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Davenport v. Edward D. Jones Co., LP, No. 17-30388 (5th Cir. May 22, 2018)

| May 22, 2018 | Daily Developments in EEO Law |

Can a boss’s repeated offer of a “big bonus” to a woman employee as an inducement to date an important customer constitute quid pro quo sexual harassment? The Fifth Circuit today holds that it can … but also holds (2-1) that the plaintiff failed to present a genuine dispute that she was entitled to such a bonus in the first place.

Davenport v. Edward D. Jones & Co., LP, No. 17-30388 (5th Cir. May 22, 2018): Davenport worked as the Branch Office Administrator for a manager named Coyne. The panel summarized the facts as follows:

“After learning that Harry Fisher (‘Fisher’), a wealthy potential client, was interested in dating Davenport, Coyne told Davenport that she should ‘date’ Fisher in exchange for ‘big bonuses.’ Davenport responded that she had a boyfriend and that she was not interested in dating Fisher. Coyne repeated his offer approximately three more times within thirty days, but Davenport never dated Fisher.”

The next year, Coyne rated Davenport as “exceeding expectations,” and recommended that she receive a 4% salary increase, but she received no bonus. Davenport complained about Coyne’s behavior and eventually resigned. She filed a complaint alleging quid pro quo sex harassment based on the “big bonus” comments, as well as constructive discharge. The district court granted summary judgment, holding that no such claim could lie because “the sexual advances related to the alleged tangible employment action must relate to advances with the supervisor.

The Fifth Circuit, while rejecting some of the district court’s rationale, affirms summary judgment. The panel first holds that Davenport had failed to submit the constructive discharge claim to the EEOC for investigation, and thus forfeited her right to bring it in court.

The panel then addresses the bonus issue. It holds that “denial of a raise” is a tangible employment action, citing the U.S. Supreme Court’s decision in Burlington Industries, Inc., v. Ellerth. Contrary to the district court, the panel also holds that the propositioning in a quid pro quo case does not need to be directly by or for the supervisor’s benefit.

“Coyne allegedly conditioned the receipt of ‘big bonuses’ upon Davenport’s submission to his requests that she date Fisher. Because Coyne made the requests, he engaged in the sexual harassment, not Fisher. It is of no consequence that a third-party was to be the beneficiary-Coyne was the harasser.”

The panel also holds that even the open-ended suggestion that Davenport “date” Fisher could constitute actionable harassment, as it may be regarded as a “request for sexual favors.”

Nevertheless, two of the panelists hold that Davenport failed to present evidence that the employer took a tangible employment actions against her, and affirm summary judgment on that basis.

“Davenport produced no summary-judgment evidence that, under Edward Jones’s bonus policy, she was eligible for a bonus in October 2015 that Coyne could either approve or disapprove. Consequently, Davenport produced no summary judgment evidence that Coyne and Edward Jones denied her a bonus because she refused to date Fisher.”

Dissenting in part, Judge Higginson would have held that there was a genuine dispute of material fact whether Coyne possessed such authority. “

“Coyne hired Davenport, formally evaluated her work performance, and approved her salary increases and bonuses. In March of 2015, Coyne approved a $400 bonus for Davenport. As Edward Jones’ attorney conceded at oral argument, Coyne ‘was responsible for giving [Davenport] a bonus’ and could have approved a bonus ‘based on good performance or any other vague thing.'”

Thus whether “Coyne was joking or lying about a bonus” or was being honest was a credibility issue that belonged to a jury.

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The Phone Dragnet Did Not (and May Still Not) Meet the PATRIOT Act’s Minimization Requirements

While a number of the changes to Section 215 passed just before the government started relying on it to create a database of all phone-based relationships in the United States watered down the law, one provision made the law stricter.

The 2006 Reauthorization required the Attorney General to establish minimization procedures for the data collected under the program.

(g) Minimization Procedures and Use of Information- Section 501 of the Foreign Intelligence Surveillance Act of 1978 (50 U.S.C. 1861) is further amended by adding at the end the following new subsections:

(g) Minimization Procedures-

(1) IN GENERAL- Not later than 180 days after the date of the enactment of the USA PATRIOT Improvement and Reauthorization Act of 2005, the Attorney General shall adopt specific minimization procedures governing the retention and dissemination by the Federal Bureau of Investigation of any tangible things, or information therein, received by the Federal Bureau of Investigation in response to an order under this title.

(2) DEFINED- In this section, the term `minimization procedures’ means–

(A) specific procedures that are reasonably designed in light of the purpose and technique of an order for the production of tangible things, to minimize the retention, and prohibit the dissemination, of nonpublicly available information concerning unconsenting United States persons consistent with the need of the United States to obtain, produce, and disseminate foreign intelligence information;

(B) procedures that require that nonpublicly available information, which is not foreign intelligence information, as defined in section 101(e)(1), shall not be disseminated in a manner that identifies any United States person, without such person’s consent, unless such person’s identity is necessary to understand foreign intelligence information or assess its importance; and

(C) notwithstanding subparagraphs (A) and (B), procedures that allow for the retention and dissemination of information that is evidence of a crime which has been, is being, or is about to be committed and that is to be retained or disseminated for law enforcement purposes.

(h) Use of Information- Information acquired from tangible things received by the Federal Bureau of Investigation in response to an order under this title concerning any United States person may be used and disclosed by Federal officers and employees without the consent of the United States person only in accordance with the minimization procedures adopted pursuant to subsection (g). No otherwise privileged information acquired from tangible things received by the Federal Bureau of Investigation in accordance with the provisions of this title shall lose its privileged character. No information acquired from tangible things received by the Federal Bureau of Investigation in response to an order under this title may be used or disclosed by Federal officers or employees except for lawful purposes.’.

But from the very start, the FISA Court and the Administration set out to ignore this requirement. After all, well before anyone did any analysis about the foreign intelligence value of the phone dragnet data, the FBI disseminated all of it, by having the telecoms hand it over directly to the NSA. And phone numbers are US person identifiers (best demonstrated by NSA’s use of phone numbers as identifiers to conduct searches in other contexts).

Thus, before any Agency even touched the data, the phone dragnet scheme violated this provision by disseminating non-publicly available information about US person identifiers on every single American without their consent.

According to FISC’s original Section 215 phone dragnet order, the NSA only had to abide by the existing SID-18 minimization procedures.

[D]issemination of U.S. person information shall follow the standard NSA minimization procedures found in the Attorney General-approved guidelines (U.S. Signals Intelligence Directive 18). [link added]

And the FBI only applied the minimization procedures it used to fulfill the statute after the NSA had already run queries on it.

With respect to any information the FBI receives as a result of this Order (information that is passed or “tipped” to it by NSA), the FBI shall follow as minimization procedures the procedures set forth in The Attorney General’s Guidelines for FBI National Security Investigations and Foreign Intelligence Collection (October 31, 2003). [link added]

Even after this initial order, the Attorney General did not comply with the mandate to come up with minimization procedures specific to Section 215. Instead, then Attorney General Alberto Gonzales just adopted four sections of the National Security Investigations Guidelines.

In analysis included in a 2008 review of the FBI’s use of Section 215, DOJ Inspector General Glenn Fine deemed this measure to fall short of the statute’s requirements.

These interim minimization procedures use general hortatory language stating that all activities conducted in relation to national security investigations must be “carried out in conformity with the Constitution.” However, we believe this broad standard does not provide the specific guidance for minimization procedures that the Reauthorization Act appears to contemplate.

[T]he Reauthorization Act required the Department to adopt “specific procedures” reasonably designed to “minimize the retention, and prohibit the dissemination, of nonpublicly available information concerning unconsenting United States persons consistent with the need of the United States to obtain, produce, and disseminate foreign intelligence information.” We believe that the interim procedures do not adequately address this requirement, and we recommend that the Department continue its efforts to construct specific minimization procedures relating to Section 215 orders, rather than rely on general language in the Attorney General’s NSI Guidelines.

