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The legislative history of FIFA's transfer rules & the cases that transformed the system

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One of the most important pieces of sport legislation is FIFA's Regulations on the Status and Transfer of Players (RSTP). The regulations establish rules in relation to the international transfer of players, the status of players, their eligibility to participate in organised football, as well as the release of players for association teams and the players' eligibility to play for those teams. Notwithstanding that, the rules are also relevant with regards to domestic transfers, between two clubs within the same association, as although the domestic association provides their own rules, those rules must take into account binding provisions of RSTP and FIFA's principles.

For the purposes of this post, the writer will focus on the history of the regulations concerning the international transfer of players - that is the transfer of players between two clubs that are members of different associations - and the landmark case law that transformed those rules.

Case law discussed:

  • Union Royale Belge des Societes de Football Association ASBL v Jean-Marc Bosman
  • Olympique Lyonnais v Olivier Bernard & Newcastle United FC
  • SV Wilhelmshaven v Club Atletico Excursionistas & Club Atletico River Plate
  • AJ Auxerre v AS Roma & Phillipe Mexes and AS Roma v FIFA
  • Heart of Midlothian v Andy Webster & Wigan Athletic FC
  • FC Shakhtar Donetsk v Matuzalem Francelino da Silva & Real Zaragoza SAD & FIFA
  • Panathinaikos FC v Sotirios Kyrgiakos
  • Club Atletico Penarol v Carlos Suarez & Cristian Rodriguez & Paris Saint-Germain

Early 1990s

FIFA introduced its first transfer regulations in April 1991 and by 1994, the re-named 'Regulations on the Status and Transfer of Players' applied to all participants in international football. The Regulations stated that a football player was only free to move to another club if his employment contract with his current club had expired or was due to do so within the coming six months. The rules also allowed for transfer compensation to be paid to the selling club, despite the fact that the contract had expired.

During this period, FIFA was the only international football body able to establish rules and give decisions in relation to the transfer of players. The governing body enjoyed an exclusive position of power and did not have to take any other organisation into account, when making decisions.

This came to an end, however, when the judgement in the landmark case of Bosman was given by the Court of Justice of the European Union (CJEU), in December 1995. Following the judgement, the European Commission held that FIFA's 1994 Regulations would have to be amended as their current format infringed EU and national law.[1]

Image source: Daily Mail

The Bosman case had a huge impact on the footballing world and remains the most significant legal case in modern football.

Bosman was employed as a professional footballer by RC Liege who, in 1990, offered him a new one year contract. That offer was rejected by Bosman and as a result he was put on the transfer list at a staggering fee of BFr11,743,000. The fee was justified by the RBFA as being compensation for the training provided to the player, a figure which was calculated based on Bosman's previous year's salary and in accordance with the transfer regulations. The fee was so large that no club was prepared to pay it but Bosman was able to negotiate a move to US Dunkerque. Thereafter, Dunkerque had the option to secure a permanent transfer by paying an additional BFr 4.8m to Liege, however, Liege failed to request the necessary international clearance certificate, as a result of concerns about Dunkerque's solvency, and thus the contracts lapsed which left Bosman unemployed.

Bosman sued Liege and the RBFA citing that the transfer system, as operated in Belgium and sanctioned by UEFA, was in breach of Art. 45 as it restricted him from being able to take up employment in another member state. Further, he also argued that UEFA's '3+2' Rule was also in breach of Art. 45. That rule had been introduced while the Bosman litigation was underway and prevented a club from fielding more than 3 players who were eligible to play international football for a national association other than the one in which their club was based. Bosman argued that this rule effectively limited the number of non-Belgium clubs that he could join as many would have already reached their foreign quota and therefore be unable to employ him. This, therefore, restricted his ability to work freely throughout the EU which was in breach of Art. 45.

The case was referred to the Court of Justice of the European Union (CJEU) who had to determine whether Art. 45 could be interpreted prohibiting a football club from requiring and receiving payment of a sum of money upon the engagement of one of its players, who has come to the end of his contract, by a new employing club;

The Court held that the demanding of a transfer fee by a former employer, after a fixed term contract had come to an end, was an obstacle to the freedom of movement for workers as it hindered and potentially prevented a footballer's ability to move to a new club. The rules were thus unlawful unless it could be proven that they were necessary and proportionate to achieve a legitimate outcome.

Two main reasons for the rules, in their current stance, were put forward by the Belgian Football Association:

  1. The rules helped to maintain financial and sporting equilibrium among clubs - This was accepted by the CJEU as a legitimate aim but the Court did not consider that the transfer system was a suitable means to go about achieving that aim.  The Court was of the view that the system did not prevent the richest of clubs securing the services of the best players nor could it restrict their commercial activities to the extent that it created a financial level playing field.
  2. The transfer fees took into account compensation for the costs incurred by a club in training the player - Again the CJEU accepted that this was a legitimate aim but there was no relationship between the compensation fee calculated and the actual outlays incurred in training the player. The Court referred to the fact that the compensation calculated was based on the player's previous salary and not the costs incurred by the club in training him.

As a result, the Court held that a rule that imposes a transfer, training or development fee to allow an out-of-contract player to move to a new club is prohibited by Art. 45 as it is working directly against the freedom of movement of workers.

As a result of the Bosman case, the CJEU found FIFA's transfer system to be incompatible with EU law. The CJEU stressed that sport, just like any other economic activity, is subject to the rules of EU law and football associations are obliged to comply with fundamental principles of EU law such as the freedom of movement of workers, within Europe. It is as a result of this ruling that transfer fees can no longer be charged for out-of-contract players.

Post-Bosman Regulations

Image source: Fieldoo

Following the CJEU decision, football clubs, around the world, responded with panic at the thought of their players being able to reach the end of their contracts and then leaving for free. This resulted in clubs negotiating contracts for longer periods and drafting clauses to allow them to secure compensation for their loss but also to unilaterally reserve the right to extend any agreements, if they so wished. Further, clubs also responded to the ruling by asking for significant transfer fees in the event that a player wanted to leave prior to his contract expiring. This turn of events created a situation which we are all familiar with today whereby the larger clubs attract the top talent and the smaller clubs struggle financially.

