candidate research, voter research, and opposition research for their clients.


title: Political campaign

text: In the context of political campaigns, activists are "foot soldiers" loyal to a campaign's cause. As supporters, they promote the campaign as volunteer activists. Such volunteers and interns may take part in activities such as canvassing door-to-door and making phone calls on behalf of the campaigns.


title: Political campaign

text: A campaign team (which may be as small as one inspired individual, or a heavily resourced group of professionals) must consider how to communicate the message of the campaign, recruit volunteers, and raise money. Campaign advertising draws on techniques from commercial advertising and propaganda, also entertainment and public relations, a mixture dubbed politainment. The avenues available to political campaigns when distributing their messages is limited by the law, available resources, and the imagination of the campaigns' participants. These techniques are often combined into a formal strategy known as the campaign plan. The plan takes account of a campaign's goal, message, target audience, and resources available. The campaign will typically seek to identify supporters at the same time as getting its message across.


title: Political campaign

text: The modern, open campaign method was pioneered by Aaron Burr during the American presidential election of 1800.


title: Political campaign

text: Another modern campaign method by political scientist Joel Bradshaw points out four key propositions for developing a successful campaign strategy. “First, in any election the electorate can be divided into three groups: the candidate's base, the opponent's base, and the undecided. Second, past election results, data from registered voter lists, and survey research make it possible to determine which people fall into each of these three groups. Third, it is neither possible nor necessary to get the support of all people. Fourth, and last, once a campaign has identified how to win, it can act to create the circumstances to bring about this victory. In order to succeed, campaigns should direct campaign resources— money, time, and message— to key groups of potential voters and nowhere else.”


title: Political campaign

text: Election campaign communication refers to party-controlled communication, e.g. campaign advertising, and party-uncontrolled communication, e.g. media coverage of elections.


title: Political campaign

text: Campaign advertising is the use of paid media (newspapers, radio, television, etc.) to influence the decisions made for and by groups. These ads are designed by political consultants and the campaign's staff.


title: Political campaign

text: Media management refers to the ability of a political campaign to control the message that it broadcasts to the public. The forms of media used in political campaigns can be classified into two distinct categories: "paid media" or "earned media".


title: Political campaign

text: Paid media refers to any media attention that is directly generated from spending. This form of media is commonly found through political advertisements and organized events. An advantage of paid media is that it allows political campaigns to tailor the messages they show the public and control when the public sees them. Campaigns often prioritize spending in contested regions and increase their paid media expenses as an election approaches. Electoral campaigns often conclude with a “closing argument ad”, an advertisement that summarizes the campaign’s core themes and explains the candidate’s vision for the future. In the 2020 election, Joe Biden's "Rising" ad starts with him saying "we're in a battle for the soul of this nation" and a worker in Donald Trump's Pennsylvania ad stated "that will be the end of my job and thousands of others" if Trump lost.


title: Political campaign

text: Earned media describes free media coverage, often from news stories or social media posts. Unlike paid media, earned media does not incur an expense to the campaign. Earned media does not imply that the political campaign is mentioned in a positive manner. Political campaigns may often receive earned media from gaffes or scandals. In the 2016 United States Presidential Election, a majority of the media coverage surrounding Hillary Clinton was focused on her scandals, with the most prevalent topics being topics related to her emails.


title: Political campaign

text: Experts say that effective media management is an essential component of a successful political campaign. Studies show that candidates with higher media attention tend to have greater success in elections. It is also important to note that each form of media can influence the other. Paid media may raise the newsworthiness of an event which could lead to an increase in earned media. Campaigns may also spend money to emphasize stories circulating through media networks. Research suggests that neither form of media is inherently superior. A 2009 study found that media coverage was not significantly more effective than paid advertisements.


title: Political campaign

text: The internet is now a core element of modern political campaigns. Communication technologies such as e-mail, websites, and podcasts for various forms of activism enable faster communications by citizen movements and deliver a message to a large audience. These Internet technologies are used for cause-related fundraising, lobbying, volunteering, community building, and organizing. Individual political candidates are also using the internet to promote their election campaign. In a study of Norwegian election campaigns, politicians reported they used social media for marketing and for dialogue with voters. Facebook was the primary platform for marketing and Twitter was used for more continuous dialogue.


title: Political campaign

text: Signifying the importance of internet political campaigning, Barack Obama's presidential campaign relied heavily on social media, Search Engine Optimisation (SEO) and new media channels to engage voters, recruit campaign volunteers, and raise campaign funds. The campaign brought the spotlight on the importance of using internet in new-age political campaigning by utilizing various forms of social media and new media (including Facebook, YouTube and a custom generated social engine) to reach new target populations. The campaign's social website, my.BarackObama.com, utilized a low cost and efficient method of mobilizing voters and increasing participation among various voter populations. This new media was incredibly successful at reaching the younger population while helping all populations organize and promote action.


title: Political campaign

text: Now, online election campaign information can be shared in a rich information format through campaign landing pages, integrating Google's rich snippets, structured data, social media open graphs, and husting support file formats for YouTube like .sbv, , and . High proficiency and effective algorithmic integration will be the core factor in the framework. This technology integration helps campaign information reach a wide audience in split-seconds. This was successfully tested and implemented in the 2015 Aruvikkara election and the 2020 Kerala elections. Marcus Giavanni, social media consultant, blockchain developer and second place opponent in the 2015 Denver mayoral election, was first to file for the 2019 election. Marcus Giavanni used advanced algorithms, artificial intelligence, and voice indexing predictions to box in campaigns.


title: Political campaign

text: A husting, or the hustings, was originally a physical platform from which representatives presented their views or cast votes before a parliamentary or other election body. By metonymy, the term may now refer to any event, such as debates or speeches, during an election campaign where one or more of the representative candidates are present.


title: Political campaign

text: An informational campaign is a political campaign designed to raise public awareness and support for the positions of a candidate (or her/his party). It is more intense than a paper campaign, which consists of little more than filing the necessary papers to get on the ballot, but is less intense than a competitive campaign, which aims to actually win election to the office. An informational campaign typically focuses on low-cost outreach such as news releases, getting interviewed in the paper, making a brochure for door to door distribution, organizing poll workers, etc.


title: Political campaign

text: A paper campaign is a political campaign in which the candidate only files the necessary paperwork to appear on the ballot. The purpose of such a token effort may be simply to increase name awareness of a minor political party, to give voters of a certain ideology an opportunity to vote accordingly, or to ensure that the party has candidates in every constituency. It can be a cost-effective means of attracting media coverage. An informational campaign, by contrast, may involve news releases, newspaper interviews, door-to-door campaigning, and organizing polls. As the level of seriousness rises, the marginal cost of reaching more people rises accordingly, due to the high cost of TV commercials, paid staff, etc. which are used by competitive campaigns. Paper candidates do not expect to be elected and usually run simply as a way of helping the more general campaign. However, an unexpected surge in support for the party may result in many paper candidates being unexpectedly elected, as for example happened to the New Democratic Party in Quebec during the 2011 federal election.


title: Political campaign

text: A forthcoming study in the American Political Science Review found that campaigns have "an average effect of zero in general elections". The study found two instances where campaigning was effective: "First, when candidates take unusually unpopular positions and campaigns invest unusually heavily in identifying persuadable voters. Second, when campaigns contact voters long before election day and measure effects immediately — although this early persuasion decays."


title: Political campaign

text: One reason why it is hard to judge the effectiveness of an election campaign is because many people know who they want to vote for long before the campaigns are started. Voters are more likely to vote for a nominee based on whose values align closest with theirs. Studies suggest that party flips come from the analysis of how a voter sees their parties performance in the years before a campaign even begins.


title: Political campaign

text: Another study suggests that at the 2017 Austrian legislative election, 31% of voters admitted to either developing of changing their party preferences during the election campaign. The study provides data that shows how the main parties within Austria had differing levels of voters flipping toward them, thus proving that an election campaign has some level of effectiveness that differs between parties, depending on factors such as media presence.


title: Political campaign

text: In presidential campaigns in the United States, research indicates that a $10 million advantage in spending in an individual states leads to approximately 27,000 more votes for the campaign in the state, which can be sufficient to win a close race. In down-ballot races, spending matters more. Scholars have estimated that a $2 million advantage can net a Senate campaign 10,000 votes.