As I’ll show in a follow-up post, presumably in response to Fine’s report, Attorney General Michael Mukasey adopted new, arguably even more general guidelines to fulfill this requirement, the AG Guidelines for Domestic FBI Operations. (I strongly suspect the August 20, 2008 FISC opinion the government won’t release authorizes the language that would appear in those Guidelines).

But the implications of this have more immediate significance.

After all, the only known American who got busted based on a Section 215 tip, Basaaly Moalin, argues for a new trial tomorrow. And he was tipped based on dissemination that took place in 2007 — that is, before DOJ even tried to address these problematic minimization procedures. He was tipped based on dissemination that — under the letter of the PATRIOT Act — should never have happened.

Update: With regards to Moalin’s case, this seems pertinent.

As of early December 2007, the [Director of National Intelligence] working group [trying to harmonize defintions] had not defined “U.S. person identifying information.

This means that, at the time he was identified in the dragnet, the entire intelligence community was still fighting over whether phone numbers constituted US person identifying information entitled to additional protection.

Update: In an address to the EU Parliament, Jim Sensenbrenner accuses NSA of ignoring civil liberty protections in the PATRIOT Act.

“I firmly believe the Patriot Act saved lives by strengthening the ability of intelligence agencies to track and stop potential terrorists, but in the past few years, the National Security Agency has weakened, misconstrued and ignored the civil liberty protections we drafted into the law,” he said, adding that the NSA “ignored restrictions painstakingly crafted by lawmakers and assumed a plenary authority we never imagined.”

NSA Has a Database Problem

Back in 2009 when the government released what we now know is a FISA Court of Review decision ordering Yahoo to cooperate in PRISM, I questioned a passage of the decision that relied on the government’s claim that it doesn’t keep a database of incidentally collected conversations involving US persons.

In this post, I just want to point to a passage that deserves more scrutiny:

The government assures us that it does not maintain a database of incidentally collected information from non-targeted United States persons, and there is no evidence to the contrary. On these facts, incidentally collected communications of non-targeted United States persons do not violate the Fourth Amendment.(26)

To translate, if the government collects information from a US citizen (here or abroad), a legal permanent US resident, a predominantly US organization, or a US corporation in the course of collecting information on someone it is specifically targeting, it it claims it does not keep that in a database (I’ll come back and parse this in a second). In other words, if the government has a tap on your local falafel joint because suspected terrorists live off their falafels, and you happen to call in a take out order, it does not that have in a database.

There are reasons to doubt this claim.

In the rest of the post, I showed how a response from Michaels Mukasey and McConnell to Russ Feingold’s efforts to protect US person incidental collection during the FISA Amendments Act had made it clear having access to this incidentally collected data was part of the point, meaning the government’s reassurances to the FISCR must have been delicate dodges in one way or another. (Feingold’s Amendments would have prevented 3 years of Fourth Amendment violative collection, by the way.)

Did the court ask only about a database consisting entirely of incidentally collected information? Did they ask whether the government keeps incidentally collected information in its existing databases (that is, it doesn’t have a database devoted solely to incidental data, but neither does it pull the incidental data out of its existing database)? Or, as bmaz reminds me below but that I originally omitted, is the government having one or more contractors maintain such a database? Or is the government, rather, using an expansive definition of targeting, suggesting that anyone who buys falafels from the same place that suspected terrorist does then, in turn, becomes targeted?

McConnell and Mukasey’s objections to Feingold’s amendments make sense only in a situation in which all this information gets dumped into a database that is exposed to data mining. So it’s hard to resolve their objections with this claim–as described by the FISA Appeals Court.

Which is part of the reason I’m so intrigued by this passage of John Bates’ October 3, 2011 decision ruling some of NSA’s collection and retention practices violated the Fourth Amendment. In a footnote amending a passage explaining why the retention of entirely US person communications with the permissive minimization procedures the government had proposed is a problem, Bates points back to that earlier comment.

The Court of Review plaining limited its holding regarding incidental collection to the facts before it. See In re Directives at 30 (“On these facts, incidentally collected communications of non-targeted United States persons do not violate the Fourth Amendment.” (emphasis added). The dispute in In re Directives involved the acquisition by NSA of discrete to/from communications from an Internet Service Provider, not NSA’s upstream collection of Internet transactions. Accordingly, the Court of Review had occasion to consider NSA’s acquisition of MCTs (or even “about” communications, for that matter). Furthermore, the Court of Review noted that “[t]he government assures us that it does not maintain a database of incidentally collected information from non-targeted United States persons, and there is no evidence to the contrary.” Id. Here, however, the government proposes measures that will allow NSA to retain non-target United States person information in its databases for at least five years.

Ultimately, Bates’ approval for the government to query on US person identifiers on existing incidentally collected Section 702 material (see pages 22-23) show that he hasn’t really thought through what happens to US person incidental collection; he actually has a shocking (arguably mis-) understanding of how permissive the existing minimization rules are, and therefore how invasive his authorization for searching on incidentally collected information will actually be.

But his complaint with the proposed minimization procedures shows what he believes they should be.

The measures proposed by the government for MCTs, however, largely dispense with the requirement of prompt disposition upon initial review by an analyst. Rather than attempting to identify and segregate information “not relevant to the authorized purpose of the acquisition” or to destroy such information promptly following acquisition, NSA’s proposed handling of MCTs tends to maximize the retention of such information, including information of or concerning United States persons with no direct connection to any target.

As Bates tells it, so long as he’s paying close attention to an issue, the government should ideally destroy any US person data it collects that is not relevant to the authorized purpose of the acquisition. (His suggestion to segregate it actually endorses Russ Feingold’s fix from 2008.)

But the minimization rules clearly allow the government to keep such data (after this opinion, they made an exception only for the multiple communication transactions in question, but not even for the other search identifiers involving entirely domestic communication so long as that’s the only communication in the packet).

All the government has to do, for the vast majority of the data it collects, is say it might have a foreign intelligence or crime or encryption or technical data or threat to property purpose, and it keeps it for 5 years.

In a database.

Back when the FISCR used this language, it allowed the government the dodge that, so long as it didn’t have a database dedicated to solely US person communications incidentally, it was all good. But the language Bates used should make all the US person information sitting in databases for 5 year periods (which Bates seems not to understand) problematic.

Not least, the phone dragnet database, which — after all — includes the records of 310 million people even while only 12 people’s data has proved useful in thwarting terrorist plots.

Update: Fixed the last sentence to describe what the Section 215 dragnet has yielded so far.

Alberto Gonzales and Internet Data Mining

I was going to leave this speculation well enough alone. But George W Bush decided to interrupt his dog painting to defend Obama’s surveillance dragnet.

Bush also defended the surveillance program, which began during his administration after 9/11, saying the programs guarantee civil liberties are protected.

“I put the program in place to protect the country and one of the certainties is civil liberties were guaranteed,” Bush said.

So here goes.

In his book, Jack Goldsmith describes Alberto Gonzales siding against David Addington in a debate just once, only to have George Bush override the then White House Counsel.

Addington’s hard-line nonaccommodation stance always prevailed when the lawyers met to discuss legal policy issues in Alberto Gonzales’ office. During these meetings, Gonzales himself would sit quietly in his wing chair, occasionally asking questions but mostly listening as the querulous Addington did battle with whomever was seeking to “go soft.” It was Gonzales’ responsibility to determine what to advise the president after the lawyers had kicked the legal policy matters around. But I only knew him to disagree with Addington once, on an issue I cannot discuss, and on that issue the president overruled Gonzales and sided with the Addington position. [my emphasis]

The issue Goldsmith could not discuss could be torture or prisoner transfers or something entirely unknown, but the data mining at the heart of the hospital confrontation is clearly one candidate.