FIFA was forced to find a solution to the problem that had arisen and revise its rules that had been seriously affected, following Bosman. The goal was to bring the Regulations into line with EU law. FIFA began drafting new Regulations to replace the existing 1994 Regulations on the Status and Transfer of Players (RSTP). The new version was sent the European Commission (EC) in 1997 but those were rejected by the EC as it had serious concerns in relation to the Regulations allowing the transfer of players under the age of 18 and the fact that there was no right to seek redress from the civil courts.

Given this, FIFA began to work in partnership with the EC in order to gain a better understanding of what they needed to do to bring the Regulations into line with EU law. The EC advised that the Regulations were free to contain provisions regarding the transfer of players, contractual stability and training compensation for players but they must comply fully with EU regulations. The Regulations could not prevent parties from seeking redress from the civil courts and they could not ignore national laws of the countries concerned. Following discussions and various amendments, the new approved Regulations came into force on 01 September 2001.[2]

2001 Edition
  • Guaranteed contractual stability of player contracts
  • Regulated international transfer of minors
  • Contract periods implemented - Minimum of 1 year and Maximum of 5 years
  • Introduction of two transfer registration periods - Winter and Summer
  • Gave rise to FIFA's Dispute Resolution Chamber (DRC)
  • Introduced provisions that regulated compensation to be paid by clubs for the training and education of young players.

FIFA's RSTP are amended regularly, to take into account current market issues, and there have been various editions released since the 2001 Edition.

2005 Edition
  • More of an adjustment than new rules
  • Revised to take into account a more "user-friendly structure"
  • DRC judge introduced
  • 5 Technical Annexes included
  • List of current definitions

2008 Edition
  • Linguistic amendments
  • Article 18bis implemented - No club shall enter into a contract which enables another party to that contract or any third party to acquire the ability to influence employment and transfer related matters, its independence, its policies or the performance of its teams - FIFA Disciplinary Committee is given power to impose disciplinary measures on clubs that do not observe the obligations set out in said Article.

2009 Edition
  • Sub-Committee of Players's Status Committee appointed and charged with examination and approal of every international transfer of minors, and every first registration of a minor player who is not a national of the country in which he wishes to be registered for the first time.
  • New Annex 2 regulating administrative procedure governing the applications for a first registration and the international transfer of minors.
  • Slight changes to calculation of training compensation with implementation of an 'exception to the exception' rule.

2010 Edition
  • Introduction of FIFA Transfer Matching System (TMS) - more on that here

2012 Edition
  • Better control by FIFA Disciplinary Committee
  • Amendments regarding sporting sanctions, jurisdiction of the DRC and registrations of new players only being allowed when sanctions are served
  • Provisional registration days reduce from 30 days to 15 days, following a request for ITC

2014 Edition
  • Amendments regarding the release of male professional players to association teams
  • The 'exception to the exception' rule, that was implemented in relation to training compensation in the 2009 edition, is removed.

2015 Edition
  • New provisions are implemented concerning third party ownership of players' economic rights as well as third party influences on clubs
  • Amendments are made concerning the transfer of minors and reducing the age limit, for which an ITC is required, up to the age of 10.
  • Article 12bis is implemented concerning overdue payables
  • Further amendments are made in relation to FIFA's DRC
  • New Annex 6 is inserted which covers training compensation, solidarity mechanism and claims through FIFA TMS

2016 Edition
  • Amendments made in relation to the release of players to association teams
  • Amendments made in relation to the protection of minors with implementation of the five year rule

The Cases

Training compensation

Bernard case (2010)
Image source: CNN

Bernard was a young football player who played for Olympique Lyonnais "espoirs" team and was offered a one year professional contract. Bernard refused the contract and concluded a contract of the same terms with Newcastle United. This move was in direct contrast to the terms of the Charter for "jouers espoirs", applicable in France, and which states that Bernard was required to sign his first professional contract with the club that had trained him. Failure to do so, will result in compensation being owed to the training club.

As a result Olympique commenced legal proceedings against Bernard and Newcastle United, seeking an award of damages equivalent to the remuneration that the player would have received over one year, had he signed the contract proposed to him by Olympique €53,357.16.

The case was heard at an Employment Tribunal in Lyon and that came to the decision that Bernard had unilaterally terminated his contract and ordered Bernard and Newcastle United jointly to pay Olympique €22,867.35. This was appealed and the Cour d'Appel in Lyon came to the view that the obligation on a player at the end of his training , to sign a professional contract with a club that had provided the training, and that also prohibited the player from signing such a contract with a club in another member state of the EU, was an infringement of the freedom of movement of workers, a fundamental EU principle.

Not happy with the decision, Olympique appealed to The Court of Cassation, the final Court of Appeal in France. The Court referred questions to the CJEU on the extent of the principle of freedom of movement for workers and the possible restrictions which national provisions can impose in circumstances like Bernard.

The CJEU held that the Charter, although it was a restriction on free movement, it was justified because it encouraged clubs to train young players and this was a legitimate aim. However, the Court did state that a rule may infringe freedom of movement if "they preclude or deter a national of one Member State from exercising his right to freedom of movement in another Member State, even if they apply without regard to the nationality of the workers concerned, unless the potential impediment to the exercise of free movement is too uncertain and indirect."

In the Bernard case, the CJEU recognised that the sum Olympique Lyonnais was seeking did not reflect the costs of training but was instead related to damages for the loss suffered. The CJEU stated that the compensation provided for must be calculated on the actual costs borne by the club in the training of the player. Payment of damages which are calculated not in relation to actual costs but instead reflect the total loss suffered by the club, go beyond what is necessary to encourage the recruitment and training of young players and cannot therefore be justified.

As you can see, the Bernard case is important because it establishes that although the charter restricted freedom of movement, it had a legitimate aim for doing so, and was therefore allowed. However, The CJEU put a stop to clubs calculating disproportionate sums as training compensation and clubs now have to reflect the actual costs only.