title: Political campaign

text: A large body of political science research emphasizes how "fundamentals" – the state of the economy, whether the country is at war, how long the president's party has held the office, and which candidate is more ideologically moderate – predict presidential election outcomes. However, campaigns may be necessary to enlighten otherwise uninformed voters about the fundamentals, which thus become increasingly predictive of preferences as the campaign progresses. Research suggests that "the 2012 presidential campaigns increased turnout in highly targeted states by 7–8 percentage points, on average, indicating that modern campaigns can significantly alter the size and composition of the voting population".


title: Political campaign

text: A consensus in the political science literature holds that national conventions usually have a measurable effect on presidential elections that is relatively resistant to decay.


title: Political campaign

text: Research is mixed on the precise impact of debates. Rather than encourage viewers to update their political views in accordance with the most persuasive arguments, viewers instead update their views to merely reflect what their favored candidate is saying.


title: Political campaign

text: The fundamentals matter less in the outcome of presidential primaries. One prominent theory holds that the outcome of presidential primaries is largely determined by the preferences of party elites. Presidential primaries are therefore less predictive, as various types of events may impact elites' perception of the viability of candidates. Gaffes, debates and media narratives play a greater role in primaries than in presidential elections.


title: Political campaign

text: Traditional ground campaigning and voter contacts remain the most effective strategies. Some research suggests that knocking on doors can increase turnout by as much as 10% and phone calls by as much as 4%. One study suggests that lawn signs increase vote share by 1.7 percentage points. A review of more than 200 get-out-the-vote experiments finds that the most effective tactics are personal: Door-to-door canvassing increases turnout by an average of about 2.5 percentage points; volunteer phone calls raise it by about 1.9 points, compared to 1.0 points for calls from commercial phone banks; automated phone messages are ineffective. Using out-of-state volunteers for canvassing is less effective in increasing turnout than using local and trained volunteers.


title: Political campaign

text: According to political scientists Donald Green and Alan Gerber, it costs $31 to produce a vote going door to door, $91-$137 to produce a vote by sending out direct mailers, $47 per vote from leafletting, $58-$125 per vote from commercial phone banking, and $20-$35 per vote from voluntary phone banking. A 2018 study in the "American Economic Review" found that door-to-door canvassing on behalf of the Francois Hollande campaign in the 2012 French presidential election "did not affect turnout, but increased Hollande's vote share in the first round and accounted for one fourth of his victory margin in the second. Visits' impact persisted in later elections, suggesting a lasting persuasion effect." According to a 2018 study, repeated get-out-the-vote phone calls had diminishing effects but each additional phone call increased the probability to vote by 0.6-1.0 percentage points. Another 2018 study found that "party leaflets boost turnout by 4.3 percentage points while canvassing has a small additional effect (0.6 percentage points)" in a United Kingdom election.


title: Political campaign

text: A 2016 study found that visits by candidate visits to states have modest effects: "visits are most effective in influencing press coverage at the national level and within battleground states. Visits’ effects on voters themselves, however, are much more modest than consultants often claim, and visits appear to have no effects outside the market that hosts a visit." The authors of the study argue that it would be more effective for campaigns to go to the pockets of the country where wealthy donors are (for fundraising) and hold rallies in the populous states both to attract national press and raise funds. A 2005 study found that campaign visits had no statistically significant effect, after controlling for other factors, on voter turnout in the 1992, 1996, and 2000 elections. On the other hand, a 2017 paper of the 1948 presidential election provides "strong evidence that candidate visits can influence electoral returns". Other research also provides evidence that campaign visits increase vote share.


title: Political campaign

text: Campaigns may also rely on strategically placed field offices to acquire votes. The Obama 2008 campaign's extensive use of field offices has been credited as crucial to winning in the states of Indiana and North Carolina. Each field office that the Obama campaign opened in 2012 gave him approximately a 0.3% greater vote share. According to one study, the cost per vote by having a field office is $49.40.


title: Political campaign

text: According to a 2020 study, campaign spending on messaging to voters affects voter support for candidates. Another 2020 study found that political advertising had small effects regardless of context, message, sender, and receiver. A 2022 study found that voters are persuadable to switch support for candidates when they are exposed to new information.


title: Political campaign

text: Political science research generally finds negative advertisement (which has increased over time) to be ineffective both at reducing the support and turnout for the opponent. A 2021 study in the "American Political Science Review" found that television campaign ads do affect election outcomes, in particular in down-ballot races. According to political scientists Stephen Ansolabehere and Shanto Iyengar, negative ads do succeed at driving down overall turnout though. A 2019 study of online political advertising conducted by a party in the 2016 Berlin state election campaign found that the online-ad campaign "increased the party's vote share by 0.7 percentage points" and that factual ads were more effective than emotional ads.


title: Political campaign

text: Political campaigns have existed as long as there have been informed citizens to campaign amongst. Democratic societies have regular election campaigns, but political campaigning can occur on particular issues even in non-democracies so long as freedom of expression is allowed. Often mass campaigns are started by the less privileged or anti-establishment viewpoints (as against more powerful interests whose first resort is lobbying). The phenomenon of political campaigns are tightly tied to lobby groups and political parties.


title: Political campaign

text: The first modern campaign is often described as William Ewart Gladstone's Midlothian campaign in 1878–80, although there may be earlier recognizably modern examples from the 19th century. The 1896 William McKinley presidential campaign laid the groundwork for modern campaigns.


title: Political campaign

text: In the 1790-1820s, the Federalist Party and the Democratic-Republican Party battled it out in the so-called "First Party System". American election campaigns in the 19th century created the first mass-base political parties and invented many of the techniques of mass campaigning.


title: Political campaign

text: Political campaigns are forever changing and evolving with the growth of technology. In the nineteenth-century candidates were not traveling the country in search of votes. That is until the American presidential race of 1896 when William McKinley recruited the help of Marcus A. Hanna. Hanna devised a plan to have voters come to McKinley. McKinley won the race with 51% of the votes.


title: Political campaign

text: The development of new technologies has completely changed the way political campaigns are run. In the late twentieth-century campaigns shifted into television and radio broadcasts. The early 00s brought interactive websites. By 2008 the world of campaigns was available to millions of people through the internet and social media programs. 2008 marks a new era of digital elections because of the fast-paced movement of information.


title: Retro Studios

text: Retro Studios, Inc. is an American video game developer and subsidiary of Nintendo based in Austin, Texas. The studio is best known for its work on the "Metroid Prime" and "Donkey Kong Country" series, and has contributed to several other Nintendo-developed projects, such as "Mario Kart 7".


title: Retro Studios

text: Retro was founded on September 21, 1998, as an alliance between Nintendo and Iguana Entertainment founder Jeff Spangenberg, hoping to create games for the upcoming GameCube aiming at an older demographic. The company began work on four games, all of which were canceled once Retro focused their resources on "Metroid Prime", the first "Metroid" game developed outside Japan. The success of "Metroid Prime" led Retro to work on three sequels, and later to become involved with reviving the "Donkey Kong" series with "Donkey Kong Country Returns".


title: Retro Studios

text: Retro Studios was founded on September 21, 1998, as an alliance between Nintendo and industry veteran Jeff Spangenberg. Spangenberg subsequently launched the company from his home on October 1, using funds he generated with his previous ventures, including Iguana Entertainment. Nintendo saw an opportunity for the new studio to create games for the upcoming GameCube targeting an older demographic, in the same vein as Iguana Entertainment's successful "" series for the Nintendo 64. Retro began with 4 key people in late 1998 and opened an office in Austin, Texas in early 1999 with a staff of 25 people, including several former Iguana employees. Despite not having access to GameCube development kits, the studio immediately began work on four projects for the GameCube: an action adventure game named "MetaForce", a vehicular combat game with the working title "Car Combat" (also known as "Thunder Rally"), an American football simulator named "NFL Retro Football", and role-playing game "Raven Blade". By the time development began, the studio had already grown in size to 120 employees. The company continued to grow during production, eventually peaking at over 200 employees.


title: Retro Studios

text: The working environment was chaotic, with development getting behind schedule, and Nintendo executives complaining on how the games turned out. In 2000, producer Shigeru Miyamoto visited the studio. He was disappointed by the games except for their demonstration of the "MetaForce" game engine, which led Miyamoto to suggest that Retro could use the engine to develop a new game in the "Metroid" series. Shortly before the 2000 Nintendo Space World conference, Nintendo granted Retro the license to create "Metroid Prime", and Retro shifted all development resources from "MetaForce" to the new game.