There’s no overt evidence Gonzales tried to do the right thing on the illegal surveillance program. After all, even after Bush agreed to put the program right on March 12, 2004, Gonzales still objected to Goldsmith and Jim Comey’s first advice on the program. After Goldsmith laid out his initial advice on March 15, Gonzales wrote a memo saying,

Your memorandum appears to have been based on a misunderstanding of the President’s expectations regarding the conduct of the Department of Justice. While the President was, and remains, interested in any thoughts the Department of Justice may have on alternative ways to achieve effectively the goals of the activities authorized by the Presidential Authorization of March 11, 2004, the President has addressed definitively for the Executive Branch in the Presidential Authorization the interpretation of the law.

This led Comey to write up his resignation letter on March 16. “[A]lthough I believe this has been one of [DOJ’s] finest hours, we have been unable to right that wrong.” Three days later, Bush modified his March 11 Authorization, directing NSA to stop collecting Internet metadata within a week.

Of course, three months later, the Administration resumed collection of Internet metadata using the FISC PR/TT order. That was within days of Goldsmith’s departure, though he had announced his departure a month earlier and Comey, obviously, stuck around for over a year longer.

So still no evidence the Internet data mining was the issue on which Gonzales tried to stand up to Addington.

But let’s jump ahead to the circumstances of Alberto Gonzales’ resignation in August 2007. At the time, his sudden and confusing resignation was attributed to the multiple scandals embroiling him — chiefly the US Attorney firing scandal, but also Gonzales’ Clapper-like lies about the illegal wiretap program before the Senate a month earlier. But for some reason, Gonzales did not benefit from the kind of sinecure every other former Bush official — even James Comey, who went to Lockheed — enjoyed upon departure, which you would have thought he’d get after lying to protect the President.

Then, a year after Gonzales’ departure, we learned that in the weeks before he resigned, White House Counsel Fred Fielding had narced him out for storing a bunch of Top Secret CYA documents in a briefcase in his closet. Read more

Metadata Oversight: “A Banner”!!!!!

The Guardian has their next big NSA scoop, and it is meatier than the earlier ones. The headline is that President Obama continued a 2-degrees of separation analysis of Internet metadata under Section 702 for two years after he came into office. The practice morphed into something else in 2011, making it highly likely the October 3, 2011 FISC opinion finding FAA 702 activities violated the Fourth Amendment pertained to this practice.

Along with their story, the released two documents, one of which has two appendices. Altogether they’ve released:

I’ll have far, far more to say going forward.

But I wanted to point to language that reinforces my fears about how they’re controlling the still extant database of US person telephone metadata.

The documents describe the great oversight of the Internet metadata twice. First in the November 20, 2007 letter itself:

When logging into the electronic data system users will view a banner that re-emphasizes key points regarding use of the data, chaining tools, and proper dissemination of results. NSA will also create an audit trail of every query made in each database containing U.S. communications metadata, and a network of auditors will spot-check activities in the database to ensure compliance with all procedures. In addition, the NSA Oversight and Compliance Office will conduct periodic super audits to verify that activities remain properly controlled. Finally, NSA will report any misuse of the information to the NSA’s Inspector General and Office of GEneral Counsel for inclusion in existing or future reporting mechanisms related to NSA’s signals intelligence activities.

And in the September 28, 2006 Amendment:

5. Before accessing the data, users will view a banner, displayed upon login and positively acknowledged by the user, that re-emphasizes the key points regarding use of the data and chaining tools, and proper dissemination of any results obtained.

6. NSA creates audit trails of every query made in each database containing U.S. communications metadata, and has a network of auditors who will be responsible for spot-checking activities in the database to ensure that activities remain compliant with the procedures described for the data’s use. The Oversight and Compliance Office conducts periodic super audits to verify that activities remain properly controlled.

7. NSA will report any misuse of the information to NSA’s Inspector General and Office of General Counsel for inclusion in existing or future reporting mechanisms relating to NSA’s signals intelligence activities.

These descriptions are consistent with what we’ve been told still exists with the telephone metadata, so it is likely (though not certain) the process remains the same.

There are two big problems, as I see it. First, note that the Oversight and Compliance Office appears to be within NSA’s operational division, not part of the Inspector General’s Office. This means it reports up through the normal chain of command. And, presumably, its actions are not required to be shared with Congress. The IG, by contrast, has some statutory independence. And its activities get briefed to Congress.

In other words, this initial check on the metadata usage appears to be subject to managerial control.

But my other worry is even bigger. See where the descriptions talk about the fancy banner? The description says nothing about how that log-in process relates to the audit trail created for these searches. Indeed, in both of these documents, “the NSA” “creates” the audit trails. They don’t appear to be generated automatically, as they easily could be and should be.

That is, it appears (and this is something that has always been left vague in these descriptions) that these are manual audit trails, not automatic ones. (Though I hope they go back and compare them with keystrokes.)

When FBI had this kind of access to similar data, they simply didn’t record a lot of what they were doing, which means we have almost no way of knowing whether there’s improper usage.

This may have changed. These “audit trails” may have been automatically generated at this time (though that’s not what the process describes). Though the NSA IG’s inability to come up with a number of how many US person records are access suggests there’s nothing automated about it.

And if that’s true, still true, then the telephone metadata still in place is an invitation for abuse.

Obama Administration Not Meeting Transparency Standard Set by Bush Lawyer Steven Bradbury

Glenn Greenwald has a great post on the Administration’s refusal to say whether it can kill Americans inside the US. But he misstates how extreme Obama’s refusal to share Office of Legal Counsel memos is. That’s because he equates an Administration sharing OLC memos with the intelligence committee and sharing them with the public.

Critically, the documents that are being concealed by the Obama administration are not operational plans or sensitive secrets. They are legal documents that, like the leaked white paper, simply purport to set forth the president’s legal powers of execution and assassination. As Democratic lawyers relentlessly pointed out when the Bush administration also concealed legal memos authorizing presidential powers, keeping such documents secret is literally tantamount to maintaining “secret law”. These are legal principles governing what the president can and cannot do – purported law – and US citizens are being barred from knowing what those legal claims are.

You know who once claimed to understand the grave dangers from maintaining secret law? Barack Obama. On 16 April 2009, it was reported that Obama would announce whether he would declassify and release the Bush-era OLC memos that authorized torture. On that date, I wrote: “today is the most significant test yet determining the sincerity of Barack Obama’s commitment to restore the Constitution, transparency and the rule of law.” When it was announced that Obama would release those memos over the vehement objections of the CIA, I lavished him with praise for that, writing that “the significance of Obama’s decision to release those memos – and the political courage it took – shouldn’t be minimized”. The same lofty reasoning Obama invoked to release those Bush torture memos clearly applies to his own assassination memos, yet his vaunted belief in transparency when it comes to “secret law” obviously applies only to George Bush and not himself.

But it is not the case that Bush always sat on OLC memos. In fact, as Dianne Feinstein noted in John Brennan’s confirmation hearing, at least by the last year of the Bush Administration, Democrats had gotten Steven Bradbury to start turning over even the most sensitive OLC memos to Congress.

I wanted to talk about, just for a moment, the provision of documents. Senator Wyden and others have had much to do about this. But our job is to provide oversight to try to see that the CIA and intelligence communities operate legally.

In order to do that, it is really necessary to understand what the legal — the official legal interpretation is. So the Office of Legal Counsel opinions becomes very important.

We began during the Bush administration with Mr. Bradbury to ask for OLC opinions. Up til last night, when the president called the vice chairman, Senator Wyden and myself and said that they were providing the OLC opinions, we have not been able to get them. It makes our job to interpret what is legal or not legal much more difficult if we do not have those opinions.

Which made it possible to — as DiFi did in an exchange with Michael Mukasey on April 10, 2008 — force the (Bush) Administration to publicly disavow some of the more extreme positions endorsed by John Yoo.  Read more

FISA Amendments Act: “Targeting” and “Querying” and “Searching” Are Different Things

Steven Aftergood suggests there’s disagreement among Senate Intelligence Committee members about whether or not the FISA Amendments Act allows the government to get US person content without a warrant.