Wilhelmshaven case (2016)
Image source: NDR.de

Sergio Sagarzazu, has dual nationality as both Italian and Argentinian. He was registered as an amateur player with Argentinian clubs Excursionistas and River Plate. The player, thereafter, transferred to the German professional football club, SV Wilhelmshaven, where he signed his first professional contract from 08 February 2007 to 30 June 2007. The contract was then extended for another season.

Both Excursionistas and River Plate claimed they were entitled to receive training compensation but this was rejected by SV Wilhelmshaven. As a result both Argentinian clubs submitted claims to FIFA's DRC.

on 05 December 2008, the DRC ordered SV Wilhemshaven to pay Excursionistas €100,000 and River €57,500, in training compensation. The German club disagreed with the decision and submitted a claim to the Court of Arbitration for Sport (CAS). The CAS gave its decision on 05 October 2009 confirming the decision of FIFA's DRC and rejected the objections raised by SV Wilhelmshaven.

SV Wilhemshaven still refused to pay the compensation now ordered by both FIFA and the CAS. As a result, the FIFA Disciplinary Committee sanctioned SV Wilhelmshaven with additional fines, stating that if they were not paid within 30 days, the German club would face a deduction of 6 points. The club still refused to pay and the 6 point deduction was imposed. Thereafter, the club still refused to pay the fines and training compensation, and a further 6 points was deducted. The club was also relegated by the domestic association following a FIFA order.

In May 2013, SV Wilhemshaven began legal proceedings to challenge the decision in the German courts. The initial case was heard before the Landgericht Bremen, however, the court rejected the claims of the club who then appealed before the Highest Regional Court, who held that the CAS award was contradictory to EU law.

SV Wilhemshaven's arguments was that FIFA RSTP was contradictory to EU law and in particular, the free movement of workers. Sagarzazu also had Italian nationality and as a result, the German club was of the opinion that the Argentinian clubs were obliged to offer him a contract (in accordance with Article 6, para 3 of Annex 4 RSTP). As they failed to do so, the club was of the opinion that the Argentinian clubs were not entitled to training compensation.

The CAS arbitrator considered that Article 6 of Annex 4 RSTP only applied when the transfer occurs within the EU/EEA territory. Thus, given that Argentina is not within the EU, the CAS arbitrator was of the opinion that the provision did not apply where the player moves from a country outside the EU/EEA to a country within the EU/EEA, regardless of their nationality.

The Highest Regional Court did not agree with the CAS sole arbitrator's opinion and considered that Article 6 of Annex 4 should apply to persons with EU nationality moving from a non-EU country to an EU country. As far as it was concerned, if that was not the case, then FIFA's system of training compensation was contradictory to EU law, when it concerned an EU nationality transferring from a non-EU club to an EU club.

The case was then appealed again to the highest German civil court, the Bundesgerichtshof (BGH) who, in September 2016, upheld the Regional Court's opinion, ruling in favour of SV Wilhelmshaven. The Court also held that the Northern German Football Federation's (NGFF) statutes were not adequately clear to allow it to implement the forced relegation, as ordered by FIFA. The statutes also failed to sufficiently provide provisions as to what level of sanctions a club would face if they failed to pay training compensation. This meant that the German club was not in a position to weigh up the risks involved in failing to pay the training compensation.

This latest decision was only made in September 2016 and the effect it will have on domestic associations and FIFA, remains to be seen. However, it is likely that associations will have to go back to the drawing board and amend their statutes with FIFA also taking another look at the RSTP, and in particular the implications for training compensation when an EU nationality player transfers from a non-EU club to an EU club.[3]

Calculating compensation following breach of contract

Mexes case (2005)
Image source: AS Roma

Phillipe Mexes is a French player who, at the age of 15, joined French club Auxerre. On 13 May 1998, Mexes signed a youth contract with Auxerre for a contractual period of five years. On 20 June 2000, Mexes replaced the current contract by signing a professional football player's contract, again for a contractual period of five years.

On 15 December 2002, Auxerre and Mexes agreed to extend the contract by one year, Mexes salary was improved and the Club agreed to pay Mexes a transfer bonus, if he moved to another club. The latter provision was crucial to the dispute that arose, thereafter, between both parties.

During the course of his contract, Mexes asked the club what transfer they would demand if the contract was terminated by mutual agreement. The club did not provide Mexes with a figure and instead, reminded him that he was under contract with the club until 30 June 2006 and they would expect him to satisfy that contractual obligation.

On 24 May 2004, AS Roma advised Auxerre that they were interested in signing Mexes and intended to make an offer. On 04 June 2004, AS Roma made an offer, to Auxerre, of €4,500,000 to secure the Mexes' services. This offer was rejected by Auxerre who advised AS Roma that the sum was considerably lower than their valuation of Mexes. They added that the player would remain under contract with them until 30 June 2006.

On 11 June 2004, Mexes made an appeal to FIFA requesting to be released from his contract on the basis of Article 42 of the FIFA RSTP. Less than 24 hours later, AS Roma and Mexes signed a four year contract commencing from the 2004/05 season.  Auxerre demanded that Mexes attend for training but despite those demands, Mexes failed to show and continued with his plans to continue the next stage of his career with AS Roma.

Auxerre filed a complaint to the FIFA DRC in relation to breach of contract. The DRC upheld the breach of contract complaint and held that Mexes would not be eligible to play for Roma for 6 weeks after the commencement of the Italian Championship. They also imposed monetary sanctions on Mexes and he was ordered to pay Auxerre €8,000,000. The sum was calculated taking into account the higher salary that Mexes would be receiving at AS Roma and that he had received 7 years of training, at Auxerre, a club of which had an excellent reputation for training players. Further to that, the sum also took into account the remaining years that Mexes had left on his contract.

The DRC found AS Roma guilty of inducing the player to breach his contract and thus they were held to be jointly and severally liable for the compensation owed to Auxerre. In a separate hearing, AS Roma was also sanctioned with a transfer ban over two registration periods, for the charge of inducing Mexes to breach his contract.