title: Retro Studios

text: Retro eventually canceled development of their other projects to focus solely on "Metroid Prime". In February 2001, the company ended development of both "NFL Retro Football" and "Thunder Rally", laying off about 20 employees. Although Retro demonstrated "Raven Blade" at E3 in 2001, the development team was plagued by technical setbacks. In July 2001, Retro canceled the project, retaining only nine team members to work on "Metroid Prime". Notably, artist Android Jones served as lead concept artist on the development of "Metroid Prime".


title: Retro Studios

text: On May 2, 2002, Nintendo secured $1 million worth of Retro Studios stock from Spangenberg, and reclassified the company as a first party developer and division of Nintendo. Steve Barcia, the founder of Simtex, replaced Spangenberg as president of the company.


title: Retro Studios

text: During the final nine months of "Metroid Prime"'s development, Retro's staff worked 80- to 100-hour weeks to reach their final milestone. Despite its troubled production cycle and initial skepticism from fans, the game was released on November 17, 2002, in North America to universal critical acclaim and commercial success, selling over two million units worldwide.


title: Retro Studios

text: After the critical and commercial success of "Metroid Prime", Nintendo asked Retro Studios to produce a sequel. The developers decided against recycling the features of the first game while creating "", and instead used new sound models, weapon effects, and art designs. A multiplayer component was also added to the game. In April 2003, Steve Barcia left the company. Michael Kelbaugh, who had worked with Nintendo for over 15 years, was appointed president, a job he retains to this date. Retro tried to include some extras, such as a hidden version of "Super Metroid", but were halted by the short development time. Producer Kensuke Tanabe later revealed in an interview that the game was just about thirty percent complete three months before the strict deadline Nintendo had set for a release in the 2004 holiday season. The critical reception for "Metroid Prime 2: Echoes" was very positive, but earned some criticism on the game's high difficulty. Sales for "Echoes" were lower than the first "Prime", with a total of 800,000 units.


title: Retro Studios

text: Retro Studios was then put to produce the next game in the "Metroid Prime" series, "". Retro intended to give "Metroid Prime 3: Corruption" larger environments than "". The developers were also interested in using the WiiConnect24 feature to provide additional content for the game that would be accessible from the Internet. Retro announced that "Corruption" would be the final chapter of the "Prime" series and would have a plot "about closure, told against the backdrop of an epic struggle". After the Wii Remote was revealed, Nintendo demonstrated how "Metroid Prime 3" would take advantage of the controller's special abilities with a version of "Echoes" modified for the Wii and shown at the Tokyo Game Show in 2005. Originally envisioned as a launch game for the Wii in November 2006, "Corruption" suffered many delays, but eventually being released in August 2007 generally positive reviews, and over 1.60 million copies sold worldwide.


title: Retro Studios

text: While Retro was busy with the "Prime" sequels, they had to pass on the Nintendo DS game "Metroid Prime Hunters". The eventual developer, Nintendo Software Technology (NST), worked closely with Retro to design the game's art and characters to make sure that they fit into the overall Metroid series.


title: Retro Studios

text: In April 2008, Retro saw the departure of three key developers, designer Mark Pacini, art director Todd Keller, and principal technology engineer Jack Mathews, who went on to form their own company, Armature Studio. Around the same time, Shigeru Miyamoto asked fellow producer Kensuke Tanabe to recommend a studio that could develop a new "Donkey Kong" game, and Tanabe recommended Retro. Kelbaugh had worked on the "Donkey Kong Country" series during his years at Nintendo of America, and had interest in continuing with the franchise. Retro accepted the task, and thus started development of "Donkey Kong Country Returns". Similar to "New Super Mario Bros.", the game was developed with the intention to invoke nostalgic feelings in the player with its art style and sound, while trying to provide them with new gameplay experiences. "Returns" employs fully polygonal 3D graphics with three times the amount of textures and polygons that "Corruption" offered, and over the course of six months, two thirds of the game's tools and engine had to be rewritten by the programmers. Development accelerated at the outset of 2010, and the project was just "beginning to cohere as a game" around the time of E3, when it was officially announced to the press. Although the game was set for release in autumn that year, the team still had 70 levels to create or refine.


title: Retro Studios

text: At E3 2011, it was announced during Nintendo's Developer Roundtable that Retro Studios would be involved in the development of "Mario Kart 7" for Nintendo 3DS. At first, Retro would contribute assets to developing one of the "Donkey Kong"-themed levels, but the number evolved to the stage design of sixteen tracks in the late stages of development, as the Nintendo EAD crew started working on other projects and the game would not be finished before the December 2011 deadline.


title: Retro Studios

text: In 2012, it was revealed that Retro Studios had received a Wii U development kit, and was reportedly working on a Wii U game. Miyamoto has said he would like to work with Retro Studios in an installment for "The Legend of Zelda"; however, he says that the current game Retro Studios was working on is not related to "Zelda". At E3 2012, Nintendo of America president Reggie Fils-Aimé told IGN in an interview that Retro is currently "hard at work" on an untitled project for the Wii U.


title: Retro Studios

text: On February 28, 2014, Kensuke Tanabe announced that Retro Studios was working on a new game, which CEO Michael Kelbaugh declared had been in development for a few months since "Tropical Freeze" was finished. In August 2015 however, during an interview about "", Tanabe said that he was not quite sure about what Retro Studios was working on, leaving the impression that he was no longer involved with their unannounced project.


title: Retro Studios

text: Nintendo announced "Metroid Prime 4" in June 2017 during their E3 online showcase, showing only the logo. Shortly after the announcement, Bill Trinen, Director of Product Marketing at Nintendo of America, confirmed that "Prime 4" would not be developed by Retro Studios, the studio that developed the previous "Metroid Prime" games, but would be produced by Kensuke Tanabe, the producer of the previous games. In 2018, "Eurogamer" reported that "Prime 4" was being developed by Bandai Namco Studios in Singapore. However, in a video released on January 25, 2019, Nintendo EPD general manager Shinya Takahashi announced that "Metroid Prime 4" had been delayed, and that development had been restarted with Retro Studios. Takahashi said that development under the previous studio had not met Nintendo's standards. Nintendo's shares fell by 2.8 percent in the week following the announcement.


title: Anthony Adams

text: Anthony "Spice" Adams (born June 18, 1980) is an American television host, actor, comedian, and former football defensive tackle. After playing college football for Penn State, he was drafted by the San Francisco 49ers in the second round of the 2003 NFL Draft, for whom he played four seasons, followed by the Chicago Bears from 2007 to 2011.


title: Anthony Adams

text: After his playing career, he became involved in social media and television. He is a former co-host of "The Great American Baking Show", the American adaptation of the popular "Great British Bake Off".


title: Anthony Adams

text: Adams played for the Penn State Nittany Lions football team from 1999 to 2002, being named to the academic all-Big Ten Conference team in the former and honorable mention all-Big Ten in the latter.


title: Anthony Adams

text: During his freshman year, he recorded four tackles in nine games, which increased to 36 tackles and a sack the following season. As a junior, he had 59 tackles, 3.5 sacks, and led the team in tackles-for-loss with 11. In his senior year, he had 67 tackles, two sacks, 13 tackles-for-loss, and four pass breakups. The 2002 Nittany Lions entered the 2003 Capital One Bowl with the chance to record their first top-ten ranking since 1996, but lost to Auburn.


title: Anthony Adams

text: Before the 2003 NFL Draft, Adams participated in the Senior Bowl. Representing the North alongside four of his Penn State teammates, his team won 17–0.


title: Anthony Adams

text: The San Francisco 49ers selected Adams in the second round (57th overall) of the 2003 NFL Draft; the 49ers, who lost two starting defensive linemen during the offseason, drafted Adams and defensive end Andrew Williams in the following round to fill the gap.


title: Anthony Adams

text: Adams became a free agent after the 2006 season, ending his 49ers tenure with 155 tackles and six sacks in 58 games. On March 25, 2007, he signed a four-year contract with the Chicago Bears; team writer Larry Mayer described Adams as "an undersized but quick tackle who seemingly is an ideal fit for the Bears' one-gap defense." In 2010, he started all 16 games and the Bears' playoff games; at season's end, he was named a Brian Piccolo Award recipient. The following season, he only started four games and appeared in 11, and was released on February 26, 2012.


title: Anthony Adams

text: He announced his retirement via YouTube on March 24, 2013. In nine seasons, he served primarily as a depth player, starting at least eight games in three years. He ended his career with 278 tackles and 10.5 sacks.