The dispute was presented but not resolved in a new Senate Intelligence Committee report on the Foreign Intelligence Surveillance Act Amendments Act (FAA) Sunsets Extension Act, which would renew the provisions of the FISA Amendments Act through June 2017.

“We have concluded… that section 702 [of the Act] currently contains a loophole that could be used to circumvent traditional warrant protections and search for the communications of a potentially large number of American citizens,” wrote Senators Ron Wyden and Mark Udall.

But Senator Dianne Feinstein, the Committee chair, denied the existence of a loophole.  Based on the assurances of the Department of Justice and the Intelligence Community, she said that the Section 702 provisions “do not provide a means to circumvent the general requirement to obtain a court order before targeting a U.S. person under FISA.”

I don’t think there is a conflict. Rather, I think DiFi simply responded to Wyden and Udall’s assertions with the same spin the government has used for some time. That’s because DiFi is talking about “targeting” and Wyden and Udall are talking about “searching” US person communications.

DiFi quotes much of the language from Section 702 earlier in her statement on FAA, repeating, repeating the word “target” three times.

In enacting this amendment to FISA, Congress ensured there would be important protections and oversight measures to safeguard the privacy and civil liberties of U.S. persons, including specific prohibitions against using Section 702 authority to: “intentionally target any person known at the time of acquisition to be located in the United States;” “intentionally target a person reasonably believed to be located outside the United States if the purpose of such acquisition is to target a particular, known person reasonably believed to be in the United States;” “intentionally target a United States person reasonably believed to be located outside the United States;” or “intentionally acquire any communication as to which the sender and all intended recipients are known at the time of the acquisition to be located in the United States.” As an additional measure the law also requires that an acquisition under Section 702 “shall be conducted in a manner consistent with the fourth amendment to the Constitution of the United States.” [my emphasis]

Her specific retort to the problem Wyden and Udall differentiates clearly between “querying information collected under Section 702 to find communications of a particular United States person” and “conduct[ing] queries to analyze data already in its possession” and “targeting.”

Finally, on a related matter, the Committee considered whether querying information collected under Section 702 to find communications of a particular United States person should be prohibited or more robustly constrained. As already noted, the Intelligence Community is strictly prohibited from using Section 702 to target a U.S. person, which must at all times be carried out pursuant to an individualized court order based upon probable cause. Read more

Anonymous DOJ Statement: “Trust Us”

The Senate Judiciary Committee is holding a hearing today to review the results of the Schuelke report on the prosecutorial misconduct in the Ted Stevens case and to entertain the Lisa Murkowski bill requiring disclosure. In response, DOJ submitted a statement for the record, opposing any legislation enforcing its discovery obligations.

When concerns were first raised about the handling of the prosecution of Senator Stevens, the Department immediately conducted an internal review. The Attorney General recognized the importance of ensuring trust and confidence in the work of Department prosecutors and took the extraordinary step of moving to dismiss the case when errors were discovered. Moreover, toensure that the mistakes in the Stevens case would not be repeated, the Attorney General convened a working group to review discovery practices and charged the group with developing recommendations for improving such practices so that errors are minimized. As a result of the working group’s efforts, the Department has taken unprecedented steps, described more fully below, to ensure that prosecutors, agents, and paralegals have the necessary training and resources to fulfill their legal and ethical obligations with respect to discovery in criminal cases. These reforms include a sweeping training curriculum for all federal prosecutors and the requirement–for the first time in the history of the Department of Justice–that every federal prosecutor receive refresher discovery training each year.

In light of these internal reforms, the Department does not believe that legislation is needed to address the problems that came to light in the Stevens prosecution. Such a legislative proposal would upset the careful balance of interests at stake in criminal cases, cause significant harm to victims, witnesses, and law enforcement efforts, and generate substantial and unnecessary litigation that would divert scarce judicial and prosecutorial resources.

In short, DOJ is saying, “trust us. We don’t need a law requiring us to do what case law says we need to.”

Right off the bat, I can think of 5 major problem with this statement:

No one has been held accountable

We are three years past the time when Stevens’ case was thrown out. Yet none of the prosecutors involved have been disciplined in any meaningful way.

No doubt DOJ would say that it will hold prosecutors responsible if and when the Office of Professional Responsibility finds they committed misconduct. But in the interim three years, DOJ as a whole has sent clear messages that it prefers protecting its case to doing anything about misconduct. And–as Chuck Grassley rightly pointed out at the hearing–thus far no one has been held responsible.

This statement may claim DOJ is serious about prosecutorial misconduct. But its actions (and inaction) says the opposite.

Even after this training, discovery problems remain

As the DOJ statement lays out, in response to the Stevens debacle, DOJ rolled out annual training programs for prosecutors to remind them of their discovery obligations.

And yet, last year, Leonie Brinkema found that prosecutors in the Jeff Sterling case had failed to turn over critical evidence about prosecution witnesses–one of the problems with the Stevens prosecution. The prosecutor involved? William Welch, whom Schuelke accused of abdicating his leadership role in the Stevens case (note, DOJ says the CIA is at fault for the late discovery; but Welch is, after all, the prosecutor who bears responsibility for it).

If William Welch can’t even get discovery right after his involvement in this case and, presumably, undergoing the training DOJ promises will fix the problem, then training is not enough to fix the problem.

Eric Holder won’t run DOJ forever

The statement focuses on Holder’s quick decision to dismiss the case against Stevens, as if that, by itself, guards against any similar problems in the future. But before Holder was AG, Michael Mukasey was–and Judge Emmet Sullivan grew so exasperated with Mukasey’s stonewalling on this case, he ordered him to personally respond to questions about the case.

Read more

The Government Doesn’t Want to Talk about Collecting Domestic Communications under FAA

On Friday, the government appealed the 2nd Circuit’s decision that Amnesty International and other NGOs and individuals have standing to challenge the FISA Amendments Act. I’ll have a post on the implications of their substantive argument shortly. But in the meantime, I wanted to note what they’re not even addressing.

The image to the left is a fragment of the government’s references to statutes and regulation mentioned in its brief; it’s the part of the list referring to the part of the FAA in question. As you can see, it almost–but not quite–lists every clause of the law.

One clause notably missing from the almost-sequential list above is 1881a(b)(4), which reads,

[An acquisition authorized under subsection (a)] may not intentionally acquire any communication as to which the sender and all intended recipients are known at the time of the acquisition to be located in the United States;

And while it mentions clauses that refer back to this restriction (for example, 1881a(c)(1), 1881a(d), 1881a(g)(2)(A)(i), etc), it never goes back and includes this language–the requirement that the government not intentionally acquire communications that are located entirely within the US–in its argument. (There are other clauses the brief ignores, a number of which pertain to oversight of the certifications the government has made; I may return to these at a future time.)

Or, to put it another way, the government never admits that the FAA permits the purportedly unintentional collection of entirely domestic communication.

And yet that is a part of this lawsuit. The original complaint in this suit invoked this clause:

An acquisition under section 702(a) may not … “intentionally acquire any communication as to which the sender and all intended recipients are known at the time of the acquisition to be located in the United States

Moreover, the Attorney General and the DNI may acquire purely domestic communications as long as there is uncertainly about the location of one party to the communications.

And the 2nd Circuit opinion (authored by Gerard Lynch) referenced this clause:

“Targeting procedures” are procedures designed to ensure that an authorized acquisition is “limited to targeting persons reasonably believed to be located outside the United States,” and is designed to “prevent the intentional acquisition of any communication as to which the sender and all intended recipients are known at the time of the acquisition to be located in the United States.”