All parties were unhappy with the decision: (1) Auxerre believed Mexes valuation to be closer to €18,000,000 whilst (2) AS Roma and Mexes were unhappy with the level of compensation they would have to pay and the length of sporting sanction received. The parties appealed to the Court of Arbitration for Sport.

Sporting sanction imposed on Mexes

The CAS required to rule on whether or not Mexes had in fact breached his contract within the "protected period" as it was necessary to determine if sporting sanctions should apply and what level of compensation was due.

The protected period is "a period of three entire seasons or three years, whichever comes first, following the entry into force of a contract, where such contract is concluded prior to the 28th birthday of the professional, or two entire seasons or two years, whichever comes first, following the entry into force of a contract, where such contract is concluded after the 28th birthday of the professional."

The CAS was of the opinion that the protected period had been re-set at the point that Mexes agreed an extension of his playing contract. He had, thus, brought the timing of his breach of contract within the 3-year protected period and as such, the CAS was obliged to impose a sporting sanction on the player and AS Roma.

The 2001 Regulations (that applied at the time of the breach) did not specifically state that the protected period would re-start, in the event that a contract is renewed. However, the panel had to find the ratio legis for the rules which governed the relationship between Mexes and Auxerre. The CAS panel had to consider the intention of FIFA and contractual stability. It referred to both the 2001 Regulations and the 2005 Regulations, in determining FIFA's intentions. The DRC had determined that the player's signature of an extension agreement to their previous contract would re-start the protected period even though this was not provided for in the 2001 Regulations, and it had to be amended in the 2005 Regulations.

FIFA's regulations state that Mexes should have been banned from playing for a four month period and the buying club, AS Roma, should receive a ban from registering players for 2 transfer periods. Despite this, the CAS departed from the regulations and upheld the original six week playing sanction on Mexes, citing the "exceptional circumstances of the case" under Article 23 of the 2001 Regulations. The CAS stated that Auxerre had no interest in the length of playing ban imposed on Mexes, as he was no longer a part of the team and there was a lack of any further legitimate submissions to persuade the panel to impose a lengthier ban.

The "exceptional circumstances" that permitted the CAS panel to reduce the usual sanction, was removed in the 2005 Regulations.

Compensation owed to Auxerre

The main concern for the CAS panel in relation to the level of compensation owed to Auxerre was the fact that the DRC had given no indication as to their method of calculation in determining that Auxerre was owed €8,000,000.

Given that, the panel's main goal was to calculate the level of compensation and explain how they reached that decision:

The panel first looked into the investment that Auxerre had made on Mexes. He had originally signed a five year contract from 2000-2005 but in 2002, signed an extension until the end of 2005/06 season. The extension was viewed as a new four year contract from 2002 - 2006. The panel considered  the difference between Mexes old salary and the new salary, that was coming into play from the date that the extension was signed, until the date in which the contract was terminated in 2004. The panel also took into account the bonus that was paid to Mexes when he signed the extension agreement and the fee paid to his agent, at that time. The effective costs were, thus, calculated by the panel at €2,289,644.

Further to that, the panel then had to take into account the future earnings for the transfer of Mexes that Auxerre lost, due to his breach of contract. The panel, therefore, turned to the only offer on the table, which was from AS Roma, and at the level of €4,500,000. The offer in this case is an important issue as it is used in subsequent breach of contract cases, for determining compensation.

In their submissions to the panel, Auxerre made several comparisons between Mexes and other professionals who had been acquired or transferred by Roma as well as comparisons between Mexes and other professionals who had been acquired by different club's in several positions. The club was, thus, attempting to establish that Mexes was a very valuable asset and in the event that the club were to transfer him, he would merit a fee comparable to other professionals that were mentioned in their submissions. The fees cited by Auxerre ranged from €11.5m to €37.5m.

The CAS panel was of the opinion that Auxerre failed to prove its commercial and sporting damages. It also considered that Auxerre had obstructed Mexes' possibilities to obtain a transfer by refusing to enter into any transfer negotiations with him. The Panel was also of the opinion, however, that AS Roma's offer did not reflect the true value of the player, and that the offer's sole purpose was to induce the termination of Mexes' contract with Auxerre.

The CAS concluded that the compensation to Auxerre would be set at €7,000,000 (€1m less than that imposed by FIFA DRC). That figure comprised of €2,289,644 (costs incurred by Auxerre), €4,500,000 (AS Roma's offer), plus other criteria taken into account by the panel and rounded to €7,000,000.

Roma transfer ban for inducing Mexes breach of contract

The CAS panel determined that, when taking everything into account, AS Roma would receive a transfer ban of one registration period (reducing the ban from from the previous two that FIFA DRC had imposed). Roma had asked for a stay of execution in July 2005 but this was rejected. They asked for another stay, in August 2005, arguing that given that they had received notice from FIFA of the transfer ban on 30 June 2005 but had already signed a number of players that month. Those players were unable to be registered because of the ban. The panel decided that because of those facts, the stay should be granted. This allowed Roma to register the players signed in June but also those up to the end of the transfer window.

There was then a dispute over whether the overall sanction should be reduced to just the one window as they did not have a free month in July 2005 because the original request for a stay had been rejected. The CAS panel accepted this argument and held that July and the first week or so in August would be considered as punishment already served. This was despite the fact that players were being signed in the prior month and during the remainder of August.[4]

This was, thus, a victory for AS Roma.

Webster case (2007)
Image source: Sky Sports

Art. 14 of the FIFA Regulations for the Status and Transfer of Players allow players to unilaterally terminate their contract of employment where there is 'just cause' (a reasonable reason for doing so). There is no standard definition to what constitutes 'just cause' and each case will be assessed on its own merits. Failure to terminate a contract with 'just cause' carries significant penalties with sanctions found under Art. 17 of the FIFA Regulations for the Status and Transfer of Players, which provide for compensation payable to the original employing club where a player breaches their contract without 'just cause', in order to join a new club. The rules also state that any player who signed a contract before the age of 28 can buy himself out of the contract three years after the deal was signed. If he is 28 or older, the time limit is shortened to two years.