title: Anthony Adams

text: Adams and his wife, Andenika, have four children. Teammates have bestowed several nicknames on Adams: Former 49ers teammate Bryant Young dubbed him "Double A" not only for his initials but also for his suspicion that Adams' extra energy came from batteries. His Penn State teammates nicknamed him "Spice". Adams was voted "Mama's Boy" his senior year at Martin Luther King High School in Detroit. He is a member of Omega Psi Phi fraternity and was initiated at Nu Chapter. In the summer of 2012, Adams produced a series of videos on YouTube about life as an NFL free agent. On May 5, 2013, Adams earned his Masters in Business Administration from George Washington University.


title: Anthony Adams

text: Since 2006, Adams has been involved with Youthville, a program in his hometown of Detroit. He gave away two Super Bowl XL tickets to the student who demonstrated the greatest improvement in grade point average. In 2009, Adams visited several Chicago Public Schools to help students write letters to troops overseas during the Iraq and Afghanistan wars.


title: Anthony Adams

text: During his tenure with the 49ers, Adams was a blogger and hosted an online show with teammate Mike Adams called "The Adams Report".


title: Anthony Adams

text: Starting on September 14, 2013, Adams began hosting a weekly half-hour show titled "Inside the Bears", which airs on WFLD and WPWR-TV.


title: Anthony Adams

text: In 2016, Adams began a recurring role on the HBO series "Ballers". He was announced on September 21, 2017 as one of the new hosts of "The Great American Baking Show", an American adaptation of "The Great British Bake Off", on ABC.


title: Anthony Adams

text: Adams is well known for his Instagram account, where he posts comedic videos under the username "spiceadams". Many of the characters and skits he has created have gone viral since 2018; an example is his catchphrase "ahaha", which became the subject of multiple memes on Twitter, and a photo of him hiding behind a tree in a bright yellow suit while rubbing his hands together and licking his lips in an expression of desire for what he is looking at.


title: Maguindanao

text: Maguindanao (, Maguindanaon: "Prubinsya nu Magindanaw"; Iranun": Perobinsia a Magindanao"; ) was a province of the Philippines located in the Bangsamoro Autonomous Region in Muslim Mindanao (BARMM). From 2014 to 2022, its provincial capital was Buluan, but the legislative branch of government, the Maguindanao Provincial Board, convened at the old provincial capitol in Sultan Kudarat. It bordered Lanao del Sur to the north, Cotabato to the east, Sultan Kudarat to the south, and the Illana Bay to the west.


title: Maguindanao

text: The province was replaced by Maguindanao del Sur and Maguindanao del Norte since September 18, 2022 after a division of the province was approved in a plebiscite.


title: Maguindanao

text: Shariff Mohammed Kabungsuwan of Johore introduced Islam in the area at the end of the 15th century. He subsequently married a local princess from the Maranao Tribe of Malabang and Maguindanao Province, and established the Sultanate of Maguindanao. The Cotabato Valley formed the sultanate's heartland but its influence extended from the Zamboanga Peninsula to Sarangani Bay and Davao.


title: Maguindanao

text: The Spaniards launched expeditions to subdue the area throughout the colonial era but they never gained control of the region until the middle of the 19th century after the Spaniards established a military post at what is now Barangay Tamontaka, one of the earliest Christian settlements founded south of the Philippines, in present-day Cotabato City.


title: Maguindanao

text: The historical province of Cotabato covered the present area of Maguindanao. In 1903, the American colonial government established the Moro Province and made Cotabato as one of its districts. Upon the conversion of the Moro Province into the Department of Mindanao and Sulu in 1914, the districts were made into provinces.


title: Maguindanao

text: In 1945, Maguindanao was liberated by allied Philippine Commonwealth troops and Maguindanaon guerrilla units after defeating the Japanese Imperial forces in the Battle of Maguindanao during the Second World War.


title: Maguindanao

text: The territory of the old province of Cotabato was reduced in 1966 when several of its municipalities were separated from it and constituted into the newly created province of South Cotabato. In 1973, Cotabato was dissolved when it was split to create three new provinces: Maguindanao, (North) Cotabato and Sultan Kudarat.


title: Maguindanao

text: Maguindanao is the only Muslim-majority province of the four created out of the original Cotabato Province. In 1989, majority of its voters opted to join the Autonomous Region in Muslim Mindanao but Cotabato City did not. Despite this, the city would later serve as the provisional capital of the Autonomous Region in Muslim Mindanao (ARMM) and host line agency offices for the province.


title: Maguindanao

text: On August 23, 1992, 16 senior officers of the insurgent Communist Party of the Philippines-New People's Army (CPP-NPA) operating in the province were arrested by intelligence operatives of the Philippine National Police, with officials considering it to be a significant hit against the organization's progress in the region.


title: Maguindanao

text: On October 31, 2006, Maguindanao voters approved the creation of a new province to be composed of 10 towns from the province. Of more than 500,000 voters registered, 285,372 favored the creation of the province, and 8,802 voted against it. The new province, Shariff Kabunsuan, established through "Muslim Mindanao Autonomy Act No. 201" by the ARMM Regional Legislative Assembly, became the country's 80th province and the 6th in the ARMM. It was composed of the towns of Datu Odin Sinsuat, Kabuntalan, Upi, Sultan Kudarat, Datu Blah T. Sinsuat, Sultan Mastura, Parang, Buldon, Matanog and Barira. However, in July 2008, the Supreme Court, in an 8–6 vote, nullified the province's creation, restoring its municipalities to Maguindanao, ruling that "Only Congress can create provinces and cities because the creation of provinces and cities necessarily includes the creation of legislative districts".


title: Maguindanao

text: On November 23, 2009, a 2010 gubernatorial election caravan supporting Esmael Mangudadatu, vice mayor of Buluan, was attacked. Fifty-seven people were killed, including Mangudadatu's wife and sisters, supporters, local journalists, and bystanders. On December 4, 2009, a number of homes belonging to the Ampatuan political family were raided in connection with the massacre.


title: Maguindanao

text: President Gloria Macapagal Arroyo officially declared martial law in the province of Maguindanao on December 5, 2009, Saturday morning.


title: Maguindanao

text: In a press conference past 7 am, Executive Secretary Eduardo Ermita announced "Proclamation No. 1959" declaring a state of martial law and suspending the privilege of the writ of habeas corpus in the province of Maguindanao, except for certain areas identified as bailiwicks of the Moro Islamic Liberation Front (MILF) separatists.


title: Maguindanao

text: The declaration of martial law led to the "arrests without warrants" of other members of the Ampatuan clan who have been linked to the November 23 massacre of 58 civilians.


title: Maguindanao

text: On August 15, 2011, Mangudadatu and his convoy were ambushed as they were on their way to his birthday celebration.


title: Maguindanao

text: On January 25, 2015, 44 members of the Special Action Force were killed after they killed the Jemaah Islamiyah terrorist Zulkifli Abdhir aka Marwan, by allegedly Moro Islamic Liberation Front and Bangsamoro Islamic Freedom Fighters in Mamasapano, Maguindanao.


title: Maguindanao

text: In February 2016, Maguindanao experienced the effects of the 2014–16 El Niño, causing destruction on rice and corn fields due to drought. The province declared a state of calamity in response to the damages caused.


title: Maguindanao

text: In the 17th Congress, then House Deputy Speaker Bai Sandra Sema (barred by law to run for another term in her current district in 2019) introduced a bill on March 2, 2017, seeking to establish a new province called "Maguindanao North".


title: Maguindanao

text: Later in the 18th Congress, two new House bills were filed: one by First District Rep. Datu Roonie Sinsuat Sr., Sema's successor, seeking the creation of "Western Maguindanao"; another by Second District Rep. Esmael Mangudadatu with same naming proposal as Sema. A substitute bill was later authored by both Maguindanao representatives along with Tarlac Third District Rep. Noel Villanueva, and approved in the final reading in 2020. In the Senate, three bills were also filed seeking for the same division with Sen. Bong Revilla pursuing instead the same naming proposal as Sinsuat. This time, those bills, except one by Revilla, would name the divided provinces as "Northern Maguindanao" and "Southern Maguindanao".


title: Maguindanao

text: In the substitute bill in the House, "Northern Maguindanao" will consist the municipalities that became part of Shariff Kabunsuan along with Sultan Sumagka, and its designated provincial capital will be Datu Odin Sinsuat, while the capital of "Southern Maguindanao" will be Buluan. Both proposed provinces will comprise a lone legislative district. Prior to the final version, the municipalities of Datu Anggal Midtimbang (by Sema and Mangudadatu) and South Upi (by Sinsuat) were proposed to became part of "Maguindanao North/Western Maguindanao"; Sultan Kudarat was proposed by Mangudadatu to be the capital of the then-proposed province.