In addition, the certification must attest that the surveillance complies with statutory limitations providing that it:

(4) may not intentionally acquire any communication as to which the sender and all intended recipients are known at the time of the acquisition to be located in the United States;

Under the FAA, in contrast to the preexisting FISA scheme, the FISC may not monitor compliance with the targeting and minimization procedures on an ongoing basis. Instead, that duty falls to the AG and DNI, who must submit their assessments to the FISC, as well as the congressional intelligence committees and the Senate and House Judiciary Committees.

But the government has not asserted, and the statute does not clearly state, that the FISC may rely on these assessments to revoke earlier surveillance authorizations.

Now, to some degree, the government might argue it ignored the clause prohibiting intentional–but not accidental–targeting of domestic communications because the plaintiffs’ primary basis for establishing standing is their frequent communication with likely targets overseas. As I’ll show, the government wants to make this case about a particular definition of a target, and key to that argument is a claim that it is impossible for the plaintiffs to be targets.

Yet therein lies one of the key problems with their argument, given that 1881a(b)(4) only prohibits the plaintiffs from being intentional targets; the FAA very pointedly did not prohibit the government from keeping US person information it “unintentionally” collected. In fact, Mike McConnell and Michael Mukasey started issuing veto threats when Russ Feingold tried to restrict the ongoing use of domestic communications identified as such after the fact.

Finally, in the one case that approved this kind of collection (though under the Protect America Act, not the FAA) used targeting procedures to substitute for particularity required under the Fourth Amendment. Under PAA, those procedures were not mapped out by law; under FAA they are, partly in the clause the government wants to ignore.

And yet, remarkably, the government doesn’t want that clause to be part of its discussion with SCOTUS. Seeing as how even the FISA Court of Review finds that substitute for particularity–the targeting procedures–to be a key part of compliance with the Fourth Amendment, you’d think that would be relevant.

The NYPD Profiles Everyone’s Favorite Terrorist Group, MEK

As I noted yesterday, the latest installment of Goldman and Apuzzo’s exposure of the CIA-on-the-Hudson relies on a 2006 document laying out plans to profile Iranians and Shiites (and Palestinians) in anticipation of heightened US-Iranian conflict.

New York City has always been a prime target for terrorist groups and as the possibility of military action taken against Iran grows stronger, so does the danger of the City being attacked by agents of the Iranian government or its sympathizers.

Based on that premise, they lay out a bunch of groups to profile.

Among those, however, is the MEK, the Iranian opposition group designated as a foreign terrorist organization. Here’s what the document has to say about them:

Mujahedin-e-Khalq Organization (MEK), designated by the US Department of State as a terrorist group, has presence in NYC. MEK is strongly opposed to the current Iranian administration and it is not believe [sic] not to pose a threat of retaliation should the US engage Iran military. The group’s actions here are typified by several incidents where suspected MEK members disrupted speeches and protested against Iranian officials visiting and/or present in US.

Now, at one level, the MEK actually is a designated terrorist organization, regardless of how sensible that designation remains. So it makes sense to see them profiled by the NYPD. Though it is telling by itself that 5 years into the CIA-on-the-Hudson program, they apparently hadn’t been, yet. That is, the NYPD doesn’t appear to have been pursuing terrorist organizations in general. (Indeed, it did not include Colombians–who might be of interest because of terrorist organizations FARC and AUC–among its ancestries of interest.)

But in spite of the fact that according to the NYPD, the MEK doesn’t pose a threat, it does appear to have included the MEK in their Iranian profiling. Among its recommended actions, it suggests,

  • Expand and focus intelligence collection at locations affiliated with the MEK.
  • Identify leads with subjects or locations having ties to Hamas, Hezbollah, PIJ, MEK, or the Alavi Foundation.

An excellent use of taxpayer dollars!

Granted, this document was written in 2006, so the NYPD’s profiling priorities may have been improved in the interim six years. But I wonder. When such prominent New Yorkers as Michael Mukasey and Rudy Giuliani joined the MEK speaking tour (technically committing material support for terrorism under Holder v. HLP) did the NYPD start collecting intelligence on them, too?

In any case, the NYPD’s belated decision to profile a designated terrorist organization at the time when they were deemed not to pose a threat sure embodies the kind if idiotic decisions that appear to lie behind the CIA-on-the-Hudson’s intelligence program.

Michael Mukasey’s Torture Apologies

After the Osama bin Laden killing, Michael Mukasey rather shamelessly took the lead in claiming torture had some role in finding OBL.

I thought then that the sheer volume of the torture apologists’ wails suggested that John Durham’s torture investigation might actually move forward in some way.

But I was particularly struck by Mukasey’s prominence. Unlike most of the other torture apologists, Mukasey was not complicit with the torture itself, but merely with the cover-up.

With that in mind, I wanted to return to the discussion in Mukasey and Mark Filip’s letter on the OPR report, particularly their argument against the OPR report’s recommendation that DOJ review the prosecution declinations.It’s interesting, first of all, because Mukasey and Filip initially lump the recommendation for review in among the list of issues they claim OPR has made errors on.

Nonetheless, we are concerned that the current proposed findings of professional misconduct, recommendation for reconsideration of prosecutorial declinations, and request that the Department review certain memoranda signed by Steven Bradbury, are based on factual errors, legal analysis by commentators and scholars with unstated potential biases, unsupported speculation about the motives of Messrs. Bybee and Y00, and a misunderstanding of certain significant Department of Justice and Executive Branch interagency practices.

But in their section on the recommendation for review, Mukasey and Filip don’t describe any errors.

The Draft Report recommends that “the Department reexamine certain declinations of prosecution regarding incidents of detainee abuse referred to the Departmentby the CIA OIG.” [Id at 9.] As the Draft Report itself recognizes, the question whether to prosecute matters addressed in the CIA OIG report has been addressed independently by two sets of prosecutors, first in the Counterterrorism Section (then located in the Criminal Division) and later in the U.S. Attorney’s Office for the Eastern District of Virginia. In both cases, the declinations were based on a variety of prosecutorial considerations, many of which seemingly would be unaffected by any information in the Draft Report and most of which seemingly would have been known to prosecutors at the time of their decisions. 11 Indeed, prosecutors in the Eastern District of Virginia made their decision to decline prosecution in 2005, well after the 2002 Bybee Memo had been withdrawn by the Department. In addition, if and when OPR’s report is finalized (whether with or without any professional misconduct referrals), the prosecutors could be given access to it, and could re-evaluate their decisions as they saw fit. In light ofthese facts, we believe it is unnecessary for OPR to recommend reconsideration.

Mukasey and Filip do suggest the OPR report might be ignoring the “variety of prosecutorial considerations” that guided the original declination decision. Except they admit that OPR has discussed some of them in its report.

11 Some of these considerations arc discussed in classified portions of the Draft Report.

But aside from that, the opposition to the recommendation to revisit the declination decisions seems to lie in the risk that a different prosecutor–not one of the ones involved in the 2003 or 2005 declinations–would review the cases. Just make the report available, Mukasey and Filip suggest, and let one of the prosecutors who has already wrestled with it choose to read the review and determine whether a reconsideration is merited (never mind the fact that some of the key prosecutors–people like Paul McNulty–were no longer in government).

That by itself is notable.

All the more so considering what happened afterwards: Eric Holder had John Durham, the independent prosecutor that Mukasey himself selected to investigate the torture tape destruction, review the declinations.

All of which makes me wonder whether Mukasey is such a shrill torture apologist not just because he had to agree not to investigate torture to get his swank AG gig. But also because he bears responsibility for picking Durham in the first place.


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We’re always looking for individuals with drive, zest, a real desire to become a better marketer, and to achieve more. Digital marketing is fast-paced and the landscape is forever changing and volatile. If you’re comfortable with change, uncertainty….If you’re flexible and understand how improvisation is the name of that game, we would love to hear from you and learn more about how you may become integrated with our ranks of digital marketing enablers!

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What is Uranium?

