Given a text passage, come up with an appropriate title for it. The title should accurately represent what the main focus of the passage is. The title of a passage may be present in the first few sentences of the passage and/or be referred to multiple times in the passage. The title should be 1-5 words long.

[EX Q]: New York City is situated in the Northeastern United States , in southeastern New York State , approximately halfway between Washington , D.C. and Boston . The location at the mouth of the Hudson River , which feeds into a naturally sheltered harbor and then into the Atlantic Ocean , has helped the city grow in significance as a trading port . Most of New York City is built on the three islands of Long Island , Manhattan , and Staten Island .
[EX A]: New York City

[EX Q]: The New York Botanical Garden ( NYBG ) is a botanical garden and National Historic Landmark located in the Bronx , New York City . The 250 - acre ( 100 ha ) site 's verdant landscape supports over one million living plants in extensive collections . Each year over one million visitors visit the garden 's remarkable diversity of tropical , temperate , and desert flora , as well as programming that ranges from exhibitions in the Haupt Conservatory to festivals on Daffodil Hill .
[EX A]: New York Botanical Garden

[EX Q]: The Cleveland Browns relocation controversy , sometimes referred to by fans as `` The Move '' , was the decision by then - Browns owner Art Modell to relocate the National Football League ( NFL ) 's Cleveland Browns from its long - time home of Cleveland to Baltimore during the 1995 NFL season . Subsequent legal actions by the city of Cleveland and Browns season ticket holders led the NFL to broker a compromise that saw the Browns history , records , and intellectual property remain in Cleveland . In return , Modell was permitted to move his football organization to Baltimore where he established the Baltimore Ravens . The Ravens are officially regarded by the NFL as an expansion team that began play in 1996 . The city of Cleveland agreed to demolish Cleveland Stadium and build a new stadium on the same site , and the NFL agreed to reactivate the Browns by the 1999 season through either an expansion draft or a relocated franchise . The Browns were officially reactivated in 1998 through the expansion process and resumed play in 1999 .
[EX A]:
Cleveland Browns relocation controversy