title: Maguindanao

text: The proposed division was signed by Pres. Rodrigo Duterte on May 27, 2021, as "Republic Act No. 11550", with new provinces to be named "Maguindanao del Norte" and "Maguindanao del Sur" (named as the mother province of Maguindanao). The original schedule of the plebiscite, to be supervised by the Commission on Elections (COMELEC), was in September 2021, ninety days after the effectivity of the law, but was postponed as the COMELEC was preparing for the 2022 general election.


title: Maguindanao

text: "RA No. 11550" was ratified on September 17, 2022, in a plebiscite, thus dividing Maguindanao. Among the province-wide plebiscites, it was the most participated in terms of number of registered and actual voters, with the voter turnout as the second highest, only behind that of the 1998 plebiscite creating and taking Compostela Valley from Davao del Norte. With that division, the number of provinces in the country has raised to 82.


title: Maguindanao

text: Maguindanao was situated in the central section of Mindanao, bordered by Lanao del Sur to the north, Cotabato to the east, Sultan Kudarat to the south, and the Illana Bay to the west.


title: Maguindanao

text: Maguindanao compriseed 36 municipalities, further subdivided into 508 barangays. Cotabato City, although geographically grouped with Maguindanao, was administratively independent from the province.


title: Maguindanao

text: The province was divided into two congressional districts. In October 2006, the first congressional district was split off into a new province, Shariff Kabunsuan. However, the ARMM's Act creating the province was nullified by the Supreme Court in July 2008, on the basis that creation of a province is a function of the Philippine legislature. The area since reverted to the province of Maguindanao.


title: Maguindanao

text: The province saw establishments of new municipalities, especially during the 2000s. Then ARMM Regional Legislative Assembly (RLA) secretary Dick Mali said such establishments would help in "decentralizing functions and resources" and provide the people "more efficient public service and governance from their public officials." However, Benedicto Bacani of the Institute of Autonomy and Governance in the Notre Dame University said such acts are methods to prevent potential conflicts between political families by having their own local government units where they can have governmental positions.


title: Maguindanao

text: The population of Maguindanao in the 2020 census was 1,667,258 people. When Cotabato City was included for geographical purposes, the province's population is 1,667,258 people.


title: Maguindanao

text: The majority (64.5 percent) of the people in Maguindanao were Maguindanaoans. The Iranuns which dominate the northern towns of Parang, Barira, Buldon and Matanog made up the second largest group with 18.4 percent. The Tedurays, which are the lumads of the southwestern highlands of the province, made up 8.4 percent of the entire population, while Hiligaynons and Cebuanos constituted the remaining significant groups in the province with each making up 3.2 percent of the population.


title: Maguindanao

text: The main native languages were Maguindanao and Iranun, while Tagalog emerged as the primary language among younger generations and is the primary medium of education, making it the lingua franca. Cebuano, Hiligaynon, and Chavacano were also spoken by both Christians and Muslims, with the Chavacano dialect native to Cotabato City being called "Cotabateño", which evolved from the Zamboangueño dialect and Cebuano spoken as lingua franca of Mindanao. Teduray, also native to the province, was spoken in the municipalities of Upi, South Upi, and Datu Blah T. Sinsuat. English, the country's other official language was also spoken, while Arabic was taught in Islamic schools.


title: Maguindanao

text: Maguindanao inhabitants were predominantly practitioners of Islam which comprises 82.99% of the population, majority of which are Sunnites. A minority are Christians (mostly Roman Catholics), who were mostly Cebuanos, Ilonggos and Chavacanos. Roman Catholics of Maguindanao fell under the jurisdiction of the Roman Catholic Diocese of Kidapawan, a suffragan of the Archdiocese of Cotabato. Iglesia ni Cristo (INC) had several locales in Maguindanao.


title: Maguindanao

text: Maguindanao was divided into two congressional districts, which elected members to the House of Representatives. For the brief period that the province of Shariff Kabunsuan existed, Maguindanao became a lone-district province. Since the appointment of a new set of provincial officials for the reunified province of Maguindanao by the ARMM Governor in January 2009, the provincial government reverted to the Sangguniang Panlalawigan district configuration from before Shariff Kabunsuan was created.


title: Maguindanao

text: Having elected to join the Autonomous Region in Muslim Mindanao (ARMM), Maguindanao also sent six representatives (three per SP district) to the ARMM Regional Legislative Assembly that convened in Cotabato City.


title: Maguindanao

text: When the province was established in 1973, the designated seat of government was the municipality of Maganoy. The first appointed governor, Simeon Datumanong, held office in Limpongo, a former barangay in Maganoy which is now part of the municipality of Datu Hoffer Ampatuan.


title: Maguindanao

text: Datumanong's successor Zacaria Candao, on the other hand, held office at P.C. Hill, the site of the former headquarters of the Philippine Constabulary in Cotabato City, an autonomous chartered city not under Maguindanao's provincial jurisdiction.


title: Maguindanao

text: In 1977 following the resignation of Candao, President Ferdinand Marcos moved the province's seat of government to the municipality of Sultan Kudarat (hometown of the newly appointed governor Sanggacala Baraguir) by virtue of Presidential Decree No. 1170. During his term Baraguir held office at the then-newly constructed provincial capitol in that municipality's Barangay Simuay Crossing.


title: Maguindanao

text: The next governor, Sandiale Sambolawan, held office in his hometown of Maganoy following his election to the governorship in 1980. In an attempt to legitimize the restoration of Maganoy's status as the seat of provincial government, Batas Pambansa Blg. 211 was enacted in 1982, but with the explicit provision that the change will only take effect after a plebiscite affirms the transfer. A plebiscite was scheduled for December 18, 1982, but was never administered, thus making the municipality of Sultan Kudarat still capital of Maguindanao by law ("de jure"), but Maganoy being the capital in practice ("de facto"). Following the end of the Marcos Regime, the next two governors – Zacaria Candao (1986–1992; 1995–2001) and Norodin Matalam (1992–1995) – both held office in the existing capitol at Sultan Kudarat thereby restoring the municipality's status as both "de jure" and "de facto" provincial capital from 1986 to 2001.


title: Maguindanao

text: Despite the lack of legal justification in the form of a law amending P.D. No. 1170 of 1977 or the passage of a supporting Sangguaniang Panlalawigan (SP) resolution, the next governor, Andal Ampatuan Sr. (governor from 2001 to 2008), and his successor, son Sajid Ampatuan (2008–2009), held office in the Ampatuan clan stronghold of Shariff Aguak (renamed from Maganoy in 1996), citing security concerns connected to clan rivalry. A new 218-million provincial capitol complex, inaugurated in 2009 in the presence of President Gloria Macapagal Arroyo, was located adjacent to the homes of the Ampatuans, and sat on a piece of Amaptuan clan land that had not been legally deeded to the government. The Ampatuans were even known to spend more time within the "satellite offices" they set up within their private properties, despite though the new capitol being located adjacent to their homes.


title: Maguindanao

text: Esmael Mangudadatu, who took office after defeating Andal Ampatuan Jr. in the 2010 gubernatorial election, cited security concerns when he decided to work from a "satellite office," named the Rajah Buayan Silongan Peace Center, in his hometown of Buluan; this move was supported by Resolution No. 5, series 2010, of the Sangguniang Panlalawigan (SP) of Maguindanao. SP Resolution No. 78, dated May 3, 2011, further allowed the transfer of the legislative branch of the provincial government (Sangguniang Panlalawigan) to the rehabilitated old capitol site in Barangay Simuay Crossing, Sultan Kudarat. This effectively made both Buluan and Sultan Kudarat – located 120 kilometers apart by road – the seats of the executive and legislative branches of provincial government respectively.


title: Maguindanao

text: On April 3, 2012, the SP of Maguindanao issued Resolution No. 132, reiterating that the town of Sultan Kudarat was the capital of Maguindanao. However this was superseded by a new resolution passed in 2014 naming Buluan the new capital of Maguindanao. Buluan's Rajah Buayan Silongan Peace Center then served as the provisional capitol building, pending the completion of the executive building in the new capitol complex. However, the legislative branch of provincial government, the Sangguniang Panlalawigan of Maguindanao, continued to hold sessions in the rehabilitated buildings of the old provincial capitol in Simuay, Sultan Kudarat.