Uranium has existed in the earth for billions of years, but until man tried to make an atomic bomb and use atomic energy, most people did not known it existed. Uranium is a metal, an ore, and one, of the haviest elements. Uranium is actually more common in the earth’s surface than mercury or silver. And it  has been found in rich deposits in many different places, including Zaire, Canada, the United States, and Russia.

When you look at clean, pure uranium metal, it is as shiny as silver. But after a few minutes of exposure to air, the uranium surface becomes dull and turns brown. The film that forms is uranium and oxygen—and it serves to protect the metal underneath.

The biggest difference between uranium and other metals is that uranium has natural radioactivity. This means the metal slowly changes by giving off certain rays that come out of the atoms of the uranium they are called alpha, beta, and gamma rays.

By giving off radiation, the uranium atom changes and becomes an other radioactive element. This element in turn changes by giving off more radiation. And this process goes on as long as a radioactive element is left. There are 14 steps in this series. One of the steps produces radium, and the last one produces lead.

After that the series is ended, because lead is not radioactive. To change from uranium to lead in nature takes billions of years. The uranium used in atomic bombs or in reactors for atomic energy is U-235. It is one of the natural forms of uranium, and is called an "isotope". Plutonium which is also used in atomic energy, is a man-made product of uranium.

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Mobile App Development

Hybrid vs Native Mobile App Development, Which is Better?

Hybrid vs Native Mobile App Development

If you are planning to build a mobile app for your business, then you may have come across plenty of options during your preliminary research. And, you find that all the development methods are not the same and you have to different ways to approach development.

Basically, there are categories in mobile app development you can choose for your mobile application- Native App Development, Web App Development, and Hybrid App Development. All these technologies hold intrinsic value and getting too much attention from the developers, but which approach is right for your project?

Depending on your business requirements and budget, the decision of choosing the platform can make or break the success of your mobile app development idea.

Hybrid vs Native

In this article, we will discuss Hybrid vs Native Mobile App Development-

What Is Native App?

Native mobile app development includes building apps for a particular operating system that is accessible from a dedicated app store (App Store or Google Play). If you want to develop a native mobile application for your business, you require objective-c or swift programming language for iOS app development and Java or Kotlin programming language for Android app development.

Google and Apple provide developers with a set of tools, elements and SKD to build platform-specific mobile application. In today’s time, most of the companies or startups prefer native mobile app development because of the advanced features and benefits in comparison of other technologies such as Web or Hybrid.

What Is Hybrid App?

A hybrid app is a software application that helps developers to build a hybrid app using web technologies like HTML, CSS and JavaScript. Basically, this technology combines elements of both native apps and web applications to provide users with a native feel like an app. Thus, Hybrid apps are web applications that can be downloaded from the platform’s app store (Android or iOS) like a native app.

Hybrid apps are deployed in a native container that uses a mobile WebView object. When the app is used, this object displays web content thanks to the use of web technologies (CSS, JavaScript, HTML, HTML5).

Hybrid apps are popular among the developers because this technology allows developers to write code for a mobile app once and can run on multiple platforms. Because hybrid apps add an extra layer between the source code and the target platform, they may perform slightly slower than native or web versions of the same app.

The major differences between Native and Hybrid

  • Native apps build on specific platforms such as iOS or Android, whereas Hybrid apps are built using web technologies like HTML, CSS and JavaScript.
  • The hybrid app runs in webView, while native apps run on iOS and Android devices.
  • In native application development, plugins are used to access the native features of the platform like camera, location, mic etc.
  • A hybrid app can be built for any platform from a single code base.

Advantages of Native App Development

  • Smooth Performance

Applications build using iOS, Android and Window provide smooth performance. Developers use different platforms and programming language to build native applications. So, the developer can provide versions of the application (iOS, Android or Window) to make the application run smoother. Users can experience the performance of that native app they are using.

  • Speed

At a time when the technology is growing at a rapid pace and people tend to have services that are quick and fast. Around 48% of the customers uninstall or stop using an app if it is slow. The ideal loading time for a mobile app is about two seconds. Performance is critical for the success of mobile application that is why businesses or startups prefer native application development.

Thus, mobile applications developed in iOS and Android ensure higher performance and speed. In native mobile application development, developers can integrate a new function to boost the speed of mobile applications.

  • User Experience

What makes mobile application very useful and impressive is its user interface. And, it is a very crucial aspect for a business to stand out. In order to make a mobile app successful, businesses or startups consider impressive and eye-catching user interface to make a good impression among the users.

In native apps, you can provide the same feel and experience with your iOS and Android apps to the users that they want. By understanding the need of your target audience, you can make your app interactive and more engaging.

  • Data Protection & Security

Every large organization carries massive data set and in order to keep them secure or protect, full efficiency of hardware resources are required and it can be possible in Native app development. Developers can build secure native applications to keep data secure.

  • Flexibility

A native application (iOS or Android) offers quick access to its inbuilt functionalities such as GPS, Camera, Contacts, Music and various other features. But in Hybrid app development, you can not add extra features in mobile applications because of the single code app that will be used on multiple devices. But, in native apps, you can integrate everything that you want.

  • Personalization

With so many Android devices available in the market with different screen sizes, only native app development is the way of adjusting the layout on each of them.

With such huge numbers of Android devices available in the market with various screen sizes, just native app development is the method of changing the format on every one of them.

Disadvantages of Native App Development

Development Time

In native apps, you need more time and invest huge money in development as compared to hybrid apps. the design of mobile applications takes too much time in order to make it compatible with various devices such as Android, iPhones, tablets, etc.

Development Cost

However the development cost of a mobile application depends on its requirements and industry type. If you want to develop a native app (Android and iOS) with basic features then you have to invest huge amount for both platforms. You will also require large development teams for development of iOS and Android application.

Advantages of Hybrid App Development

Decreased Cost of Development

You can decrease the cost of app development in Hybrid technology. Due to single code capability, you don’t need to hire any specific mobile app developers (iOS and Android).

Basically hybrid application requires low maintenance as we all know hybrid apps are basically web applications which run on mobile browsers. The code built for hybrid application basically requires less testing, maintenance, etc.

Shorter Time to Market

How rapidly do you need your application to go live? As there is a high rivalry in the market and a similar thought being pitched by more than one business visionary, you need to acquaint your application with the targeted audience as fast as could be expected under the circumstances. In the event that that is the situation, at that point, you ought to go for Hybrid App.

Disadvantages of Hybrid App Development

  • Performance

Hybrid applications include an additional layer between the source code and mobile app platform, even more especially the hybrid mobile framework. It can bring about loss of execution yet it changes from application to application. Founder of Facebook- Mark Zuckerberg also has faced the biggest mistake that made the company batting on HTML5 over native. The company migrated its app from HTML5 to a native application, which is clearly showing the difference as far as enterprise applications are concerned.

  • Debugging

The additional layer from hybrid development framework makes troubleshooting a greater undertaking. Engineers need to depend on the structure itself to play pleasantly with the focused on working framework without presenting any new bugs in the application.

  • User Experience

As compared to native app development, in hybrid applications, it is hard to keep maintain the user interface between the Android and iOS app. If you focus more on iOS, the user experience would worsen for Android users.

We have come to the conclusion of this native and hybrid app development, both the technologies have their own specialities which make them best in its class. Hybrid app development is the best technology for those who want to develop minimum viable products in less time and with less budget, while native apps are suitable for products that require flawless performance and custom features.

Ajay Goyal
About author

Ajay Goyal is the founder of Endive Software, is the leading IT Company based on India. He works dedicatedly with the clients to give industry-based results. His passion for learning the trending technology aids the team members to introduce unique and brainstorming. He runs development services like mobile app development and web development for enterprises and startups.
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The tablet formulation of levothyroxine requires gastric pH in order to dissolve and be appropriately absorbed by the intestine. Interference from other treatments such as proton-pump inhibitors, however, may prevent proper absorption.