The Webster case was based around Articles 14 and 17 and their correct interpretation along with the appropriate approach in determining compensation under Art. 17.

The case concerned Andy Webster, a Heart of Midlothian (Hearts) player, who was under a four year contract with the club, which commenced shortly before his 19th birthday in March 2001. In January 2006, Hearts entered into negotiations with Webster to keep him at the club long-term. Negotiations broke down and there was a dispute with Vladmir Romanov, the majority shareholder of the club. In May 2006, Webster gave notice to Hearts that he was unilaterally terminating his contract on the basis of Article 14 of the FIFA Regulations. Following the termination, Webster signed a new contract with Wigan Athletic. However, Hearts refused to accept the termination and thus refused to co-operate with the transfer to Wigan Athletic.

Webster's termination occurred outside the protected period as Webster had served more than three years of his contract. However, The FIFA DRC held that Webster had breached his contract (on a technicality) and awarded the club £625,000 compensation. This calculation was based on Webster's basic salary, appearance bonuses, former transfer compensation as well as the five years that Webster had spent with the club. Both parties appealed to the Court of Arbitration for Sport (CAS).

The CAS ruled that Art. 17 did not allow a club or player to unilaterally terminate an employment contract without just cause, even if it fell out-with the protected period. As a result, the Court ruled that Hearts were owed compensation. Hearts claimed the market value of Webster was £4m and they should thus receive a similar sum as compensation for lost profit. However, the CAS panel was unequivocal in stating that there was no economic, moral or legal justification for a club to be able to claim the market value of a player as lost profit. The panel also found that Hearts claim of £330,524 based on the difference between the value of the old and new contract was not a suitable way of calculating compensation for breaches of contract that occur outside the protected period.

The CAS panel considered that the most appropriate way of calculating such compensation was to determine the remuneration remaining due to the player under the employment contract upon its date of termination (the residual value of the contract). The panel thus held that the amount of compensation due to Hearts was the sum of £150,000. This was to be paid by Webster and Wigan Athletic, jointly and severally.

Why did the CAS not take into account potential transfer fee, like in Mexes?

Heart of Midlothian did not receive the offer from Wigan until after Webster had breached his contract. This effectively meant that the Scottish club was not suffering any damage because the player and the club no longer had any contractual ties. The club could not accept the offer, therefore it is a fee that they could never have earned, in the circumstances.

In Mexes' case, the offer was received whilst he was still under contract with Auxerre and was, thus, still an asset to the club. Therefore, the CAS panel determined the offer loss as a legitimate loss. The pattern of the offer, and the renewal of the contract with a clause allowing the player to benefit from a portion of any future transfer fee, demonstrated that Auxerre had the intention to sell the player, at one point, and also that other clubs had the will to buy Mexes. No offers had been received for Webster leading up to his breach of contract, therefore the panel concluded that the club would would not be able to earn any money from the player, but for the breach of contract.[5]

The Webster case unsurprisingly drew mixed reactions depending on what side of the fence you are on. FIFA were critical of the decision with former President, Sepp Blatter, stating that it would be generally damaging to the game. Football clubs and domestic associations were also dismayed by the CAS decision as it gave rise to the possibility that players were free to terminate their contracts, after the protected period had expired, by only paying the remaining value as compensation. Players' unions, however, were supportive of the decision stating that it gave players the same employee rights that any other worker would expect to find and awarded a greater freedom of employment.

The panic that had engulfed the football world following Webster was short-lived when the CAS ruled on the Matuzalem case and took a different decision which appears to have set a precedent, with more and more cases following the same line.

Matuzalem case (2008)
Image source: Be Soccer

In this case, Matuzalem, was three years into a five year contract with Shakhtar Donetsk when he unilaterally and without just cause, terminated his contracted with Shakhtar and signed a three year contract with Real Zaragoza. Shakhtar brought an action against both Matuzalem and Zaragoza before Fifa's Dispute Resolution Chamber (DRC) seeking 25m Euros. Fifa's DRC awarded 6.8m Euros which Shakhtar appealed to CAS for a larger award.

CAS ruled that the purpose of Art. 17 was to create greater contractual stability (Art.13) and did not give players the right to unilaterally breach their contracts and move to a new club, whether in or outside of the protected period. Compensation awarded under Art. 17 was to be at a level as to act as a deterrent for breaching contracts. The CAS held that Matuzalem had breached his contract by not reporting for training with Shakhtar and signing a contract with Zaragoza. This was a serious breach of contract for which there must be consequences and Shakhtar was thus owed compensation.

Turning to the level of compensation, the CAS held that the compensation should be calculated in accordance with Art. 17 and not the release clause, as the circumstances in which Matuzalem terminated his contract were not anticipated in the contract. In determining the level of compensation, the CAS held that the value of the player's services to the club, his status and standing , his behaviour and the timing of his departure should be taken into account when calculating the sum payable. That sum should then be reduced by the sum of money that Shakhtar would not have to pay Matuzalem in wages. Compensation was assessed to consider what was necessary to put the club back into the position it would have been in but for the breach of contract. The CAS, thus, awarded 11.9m Euros, in Shakhtar's favour, and that Real Zaragoza were jointly and severally liable for along with Matuzalem.

Although Art,17 has not been challenged under EU law it is likely to be considered as in accordance on the basis that it is an objectively justifiable means of calculating the value to a club of a player who has breached their contract. Effectively, this case helped restore the contractual stability thrown into turmoil by the Webster case whilst bringing an end to cheap buy-out clauses. If a player, today, wishes to terminate his contract early,  he better have deep pockets to meet the compensation that he will be liable for.