title: Maguindanao

text: The Ampatuan-built former provincial capitol complex in Shariff Aguak, initially planned to be converted for public school use, was planned to become the new headquarters of the ARMM's Bureau of Fire Protection and eventually became an infantry brigade of the Philippine Army. However, incumbent governor Bai Mariam Mangudadatu held her office in the Shariff Aguak Provincial Capitol and planned to convert the Buluan provincial capitol to a district hospital.


title: Maguindanao

text: Following the provincial division as approved in the 2022 plebiscite, Section 5 of Republic Act No. 11550 officially designated Buluan as the capital of the mother municipality of Maguindanao del Sur where Shariff Aguak is also located. Sultan Kudarat municipality was designated to Maguindanao del Norte but Datu Odin Sinsuat will be designated as its capital.


title: Maguindanao

text: The native Maguindanaon culture revolved around Kulintang music, a specific type of gong music, found among both Muslim and non-Muslim groups of the Southern Philippines.


title: General-purpose bomb

text: A general-purpose bomb is an air-dropped bomb intended as a compromise between blast damage, penetration, and fragmentation in explosive effect. They are designed to be effective against enemy troops, vehicles, and buildings.


title: General-purpose bomb

text: General-purpose (GP) bombs use a thick-walled metal casing with explosive filler (typically TNT, Composition B, or Tritonal in NATO or United States service) comprising about 30% to 40% of the bomb's total weight. The British term for a bomb of this type is "medium case" or "medium capacity" (MC). The GP bomb is a common weapon of fighter bomber and attack aircraft because it is useful for a variety of tactical applications and relatively cheap.


title: General-purpose bomb

text: General-purpose bombs are often identified by their weight (e.g., ). In many cases this is strictly a "nominal weight" (the counterpart to the "caliber" of a firearm), and the actual weight of each individual weapon may vary depending on its retardation, fusing, carriage, and guidance systems. For example, the actual weight of a U.S. M117 bomb, nominally , is typically around .


title: General-purpose bomb

text: Most modern air-dropped GP bombs are designed to minimize drag for external carriage on aircraft lacking bomb bays.


title: General-purpose bomb

text: In low-altitude attacks, there is a danger of the attacking aircraft being caught in the blast of its own weapons. To address this problem, GP bombs are often fitted with "retarders", parachutes or pop-out fins that slow the bomb's descent to allow the aircraft time to escape the detonation.


title: General-purpose bomb

text: GP bombs can be fitted with a variety of fuzes and fins for different uses. One notable example is the "daisy cutter" fuze used in Vietnam War era American weapons, an extended probe designed to ensure that the bomb would detonate on contact (even with foliage) rather than burying itself in earth or mud, which would reduce its effectiveness. (This was not the first instance of such devices. As early as World War II, the Luftwaffe was using extended-nose fuzes on bombs dropped by Stuka dive-bombers and other aircraft for exactly the same reason. A blast several feet above the ground is many times more effective and has a far greater radius than one that is delayed until the bomb is below the surface.)


title: General-purpose bomb

text: GP bombs are commonly used as the warheads for more sophisticated precision-guided munitions. Using various types of seeker and electrically controlled fins turns a basic 'iron' bomb into a laser-guided bomb (like the U.S. Paveway series), an electro-optical guided bomb, or, more recently, GPS-guided weapon (like the U.S. JDAM). The combination is cheaper than a true guided missile (and can be more easily upgraded or replaced in service), but is substantially more accurate than an unguided bomb.


title: General-purpose bomb

text: During WWII the British adopted a description of general-purpose bombs as medium capacity (MC) bombs. The MC was developed from 1942 to replace the existing 1000 lb GP (General Purpose) bomb. Initially using most of the components of the 1000 lb GP it was decided to give it a new tail and it was built with a half-inch-thick wall. Fillings could be Amatex, Amatol, Minol, RDX and others. Actual weight was around .


title: General-purpose bomb

text: It was introduced to service in 1943 and about a quarter of a million were produced by the end of the war.


title: General-purpose bomb

text: During the Korean War and Vietnam War the U.S. used older designs like the M65, M117 and M118, which had an explosive content about 65% higher than most contemporary weapons. Although some of these weapons remain in the U.S. arsenal, they are little used and the M117 is primarily carried only by the B-52 Stratofortress.


title: General-purpose bomb

text: The primary U.S. GP bombs are the Mark 80 series. This class of weapons uses a shape known as Aero 1A, designed by Ed Heinemann of Douglas Aircraft as the result of studies in 1946. It has a length-to-diameter ratio of about 8:1, and results in minimal drag for the carrier aircraft. The Mark 80 series was not used in combat until the Vietnam War, but has since replaced most earlier GP weapons. It includes four basic weapon types:


title: General-purpose bomb

text: Vietnam service showed the Mk 81 "Firecracker" to be insufficiently effective, and it was withdrawn from U.S. service. However, recently, precision-guided variants of the Mk 81 bomb have begun a return to service, based on U.S. experience in Iraq after 2003, and the desire to reduce collateral damage compared to Mk 82 and larger bombs (e.g., when attacking a single small building in a populated area).


title: General-purpose bomb

text: Since the Vietnam War and the 1967 USS Forrestal fire, United States Navy and United States Marine Corps GP bombs are distinguished by a thick ablative fire-retardant coating, which is designed to delay any potential accidental explosion in the event of a shipboard fire. Land-based air forces typically do not use such coatings, largely because they add some to the weight of the complete weapon. Fire is less a danger in a land-based facility, where the personnel can be evacuated with relative ease, and the building be the only loss. At sea, the crew and munitions share a facility (the ship), and thus are in much more danger of fire reaching munitions (which tend to be more closely packed, due to space limitations). Also, losing a munitions storage building on land is far cheaper than sacrificing an entire naval vessel, even if one could easily evacuate the crew.


title: General-purpose bomb

text: All Mk 80 bombs have both nose and tail fuze wells and can accept a variety of fuzes. Various nose and tail kits can be fitted to adapt the weapon for a variety of roles.


title: General-purpose bomb

text: On August 14, 2020, Kaman Precision Products received roughly $57.3 million for a "cockpit-selectable" bomb fuze to be used on Mark 80 warheads (guided and unguided). The contract involved foreign military sales (FMS) to 25 unnamed countries.


title: General-purpose bomb

text: The principal modern British bombs are and , and are no longer in service. The smaller 540 lb was retired with the demise of the Harrier GR9 aircraft with the larger 1000 lb being retired in Apr 2019. Currently the UK only uses the 500 lb class Paveway IV weapon system. The warhead is a modified enhanced Mk 82 warhead.


title: General-purpose bomb

text: The Russian term for general-purpose bomb is "fugasnaya aviatsionnaya bomba" (FAB) and followed by the bomb's nominal weight in kilograms. Most Russian iron bombs have circular ring airfoils rather than the fins used by Western types.


title: General-purpose bomb

text: In 1946 the Soviet Union developed a series of freefall bombs in four sizes , , , and and sharing a single nose and a single tail fuze. The bomb could be dropped from up to and up to ). The original, 1946-series bombs had poor ballistic characteristics at supersonic speed, and their construction was fragile. As an interim measure, upgraded versions of the bombs were built with thicker walls and no nose fuze. The thick-walled version of the bombs were built until 1956.


title: General-purpose bomb

text: The 1954 series of high-drag bombs was built in six sizes: , , , , , and . A feature of the 1954 series of bombs is the ballistic ring on the nose of the bomb which acts as a vortex generator to aid the bombs stabilizers. The smaller (less than ) bombs had a single nose and a single tail fuze, while the larger weapons shared a single nose fuze and two base fuzes. The FAB-9000 () weapon was roughly comparable to the wartime Grand Slam bomb. It was used by Russian aircraft designers as a substitute for early nuclear weapons when determining the size and clearances of bomb bays.


title: General-purpose bomb

text: In 1962 a new series of streamlined, low-drag bombs was introduced, designed for external carriage by fighter-bomber aircraft rather than in internal bays. They come in only two sizes, and . Both bombs have a single nose fuze.


title: General-purpose bomb

text: Both the 54 and 62 series designs remain in use. The most common of these are the FAB-100, FAB-250, FAB-500, FAB-750, and FAB-1500, roughly corresponding to the U.S. Mark 80 series. These have seen widespread service in Russia, Warsaw Pact nations, and various export countries.


title: General-purpose bomb

text: Larger bombs with less streamlined shapes also remained in the Soviet arsenal, primarily for use by heavy bombers. In the Iran–Iraq War, FAB-5000 () and FAB-9000 () bombs were dropped by Iraqi Air Force Tupolev Tu-22 bombers, generally against large, fixed targets in Iran. In Afghanistan in the 1980s, Soviet Tupolev Tu-16 and Tupolev Tu-22M bombers used massive FAB-1500, FAB-3000, FAB-5000NG, and FAB-9000 bombs to devastating effect during the Panjshir offensives.