Recently, new levothyroxine formulations have been developed, some of which are now available in some countries. One such new formulation is a liquid oral solution that does not require dissolution for absorption.

To determine whether the liquid oral solution prevents the malabsorption caused by proton-pump inhibitors, researchers evaluated outcomes in patients before or after switching from the tablet to liquid formulation.

Their results provide insight into the potential of novel levothyroxine formulations in improving patient outcomes.

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Noise standards for mini-wind turbines

Micro-wind turbines will not be made permitted developments - which don’t require planning permission -until the industry develops standards for noise and vibration.

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Caffeine And Your Recovery

I will be writing this post a bit different from my other ones. Normally I already know what science supports and then look up the finite details to write a post. This time you will follow me from hypothesis to conclusion [this will just be the short version].

Caffeine decreases the bodies ability to heal during an injury, muscular or tendon, due to it's vasocinstrictive properties. By decreasing flow of nutrients the injury will receive less of what it needs for healing. A decrease in Oxygen can lead to secondary hypoxia. This is more crucial within the first 48 hours of inflammation and healing.

Caffeine is a white, bitter crystalline alkaloid derived from coffee or tea. It belongs to a class of compounds called xanthines, its chemical formula being 1,3,7-trimethylxanthine. Caffeine is classified together with cocaine and amphetamines as an analeptic, or central nervous system stimulant[1].

When the caffeine reaches the brain , it increases the secretion of norepinephrine, a neurotransmitter that is associated with the so-called fight or flight stress response. The rise in norepinephrine levels and the increased activity of the neurons, or nerve cells, in many other areas of the brain helps to explain why the symptoms of caffeine intoxication resemble the symptoms of a panic attack .

One research study conducted found that when caffeine was consumed there was significant vasoconstriction and mean arterial pressure increase (MAP) [2]. As stated above vasoconstriction may inhibit the bodies ability to heal early on with injuries.

Pressure. When pressure at the wound site is excessive or sustained, the blood supply to the capillary network may be disrupted. This impedes blood flow to the surrounding tissue and delays healing.[3]

If two plus two equals four, then caffeine causing increased vasoconstriction plus increased blood pressure causing disrupted blood flow equals delayed healing. However, I could not find isolated evidence of this pertaining towards large muscle groups or tendons.

Hypoxia is the deficiency of oxygen reaching tissue. I found that one study conducted on pregnant woman showed that caffeine consumption lead to hypoxia of the infant [4] This is probably the reason why woman shouldn't drink caffeine when they're pregnant. We also know that caffeine does not have to be broken down in the gut and can pass the blood placenta membrane. In theory, and this may be a bit of a leap, intake of caffeine within the crucial 48 hour healing period of an injury can result in increased hypoxia to the damaged area.

Of the two area's of recovery we discussed, the conclusions were similar to the hypothesis claim. By having increased consumption of caffeine around the time of an injury can result in delayed and impaired healing.

Do I like these results? No of course not, I use caffeine to muscle my way through college. Based on the above it seems we should avoid caffeine for a few days within an injury. This is not finite in any way because I saw no research completely backing this claim. If you have any malice towards my claim then please comment below. Maybe you have your own hypothesis but lack a college funded database to research on. Comment that below too. [raises coffee cup] A toast to the pursuit of knowledge.

  1. Frey, Rebecca J. (2003) Gale Encyclopedia of Mental Disorders
  2. Terai NSpoerl EPillunat LEStodtmeister R. (2012) The effect of caffeine on retinal vessel diameter in young healthy subjects.
  3. Hess CT. Clinical Guide to Skin and Wound Care. 6th ed. Philadelphia, PA: Lippincott Williams & Wilkins; 2008
  4. Momoi NTinney JPKeller BBTobita K. (2012) Maternal hypoxia and caffeine exposure depress fetal cardiovascular function during primary organogenesis.

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About Me

My photo
BS, MS - exercise Physiology
EPC - Board Certified Exercise Physiologist

Published Thesis
The impact of three different forms of warm up on performance

The Effects of Glucose Supplementation on Barbell Velocity and Fatiguability in Weightlifting - A pilot study"

The Accute Effects Of Different Squat Intensities on Vertical Jump Performances
The Accute Effects of Different Squat Intensities On Jump Performance

Graduate from Midwestern State University, founder of Endunamoo Barbell Club, and Endunamoo Strength and Conditioning. Working to help athletes physically reach their goals and achieve scholarships while spiritually pouring into as many people as possible on all platforms.


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The Evolution of Paleo is a Revolution

With bullets and canon fire America clenched its fist and punched Britain in its smug face. The British Kingdom’s pompous attitude and blind-religiosity lead to a self-evaluation by the colonist. However, after all the smoke cleared not a whole lot changed within the nation. Sure, a new government was founded, but the way people acted wasn’t really altered. When the fire of a revolution is lit the people aren’t looking to turn 180 on who they are. Normally, a revolution is enacted to change a particular belief or system of doing things.

So when I say that the evolution of paleo is a revolution, I mean that there is a religious cult in the paleo circle that needs to be excommunicated like a demon spirit.

When my fiancé posted a picture of a bunch of baked goods she made the other day, she labeled it as paleo. Unfortunately, the desserts where slammed as “not actually paleo” for containing potatoes and milk.
The not-masked bandit of paleo conformity has struck again. I have nothing against sticking to your guns and not drifting from your goals, but to turn it into an act of worship and cult following is ridiculous. I see only one being worthy of worship, and it’s not Paleo (Deut. 4:39).
and they were delicious

The best way to kill a tree is also the best way to address a problem, at its roots. Paleo has created the common motto, “eat like the cavemen would.” Like your typical bible verse, this has been taken out of context and twisted into meaning something it was never intended to. Eat like a caveman simply illustrates the idea that we should eat a less processed more meat and veggie diet. That’s it. Unfortunately, briefly educated pseudo-experts claim that humans have not adapted to the current foods, and thus we should all eat like Paleolithic early humans. This is an over-simplified and under-evaluated system of thinking that has stricken crossfit boxes like the black plague.

Paleo has evolved. It no longer stands for the ideals of “eating like a caveman.” Paleo is about reducing gut irritation, inflammation, and improving mineral absorption and immune function. If you’ve even glanced at my e-book “Spear & Spoon” you’ll see that I addressed why many foods are bad. Foods that contain gluten and high levels of phytates and lectins are more dangerous for the gut than a lumber factory is to the Amazon jungle.

Paleoers recognize that many grains contain gluten, phytates, and lectins. To them, the math is simple; two plus two equals don’t ever eat that stuff. So when new paleoers have been indoctrinated into the religion, they perform a mass exodus of grains into their trash can. However, not all grains contain gluten and not all grains have substantially high levels of phytates and lectins. Steel cut oats and rice are just two grains that should be paleo. Yet if anyone claims to eat paleo while downing some morning oatmeal they will be ostracized as sacrilegious.

Some people are pretty hardcore though. I’ve been informed by some paleo professionals that any toxin, such as phytates or lectins, should be completely avoided. So they dress in their organic holy garments and sprinkle coconut water on the sinners who eat potatoes, dairy, and grains.

Yet I find it funny how no-one addresses the issue of vegetables. Natures green ground vitamins have adapted to survive over-consumption by developing their own system of toxins. In fact, organic vegetables contain more natural toxins than their non-organic counterparts. The crops that we see today have derived poisons that kill certain insects and animals, and every day I scarf down a big bowl of them. It may sound crazy, but sometimes the benefits outweigh the cost.

Lifting weights, especially heavy, is a very costly and taxing thing to put the body through. During every rep a muscle is broken down with micro tears that will require vast amounts of amino acids and glucose to rebuild. But many people understand the benefits to lifting outweigh the costs. The same principle can be applied to diet and nutrition.