The validity of unilateral options to extend contracts

Kyrgiakos case (2005)
Image source: UEFA

In 2001, Kyrgiakos signed a two year contract with Greek side, Panathinaikos FC. The contract also contained two unilateral options giving the club the right to extend Kyrgiakos' contract, initially for a two year period, and then again (if they wished) for one year when the initial two year extension period expired. Kyrgiakos would also be entitled to additional bonuses, under the contract agreement. The contract was registered with the relevant Greek association and was placed under Greek law.

In June 2003, Panathinaikos activated the first of the extensions (a 2 year period), extending Kyrgiakos' contract to June 2005. In January 2005, Kyrgiakos went on loan to Scottish club, Rangers FC, until June 2005. Under the loan agreement, Rangers had the option to sign the player permanently at the end of his loan period but the Scottish club opted not to exercise that option and instead expressed its interest in signing the Kyrgiakos for a lower fee. Panathinaikos, did not accept that, and instead chose to exercise its unilateral option to extend Kyrgiakos' contract for a further year, as per the original contract agreement. This would take Kyrgiakos' contract up to the end of the 2005/6 season.

Kyrgiakos refused to return to the Greek club at the end of his loan period  and claimed that the unilateral option was invalid. As such, FIFA's DRC became involved and reviewed the case, ruling in favour of Kyrgiakos and agreeing that unilateral option was invalid.

In usual fashion, Panathinaikos appealed to the Court of Arbitration for Sport (CAS) who found in the club's favour and fully recognised the validity of the unilateral option. The CAS panel stated that FIFA's RSTP (1997 edition) applied in the first instance and then considered whether national law should apply as an alternative. The panel recognised that the contract was signed in Greece between a Greek individual and a Greek football club concerning footballing activities that were largely taking place in Greece. The contract also referred to Greek law which recognised and legalised the unilateral option to extend the contract of a footballer. Given that the CAS panel considered it inappropriate to apply Swiss law to the contract.

The CAS panel held that Kyrgiakos was in breach of his contract and was thus liable. The panel referred to the fundamental principle "pacta sunt servanda" which translates to the obligation to respect a contract, and they considered that the terms and conditions that were entered into were fair and reasonable. There was no unequal bargaining power between the two parties and the CAS panel also took into account the additional bonus payments that Kyrgiakos was earning, at the point of each extension.

This award raises questions in relation to FIFA's competence and what national law is applicable - it should be noted that FIFA's regulations do not contain any provisions that either allow or prohibit unilateral options to extend contracts. The next case changes the position again, but it should be noted that employment conditions were poorer and there was an international element with Paris Saint-Germain's involvement.[6]

Club Atletico Penarol v Carlos Heber Bueno Suarez & Cristian Gabriel Rodriguez Barrotti & Paris Saint-Germain (2005)
Image source: Foot Mercato

Under the Uruguayan Football Player's Statute, football clubs were authorised to extend player contracts until the second 31 December, following the date of termination of the initial contract. In the event that the contract is signed during the second half of the season, the Statute allowed for the contract to be extended until the third 31 December, following the date of termination.  Given that the Uruguayan season runs from January 1 to December 31, this therefore means that clubs are in a position to extend a player's contract for a further two seasons.

Under the provisions, clubs were obliged to increase the player's salary in line with the national consumer index but were under no obligation to improve better the player's conditions. In the event that the player refused the extension, the statutes allowed for the club to record the player as "rebellious" and withhold the player's wages. The player, thereafter, was only allowed to leave the club when the player's contract expired (also known as the end of the "rebellious" period).

In the above case Suarez and Rodriguez (two Uruguayan nationals) refused to agree to the terms of an extension to their contracts with Uruguayan club, Club Atletico Penarol. The dispute was over a pay increase and other benefits. The club, however, knowing that it was protected by the Statute, failed to negotiate with the two players and when they refused to sign the extension contracts, recorded them as "rebellious" with the Uruguayan Football Federation and withheld their salaries, as per the Statute. The players were unable to sign for another club as they were still under contract until the end of the "rebellious" period (when the contract was due to expire).

After being unable to play for approximately four months and whilst their contracts were still active, the two players signed a contract with French club, Paris Saint-Germain (PSG), commencing season 2005/06. Club Atletico Penarol, thus, filed a claim with FIFA's Dispute Resolution Chamber that alleged that the players had been induced by PSG and thus breached their contract without just cause.

The DRC panel rejected Penarol's claim on the basis that the unilateral option clause was invalid and the Uruguayan club, thereafter, appealed to the Court of Arbitration for Sport (CAS). The CAS, like in the previous case, determined what law should be applied in such cases and also whether or not the players had infringed Article 17 of FIFA RSTP (terminating a contract without just cause).

In determining what law should be applied, the CAS referred to the global nature of sport:

"The panel considers that sport is naturally a transnational phenomenon. It is not only desirable but indispensable that regulations referred to the sport at an international level have a uniform and coherent worldwide character. In order to ensure respect at a worldwide level, such a regulation should not be applicable in a different way from one country to another, due to interferences established by state law or a sporting regulation. The principle of the universality of the application of the FIFA regulations - or of any other international federation - is a need for the legal rationality, security and predictability. All the members of the football family are therefore under the same regulations, which are published. The uniformity that comes from it tends to assure the equality of treatment between all the addresses of such regulations, independently of the countries from which they are...As it has been stated, the aim of the FIFA Regulations is to create uniform regulations that can be valid for all international transfers and in which all the actors of the football family are subject to. This aim would not be reached if all the applicable rules of one or other country had to be applied. It would be inconceivable that such national rules would affect parties that are not subject to the law of a country ... Unless you want to undermine the fundamental aim of the FIFA international Regulations, the agreements and other legal dispositions of national levels can only be applicable if they are in conformity, or at least complementary to the FIFA Regulations, but in no case if they are contrary to those. This necessity of uniform legality is, moreover, one of the most evident "specificities of sport" that article 25.6 of the FIFA Regulations refers to."