title: General-purpose bomb

text: France's GP bombs, marketed by Matra and built by the Société des Ateliers Mécanique de Port-sur-Sambre (SAMP) are made in a variety of types with nominal weights from to . The most common are the EU2 and T25, T200, and BL4.


title: General-purpose bomb

text: Other countries, including Australia, Azerbaijan, Brazil, Chile, Greece, India, Israel, Pakistan, Poland, Portugal, Romania, South Africa, Spain, Sweden, and Turkey, manufacture their own bombs, most of which are either licensed versions of the U.S. Mark 80 series or close copies but India's DRDO has developed its own variants of bombs in the name of High Speed Low Drag Bomb


title: Aksyon Demokratiko

text: Aksyon Demokratiko ( ) or simply Aksyon is a political party in the Philippines founded by Raul Roco. It was recognized as a national political party in 1998 by the Commission on Elections (COMELEC) and is considered to be one of the major parties in the Philippines. Former Manila Mayor Isko Moreno currently acts as president of the party.


title: Aksyon Demokratiko

text: Aksyon participated in national and local elections since its founding (1998, 2001, 2004, 2007, 2010, 2013, 2016 and 2019) where it had moderate successes. In 2010, the party signed a coalition agreement with the Liberal Party in order to jointly field then Senator Benigno Aquino III for president.


title: Aksyon Demokratiko

text: For the 2016 Philippine general election, the party fielded national and local candidates throughout the Philippines including lawyer Lorna Kapunan and TIEZA COO Mark Lapid. It was aligned with the candidacy of Grace Poe.


title: Aksyon Demokratiko

text: The party's standard bearer for the 2019 senatorial elections was former Solicitor General Florin Hilbay. Prominent local government candidates of the party during the 2019 elections included Vico Sotto and Roman Romulo, who ran as mayor and representative of Pasig respectively, and Marielle del Rosario ran as representative of Navotas.


title: Aksyon Demokratiko

text: In 2021, Aksyon named then Manila Mayor Isko Moreno, who just joined the party from the National Unity Party, as its new party president ahead of the 2022 Philippine presidential election. New notable party members that would follow included 2019 senatorial candidate Samira Gutoc, Caloocan 2nd district representative Edgar Erice and former Vice President Noli de Castro. In November 2022, months after the 2022 elections, Executive Vice-President Vico Sotto resigned from the party.


title: Aksyon Demokratiko

text: "Magbago!" (Change!) "Makialam!" (Participate!) "Sulong sa Bagong Pilipinas!" (Forward to a New Philippines!) are the party's slogans. Aksyon is rooted in Raul Roco's "The Agenda of Hope": honest government; opportunity for all, special privileges for none; peace, productivity and prosperity; education and environment for sustainable development.


title: Aksyon Demokratiko

text: Aksyon believes that there should be regional solutions to regional problems. Aksyon organizes itself based on the principles of local autonomy. It believes and pushes for the empowerment of the Filipino masses. The party advocates a 'bottom-up' approach in tackling the issues of the country. Aksyon recognizes the importance of the participation of youth in government and therefore actively pushes for the empowerment of the youth.


title: Rylands v Fletcher

text: Rylands v Fletcher (1868) LR 3 HL 330 is a leading decision by the House of Lords which established a new area of English tort law. It established the rule that one's non-natural use of their land, which leads to another's land being damaged as a result of dangerous things emanating from the land, is strictly liable.


title: Rylands v Fletcher

text: Rylands employs contractors to build a reservoir. As a result of negligent work done, the reservoir burst and flooded a neighbouring mine, run by Fletcher, causing £937 worth of damage (). Fletcher brought a claim under negligence against Rylands. At the court of first instance, the majority ruled in favour of Rylands. Bramwell B, dissenting, argued that the claimant had the right to enjoy his land free of interference from water, and that Rylands was guilty of trespass and the commissioning of a nuisance. Bramwell's argument was affirmed by the Court of Exchequer Chamber and the House of Lords, leading to the development of the "Rule in "Rylands v Fletcher"".


title: Rylands v Fletcher

text: This doctrine was further developed by English courts, and made an immediate impact on the law. Prior to "Rylands", English courts had not based their decisions in similar cases on strict liability, and had focused on the intention behind the actions rather than the nature of the actions themselves. In contrast, "Rylands" imposed strict liability on those found detrimental in such a fashion without having to prove a duty of care or negligence, which brought the law into line with that relating to public reservoirs and marked a significant doctrinal shift. The rule in "Rylands" has both been distinguished with and regarded as a species of the fort of private nuisance. Unlike ordinary cases of private nuisance, the rule in Rylands requires the escape of a thing that arises from a non-natural use rather than the typical interference emanating from unreasonable use of land. It additionally does not require an act to be continuous, which is typically a requirement for nuisance. Academics have criticised the rule both for the economic damage such a doctrine could cause and for its limited applicability.


title: Rylands v Fletcher

text: The tort of "Rylands v Fletcher" has been disclaimed in various jurisdictions, including Scotland, where it was described as "a heresy that ought to be extirpated", and Australia, where the High Court chose to destroy the doctrine in "Burnie Port Authority v General Jones Pty Ltd". Within England and Wales, however, "Rylands" remains valid law, although the decisions in "Cambridge Water Co Ltd v Eastern Counties Leather plc" and "Transco plc v Stockport Metropolitan Borough Council" make it clear that it is no longer an independent tort, but instead a sub-tort of nuisance.


title: Rylands v Fletcher

text: In 1860, Rylands paid contractors to build a reservoir on his land, intending that it should supply the Ainsworth Mill with water. Rylands played no active role in the construction, instead contracting out to a competent engineer. While building it, the contractors discovered a series of old coal shafts and passages under the land filled loosely with soil and debris, which joined up with Thomas Fletcher's adjoining mine. Rather than blocking these shafts up, the contractors left them. On 11 December 1860, shortly after being filled for the first time, Rylands' reservoir burst and flooded Fletcher's mine, the Red House Colliery, causing £937 worth of damage. Fletcher pumped the water out, but on 17 April 1861 his pump burst, and the mine again began to flood. At this point a mines inspector was brought in, and the sunken coal shafts were discovered. Fletcher brought a claim against Rylands and the landowner, Jehu Horrocks, on 4 November 1861.


title: Rylands v Fletcher

text: The tort of trespass was inapplicable, as the flooding was deemed not to be "direct and immediate"; the tort of nuisance was rejected as this was a one-off event. The case was first heard by Mellor J and a special jury in September 1862 at the Liverpool Assizes; a court order led to an arbitrator from the Exchequer of Pleas being appointed in December 1864. The arbitrator decided that the contractors were liable for negligence, since they had known about the old mine shafts. Rylands, however, had no way of knowing about the mine shafts and so was not.


title: Rylands v Fletcher

text: The case then went to the Exchequer of Pleas, where it was heard between 3 and 5 May 1865. It was heard on two points: first, whether the defendants were liable for the actions of the contractors and secondly, whether the defendants were liable for the damage regardless of their lack of negligence. They decided for the first point that the defendants were not liable, but were split on the second point. Channell B recused. Pollock CB and Martin B held that the defendants were not liable, as since a negligence claim could not be brought there was no valid case. Bramwell B, dissenting, argued that the claimant had the right to enjoy his land free of interference from water, and that as a result the defendant was guilty of trespass and the commissioning of a nuisance. He stated that "the general law, wholly independent of contract" should be that the defendants were liable, "on the plain ground that the defendants have caused water to flow into the [claimant]'s mines, which but for their act would not have gone there..."


title: Rylands v Fletcher

text: Fletcher appealed to the Exchequer Chamber of six judges. The prior decision was overturned in his favour. Blackburn J spoke on behalf of all the judges and said that:


title: Rylands v Fletcher

text: Blackburn J's opinion relied on the liability for damages to land available through the tort of chattel trespass and the tort of nuisance, as well as the "in scienter action", injury by a domesticated animal known to have a disposition to injure. Rylands appealed.