So here I stand waving my red flag of revolution. Unlike many popular and paleo hating websites, I’m not asking anyone to stop the diet. I’m asking most people to revolt. Keep the good of paleo and ditch the religious. Don’t be a captive to the overly-aggressive paleo Pharisees, but be a critical thinker. Eating paleo may require a change in your lifestyle, but paleo should NEVER be your lifestyle.

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About Me

My photo
BS, MS - exercise Physiology
EPC - Board Certified Exercise Physiologist

Published Thesis
The impact of three different forms of warm up on performance

The Effects of Glucose Supplementation on Barbell Velocity and Fatiguability in Weightlifting - A pilot study"

The Accute Effects Of Different Squat Intensities on Vertical Jump Performances
The Accute Effects of Different Squat Intensities On Jump Performance

Graduate from Midwestern State University, founder of Endunamoo Barbell Club, and Endunamoo Strength and Conditioning. Working to help athletes physically reach their goals and achieve scholarships while spiritually pouring into as many people as possible on all platforms.


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Talk SIPs to Me. A Glossary of SIP-Related Words and Phrases

Posted by Roberta Bartel on July 27, 2020

Like all industries, the construction industry (and, in particular, SIP construction) seems to have its unique language. Some of the products and components we use and produce are unique.  While those of us who work in the SIPs industry are familiar with the terms and acronyms, they may be new to you.

This SIP glossary will help you to be able to talk the talk and avoid possible misunderstandings.

sausage tube and SIP-Seal gunAcoustical Sealant: A tar-like substance compatible with polystyrene and OSB that retains flexibility for a long period of time used to minimize air leakage at panel seams and joints. With Enercept SIPs you will receive "sausage" tubes of sealant and special "SIP-seal" applicator gun. See photo to the right.

Adhesive: Any adhesive compatible with polystyrene.

Basement Panels:  SIP panels constructed with a treated plywood exterior and treated 2x dimensional lumber on 12" or 16" centers. It is used in below-grade applications.

beam pocket

Beam Bracket: A T-shaped steel strap which fastens the king post to the center beam.

Beam Hangar:  Welded steel bracket typically used to attach beams to other beams.

Beam Pocket:  A factory-cut opening that holds the support beam in place.

Block & String Alignment: An accepted carpentry technique used to assure proper alignment. Spacer blocks hold taut string a given distance from the surface to be aligned. Serves as a reference point for measuring parallelism between line and surface.

Center Support Beam:  A factory-constructed beam that supports the upper end of the roof panels over long, open spans.

Center Wall:  Site-built wall used to support the upper end of the roof panels.

Chimney Collar: Doughnut-shaped metal flashings designed to fit the circumference of the chimney, and provide for a minimum 3" clearance between chimney and combustible structural members. Noncombustible insulation, e.g. vermiculite or rock wool, must be used to totally fill the 3" void before applying the upper collar.

Fly By Corner panelCorner Adjustment Panel: Panel which is designed to be more easily trimmed to compensate for any growth that may have occurred during erection of the wall panels. Sometimes referred to as a "fly-by corner."

Electrical Channels or Chases: Factory-located passageways at the edge of each panel, beside each opening, and 16" above the lower edge of wall panels used for electrical wiring. Electrical chases can be installed above counter top height in kitchens and bathrooms. Basement panels only contain vertical chases at the edge of each panel. Foundation panels do not contain electrical chases. For additional information, see Enercept Electrical Guide.

EPS: Expanded polystyrene, the insulating core of the Enercept components.

EPS Wedge: Roof to wall angled EPS foam wedge placed on top of wall where the roof meets the top of the sidewall to insulate wedge shaped space.

Foam Sealant Insulation: Commercially available polyurethane foam packaged in aerosol cans. Used for filling voids around windows and door openings, exterior electrical passages, and roof-to-wall area.

Growth:Joint spacing can slightly effect the exact measurements of panels. Therefore,
finished lengths of SIP walls or roofs can vary slightly. Installation crews must check center line measurements. Unchecked growth can slightly change rough opening locations. Management of growth in gable walls is critical since beam pocket
location is very important.

Insulated Post: A patented thermally insulated connecting spline ( or post) made from (2) 2x members and EPS, which is used to easily join panels together.

Left: Direction as viewed from the interior of the home.

Lintel:  A narrow panel positioned above a window or door opening.

LVL: Laminated Veneered Lumber, 2x type material manufactured similarly to plywood. Stronger than traditional 2Xs.

OSB: Oriented Strand Board. A composite wood-based panel made from new-growth timber. The strands are oriented or arranged so maximum strength is achieved in any given direction when combined with adhesives to produce greater tension and compression performance.

Overhang: The part of the roof extending past the exterior wall.

Plate: Dimensional lumber, usually 2x6, installed in the top, bottom, and edges of the Enercept Panels.

Plumb: Perpendicular to the horizon. At a right angle to the level floor.

Right: Direction as viewed from the interior of the home.

SIP seam tapeSIP Seam Tape: An adhesive tape designed to be applied to the interior seams of exterior wall and roof SIPs. The purpose is to minimize moist interior air from escaping through panel seams.

Sill Plate: Dimensional lumber, usually 2x6, which is nailed to the subfloor and deck.

SIP:  Structural Insulated Panel.  A manufactured, high performance building system for all types of construction. Used to form the exterior shell of a building.

Now, you are ready to talk SIPs to me!

SIPS 101

Topics: SIP Home, building systems, Structural Insulated Panels


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It's a very interesting debate - how much physical activity is required to achieve or retain good health?  It's a bit of a conundrum what to say in answer to this because the answer - at least according to the scientists and therefore the Chief Medical Officer - is not at all simple.  And of course simple is pretty much what we need.  Everyone knows how much fruit and veg you should eat to maintain good health - and it's a similar 'simple bite size chunk' of a message that's required for physical activity too.  But so far we haven't managed this.

Ok - let’s start with the science - then I'll give my view on why we need something different.  The Chief Medical Officer tells us first that it depends on our age - which makes sense.  They go on then to describe how the suitable lengths of time to be active might vary dependent on the intensity too - so if your physical activity is more intense clearly you don't need to be active for quite so long.  And then they throw that extra curve ball into the equation - that strength and balance activities are also required especially as you get older.  Blimey and to cap it all off they have now added into the equation the requirement not to sit down for extended periods.

It's all a bit mind boggling isn't it?  There are now actually specific guidelines for toddlers (under 5's - both babies and those that can walk), children 5-18yrs, adults 19-64yrs and over 65.  If you're really interested I've copied the link here  But the point is that all this information and guidance is not making a jot of a difference - I wonder why?

Here's a theory - call it my theory if you like - it's really just a thought having read quite a bit on the subject of exercise and physical activity.  Essentially I think Homo sapiens have now developed from a time when physical activity was an essential element of life in order to be able to survive to the point where it is almost thought of as a luxury.  Most of our thinking about physical exercise today lumps it into exercise - i.e. going to the gym, playing sport, going for a run, doing yoga, swimming etc.  We are fast becoming what a professor in exercise and health I know would describe as 'exercise couch potatoes'.  i.e. we are largely inactive and sedentary - at home, at work and while travelling but some of us occasionally have bouts of exertion to try to counter this.  It's clearly a luxury as the evidence shows that with poverty comes great sloth and the greater likelihood that you will just be a 'couch potato'.   Also, again as my professor in exercise and health would remind me, 'exercise couch potatoes' may only live slightly longer than 'couch potatoes'.  Increased evidence from around the world suggests that exercise on its own is not that much more beneficial.

Ok - I hear you say - what IS the answer?  What should be the message/s be that we should remember and remind ourselves, our children and our ageing grandparents?  It's simple really - try to sit less, move more and incorporate physical activity into your daily life.  If you crack this not only will you improve your physical health - amongst others you'll be 40% less likely to contract diabetes and 35% less likely to suffer from cardio vascular disease - you will also improve your mental wellbeing and outlook on life.  But I don't need to tell you this - you knew that anyway didn't you?