I.e. The outcome of two cases that arise in two different jurisdictions should produce the same result and that FIFA's Regulations (which adapts itself to Swiss Law) are applicable to all member states, and not national law. The CAS panel also stated that Swiss International Private Law, allows them to apply a law that is not particular to a specific state but of universal application such as sporting rules, so long as those rules are not in contrast with public policy. Thus, the panel makes it clear that members of FIFA cannot avoid the principles of Swiss Law when resolving disputes.

Turning to the Uruguayan law, the CAS panel raised serious doubts in relation to the rules governing the unilateral option to extend a player's contract and the "rebellion"system, and whether they were compatible with the minimum standards of protection of employees under Swiss Law. The panel would have to refuse any rules that were potentially contrary to public policy and when considering this case, they ruled that a statute that allows a club to unilaterally extend the duration of a player's contract with very little increase to remuneration was incompatible with FIFA's regulations, which state that contracts should have a fixed duration and clearly stipulate salary and other benefits. The CAS panel also concluded that such a clause also infringed the Swiss Code of Obligations and principles of law. Given that, the CAS panel upheld the DRC's decision and held that the players were not contractually bound to Club Atletico Penarol when they signed employment contracts with Paris Saint Germain.

This was an important decision, not only globally in terms of applicable law and unfair contract clauses, but particularly so in South America where associations had failed to adhere to reforms of the FIFA regulations allowing clubs to retain players and block any moves to a different club, even in the event that the player's contract had expired. The case was a trigger for changes in South America and forced associations to consider and begin amending their rules. [7]

What does the future hold?  -  FIFPro's Challenge

Image source: Visions Connected

The current transfer system receives both praise and criticism. Many clubs are of the view that it enables them to plan for a set period of time, with the knowledge of the players they have available to them whilst FIFA has stated that the system allows clubs to invest in the training and education of young players.

On the other hand, FIFPro have heavily criticised the current system and have, in turn, launched a legal challenge, filing a complaint with the European Commission, claiming it to be anti-competitive, unjustified and illegal. The case is currently pending but if successful could see the end of transfer fees.

In the complaint, the players' union states that the current system which encourages large transfer fees stating that it:

"prevents clubs from fairly competing on the market to acquire sporting talent, harming the interests of players, small and medium sized professional teams and their supporters" and that it "fuels and sustains increasing competitive and financial disparity, invites commercial abuse by third party owners and agents and fails to protect players against abuses of their labour contracts via systematic non-payment."

Ultimately, FIFPro argues that the system is anti-competitive because it unfairly discriminates in favour of the bigger clubs, and the solidarity mechanism that was introduced following Bosman, is not effective enough to combat the effect of the status quo. Further, FIFPro also argues that the system restricts the free movement of players (workers) which is a direct infringement of EU law.

Considering FIFPro's argument

Whilst it can be argued that the transfer window restricts the ability of a player to move at his own desire. The justification for the transfer window is to protect the stability of the competition season and the team - and this is a legitimate aim recognised by the European Commission (EC).

The European Court of Justice has previously considered the legality of having fixed transfer windows (albeit in relation to basketball) and stated, in its decision, that team stability and the regularity of the sporting season can justify any restrictions on free movement of workers, and was therefore valid and authorised.

If we consider the example of competitive football and the need for overall stability, it could be argued that allowing late transfers in a season could significantly change the strength of one team over another and, thus, distort the proper functioning of a league season. Another example for restricted transfer windows is that if clubs were able to buy and sell players, throughout the season, it is likely that clubs would buy players with a few games of the season to go from clubs who have nothing to play for, in an attempt to win the league, avoid relegation or even qualify for European competitions. It is for this reason, that the EC allows exceptions for sporting justification and as a result, it is unlikely that the EC will uphold FIFPro's complaint that the transfer window unjustifiably, restricts the free movement of players.

However, it remains to be seen how the EC will consider the other arguments put forward by FIFPro, and in particular in relation to the benefits gained by the larger clubs to the detriment of the smaller ones. However, even at that, the larger clubs are likely to have more commercial might in terms of sponsorships and highly valuable player image rights, that are likely to generate significant more revenue that smaller clubs who do not attract as much commercial revenue. As such, it is likely to be the case that the larger clubs will always be in a position to buy the more expensive players, as a result.[8]

IMPORTANT: This post is not intended to be a legal briefing, it is not intended to be a statement of the law and no action should be taken in reliance on it without specific legal advice.

  1. Frans de Weger, The Jurisprudence of the FIFA Dispute Resolution Chamber, Asser Press (6-7)
  2. Frans de Weger, The Jurisprudence of the FIFA Dispute Resolution Chamber, Asser Press (10-24)
  3. http://www.insideworldfootball.com/2016/09/22/german-court-kicks-fifa-cas-rulings-wilhelmshavens-forced-relegation/
  4. Alexander Wild, CAS and Football: Landmark Cases, Asser Press (Chapter 4.2)
  5. Alexander Wild, CAS and Football: Landmark Cases, Asser Press (54-55)
  6. Alexander Wild, CAS and Football: Landmark Cases, Asser Press (108)
  7. Alexander Wild, CAS and Football: Landmark Cases, Asser Press (116)
  8. http://www.lawinsport.com/articles/item/analysis-of-the-legal-arguments-in-fifpro-s-challenge-to-fifa-s-football-transfer-system?highlight=WyJmaWZwcm8iLCJmaWZwcm8ncyIsIidmaWZwcm8iLCInZmlmcHJvJyIsImNvbXBsYWludCIsImNvbXBsYWludCcsIiwiY29tcGxhaW50J3MiLCInY29tcGxhaW50IiwiZmlmcHJvIGNvbXBsYWludCJd

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Because of the many years of experience built up in the food and pharmaceutical industries and the knowledge that the current legislation in respect of food production is becoming ever more stringent, we offer our customers a high-quality surface-treatment technology; this is consistent with the high-quality and high-end products that we manufacture and finish. This technology is offered in the form of the SUBLIMOTION-process®. The surface treatment of these products by means of wet abrasive blasting (SUBLIMOTION-process®) is key to the final result. The products have to comply with all hygienic properties and the ease of cleaning in its entirety has to be optimal. This surface treatment process has the following properties:

  • Improved surface topography / roughness <0.6 Ra
  • Optimal corrosion resistance (anti-corrosive)
  • Controlled surface peening (sealing fine cracks)
  • Hydrophobic (water-resistant) properties

Quite simply: reduced adhesion properties and optimum ease of cleaning!