title: Rylands v Fletcher

text: The House of Lords dismissed the appeal and agreed with the determination for Fletcher. Lord Cairns, in speaking for the House of Lords, stated their agreement of the rule stated above by Justice Blackburn, but added a further limitation on liability, which is that the land from which the escape occurs must have been modified in a way which would be considered non-natural, unusual or inappropriate. The case was then heard by the House of Lords on 6 and 7 July 1868, with a judgment delivered on 17 July. Oddly the court consisted of only two judges, Lord Cairns and Lord Cranworth; Lord Colonsay failed to attend. The eventual judgment confirmed Blackburn's decision and general principle, adding a requirement that the use be "non-natural". The judgment of Lord Cairns LC was as follows.


title: Rylands v Fletcher

text: The 'enjoyment of land' was primary in the reasons of Lord Cairns (above). This foundation stone is a recurring theme in the common law throughout the ages, to wit: "It has been well said, that the use of the law consists, first, in preserving men's persons from death and violence; next, in securing to them the free enjoyment of their property." Tindal, CJ: Charge to the Grand Jury at Bristol on the occasion of the 1832 riots over the rejection in the House of Lords of the Reform Bill.


title: Rylands v Fletcher

text: Early English common law had, in many instances, imposed liability on those who had caused harm regardless of wrongful intent or negligence. Trespass was considered a remedy for all tortious wrongs, and sometimes used as a synonym for torts generally. Over the centuries, however, judges focused more on the intent and negligence behind the actions than the nature of the actions themselves, leading to the development of negligence and nuisance and the further development of trespass. At the time of "Rylands", the previous case relied upon was "Vaughan v Menlove", decided in the Court of Common Pleas in 1837. The case had almost identical facts to "Rylands", but strict liability was never even considered. The case is instead thought of as one of the best attempts of early 19th century English judges to build up the law of negligence. The outcome of "Rylands" meant that judges would again impose strict liability on defendants who accumulated dangerous things on their land without any need to prove negligence or wrongful intent. The decision won support for bringing the law relating to private reservoirs up to standard with the law relating to public reservoirs, which contained similar statutory provisions thanks to a pair of private Acts of Parliament passed in 1853 and 1864.


title: Rylands v Fletcher

text: The decision in "Rylands" initially faced little criticism within England and Wales, although many American scholars and judges of the time felt that judgment was a poor one. Doe CJ of the New Hampshire Supreme Court wrote that it "put a clog upon natural and reasonably necessary uses of matter and tend to embarrass and obstruct much of the work which it seems to be a man's duty carefully to do". The American interpretation was based primarily on the idea that it would cause economic harm. Further American criticism is based on the idea that it is poor law. Firstly, they argue, it is not trespass, since the damage is not direct, and secondly, it is not a nuisance, because there is no continuous action. Glofcheski, writing in the "Hong Kong Law Journal", notes that "the doctrine has not flourished... a tort imposing strict liability should be closely interpreted and circumspectly applied". It has been argued that the decision was never entirely accepted by the judiciary as a whole, and that it is difficult to justify. This is for two reasons; firstly, it is a case of very limited applicability, and it has been suggested that it be folded into a general principle of strict liability for "ultra-hazardous" activities. Secondly, subsequent case law in England and Wales, particularly in "Rickards v Lothian", has undermined the "non-natural use" element by introducing a cost/benefit analysis which severely limits the decision's usefulness.


title: Rylands v Fletcher

text: The first article in the 1960 Canadian Bill of Rights states that "the right of the individual to life, liberty, security of the person and enjoyment of property, and the right not to be deprived thereof except by due process of law" is recognised. However it is difficult to adjudicate on this Bill, especially as the provinces have priority over property rights.


title: Rylands v Fletcher

text: A difficulty is encountered with the definition of "property", as remarked by Johansen, which may well be the reason why the matter remains for interpretation by precedent. The 1974 test case for the Bill of Rights, "Attorney General of Canada v. Lavell", provided an impetus for the 1982 Charter of Rights, which specifically excludes the "enjoyment of property" for reasons described in the Constitutional history of Canada page. Fridman on Torts in Canada has helpful material.


title: Rylands v Fletcher

text: In Ontario, a common law province, "Rylands" was upheld by a lower court in "Smith v. Inco Ltd." a case alleging that a factory in Port Colborne, Ontario had contaminated adjacent lands with nickel. A subsequent Ontario Court of Appeal ruling in 2010 found that the plaintiff had not provided sufficient evidence of economic harm, raising the legal burden of proof but not invalidating "Rylands" as precedent law. However, it has been said that the Court of Appeal erred in law in their adjudication over the words "non-natural". In April 2012, the Supreme Court of Canada chose not to hear the appeal.


title: Rylands v Fletcher

text: Mineral rights in the subsurface seem to be preferred over the landowner's rights by the Mineral Tenure Act or the Petroleum and Natural Gas Act in British Columbia (also a common law province) so that recourse to "Rylands" is quite limited, as case law has developed over liability "to compensate the owner of a surface area for loss or damage caused by the entry, occupation or use of that area" (MTA) and "compensation for nuisance and disturbance from the entry, occupation or use" (PNGA). The compensation for "entry, use and occupation of the Property" seems not to "exceed the entire [taxable] value of the land" as written in the registry. This means in effect that the relocation costs (of, say, a farming operation, or an abode) or emotional damage are likely not payable by the expropriator. Even municipalities cannot exclude miners. The powers of an arbitrator include compensation for land, timber and time, but expressly do not include watershed, health and welfare, or lost cattle. Miners avoid environmental review; the province has no discretion to refuse mineral leases; miners need not notify landowners of transactions; the province can exempt mines from review when mining commences; and landowners do not have rights to refuse to negotiate.


title: Rylands v Fletcher

text: The impact of "Rylands v Fletcher" in Quebec law, which is based for historical reasons on the civil code, was evaluated by the Supreme Court of Canada in the 1916 case of "Vandry et al. v. Quebec Railway, Light, Heat and Power Co." The SCC found that a section in the civil code had ample scope to support the liability of the Quebec Power Co.


title: Rylands v Fletcher

text: The party that can be sued in a "Rylands" claim is an owner or occupier of land, along with anyone who stores or collects the dangerous material, as in "Rainham Chemical Works Ltd v Belvedere Fish Guano Co Ltd". The party suing was initially one with an interest in land, but "Perry v Kendricks Transport Ltd" confirmed that an interest in land was not necessary to bring a claim. Historically, personal injury claims have been allowed, as in "Hale v Jennings". More recent cases, however, such as the House of Lords decision in "Transco plc v Stockport Metropolitan Borough Council", have confirmed that "Rylands" is "a remedy for damage to land or interests in land. It must...follow that damages for personal injuries are not recoverable under the rule".


title: Rylands v Fletcher

text: In "Cambridge Water" Lord Goff opined that the rule in "Rylands" should not further be developed, and that rather than being an independent tort it should be instead considered a sub-tort of nuisance. Statutory provisions, such as the Environmental Protection Act 1990, were a more modern and appropriate way of addressing environmental problems which would previously have been covered by "Rylands". Subsequently, "Transco" disapproved of the Australian decision in "Burnie Port Authority v General Jones Pty Ltd" to absorb "Rylands" into the general law of negligence, deciding that "Rylands" should continue to exist but, as Lord Bingham said, as a "sub-species of nuisance...while insisting upon its essential nature and purpose; and...restate it so as to achieve as much certainty and clarity as is attainable". It is now a sub-tort, rather than an independent tort; they have confirmed that it will be allowed to remain.


title: Rylands v Fletcher

text: Donal Nolan has argued that to consider "Rylands" as part of private nuisance is unsound. Private nuisance requires the claimant to have an interest in land, while "Rylands" does not; although exceptions to this rule have occasionally been made in private nuisance, in "Hunter v Canary Wharf Ltd", the House of Lords ruled that to make exceptions would transform nuisance from a tort against land to a tort against the person, and should not be permitted. John Murphy, Professor of Common Law at the University of Manchester, agrees with Nolan, and makes the additional point that nuisance is focused on a loss of enjoyment to land, not physical damage as "Rylands" is. It has also been concerned that the reasonable use test, which appears in nuisance, is not applicable to cases brought under "Rylands".


title: Rylands v Fletcher

text: The first requirement under "Rylands" is that the defendant "for his own purposes brings onto land and collects and keeps there". In "Rylands", this was the keeping of water in a reservoir; other cases in England and Wales have illustrated what sort of material is considered. In "British Celanese v AH Hunt", the accumulation was of metal foil strips. "For his own purpose" is not understood to be "for his benefit", although that was what Blackburn was referring to at the time; in "Smeaton v Ilford Corp", "Rylands" was held to apply to a local authority accumulating sewage on its land, although there was no benefit to the local authority from doing this.