Within the food industry, there has to be a constant and specific focus on hygiene, because consumers expect high-quality food products which are produced safely. This means that all machinery that comes into contact with those food products has to be free from all types of soiling and microbial contamination. That is why various regulations and directives have to be complied with:

  • EN1672-2: Food processing machinery / General Basic Rules / Part 2: Hygiene requirements.
  • EN ISO 14159: Hygiene requirements for the design of machinery
  • 2006/42EG: Machinery directive
  • Regulation (EC) 1935/2004: food contact materials and articles
  • EHEDG Guidelines (European Hygienic Engineering and Design Group)

The SUBLIMOTION-process® is a technology that has the following exceptional advantages:

  • It is a one-step-process; everything takes place in one single treatment
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  • No iron contamination occurs during the process.
  • The process uses an inert cleaning suspension consisting of water and inert microparticles.
  • The process is ecological and is based on a sustainable technology (Green Process).

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Onions make St. Croix’s Cry

On a beautiful day in Northwestern Wisconsin, the St. Croix BBC crossed bats with the Osceola Onions, the finest Wisconsin vintage base ball club.

The day started out well, many cranks came to witness the match that was held on the grounds of the Pioneer Village in Cameron, Wisconsin. The St. Croix’s lost the toss of the coin and were sent to strike first. The St. Croix’s could not muster a hit of any kind and went down in order. The Onions took their strikes in their half of the first and tallied two aces.

The next inning saw the Onions add to their lead by having four players cross home plate. The St. Croix’s got on to the tally board by making one tally in their third, but the Onions made good use of miscues by the St. Croix fielders and tallied another two aces. The Onions tallied another two in their fourth making the score ten to one in favor of the Osceola nine.

The Onions defense made many outstanding plays in the field, receiving the much deserved “huzzah” from the assembled crowd. The Onions continued to hit the sphere hard – tallying another three aces in their fifth, two more in their seventh and another in their ninth.

The Minnesota collection of ball players finally had their hitting shoes put on in their seventh when they tallied twice and another three aces in their ninth – but too little to catch the hard hitting Onions. The final score of the match was the Osceola Onions 16 and the St. Croix’s 6.

For the St. Croix’s, Captain Peterson lead the way with three aces scored, Mr. Pfundstein tallied twice and Mr. Tholkes once.

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Home & Family

belts Platform Reviews – Why They Are Important

There are many belts platform reviews 8belts opiniones sobre la plataforma that are out there but there are only a handful that actually give you an honest and truthful review of the product. The reason why many people don’t buy the product is because they get scammed and deceived by the company and are made to believe something that is false.

Before you buy any product you need to research about it to find out what other people have to say about it. If you don’t research then you might get scammed and buy something that you don’t really need. There are a few reasons why people like to read reviews and want to know about what other people are saying about a product before they buy it.

If you are going to buy something on the internet you want to make sure that you buy the best product for your money. Many people are able to purchase a product and then they find out that it does not work for them because they don’t take the time to do the research. They just buy something and start using it and this is a big mistake.

The first thing you need to do before you buy anything is to make sure that you are getting what you want. When you read an article or watch a video and they tell you that this is the best thing you will ever get you need to make sure you don’t fall for it. You want to make sure that you do your research before you spend any money.

The best way to make sure that you don’t fall for these kind of scams is to make sure that you are buying from a well known company that has been around for awhile. These companies have been around for awhile and they are very trustworthy. You don’t want to go with a company that is new to the industry because they might not have a lot of money to spend on advertising so they will try to get you to buy their product.

When you are looking for a new way to advertise on the internet then you should use the platforms like belts. They have a great way to advertise and they are trusted by millions of people all over the world.

When you are reading platform reviews, you will want to make sure that you read the information and make sure that it is true. You want to make sure that the information is reliable so that you don’t fall for a scam.

You should also make sure that the person that is giving you the information is legitimate. You want to do your research so that you don’t get scammed by a person that is trying to get money from you.

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RSE Consultation

As a part of your child’s educational experience at Sunnyside Academy, we aim to promote personal wellbeing and development through a comprehensive taught programme of Personal, Social, Health and Economic (PSHE) education that gives children and young people the knowledge, under-standing, attitudes and practical skills to live healthy, safe, productive and fulfilled lives, both now and in the future.
The Department for Education has made changes to relationships and sex education following nationwide consultation which came into effect from September 2020 (delayed to Summer 2021 due to COVID-19)  and all schools are required to comply with the updated requirements. The statutory guidance can be found at:

The guidance focuses on healthy relationships and keeping children safe in the modern world. It also covers a wide range of topics relating to physical and mental health, wellbeing, safeguarding and healthy relationships.

Learning about the emotional, social and physical aspects of growing up will give children and young people the information, skills and positive values to have safe, fulfilling relationships and help them take responsibility for their own well-being.

Consequently, from April 2021, Relationships and Sex Education (RSE), along with Health Education, will be statutory, and form part of the National Curriculum.

We have reviewed our RSE curriculum and policy so we can be sure our RSE provision is appropriate for our pupils based on their:

  • Age
  • Physical and emotional maturity
  • Religious and cultural backgrounds
  • Special educational needs and disabilities

As part of this process, the academy wishes to consult with parents, staff and governors that helped to inform our schools’ decisions on when and how certain content is covered.

This consultation will enable us to reach a general consensus and we may make adjustments to our policy and curriculum based on this feedback.

To help you understand the curriculum requirements, please look at the information below which provides more detail.

Please find below:

After reading these documents, please follow the link or QR code to complete the following questionnaire online to share your thoughts:


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“Blue Alien Cop” – Student Agency in Action!

A project which lasted over a year ended this month with the planting of 4 beautiful cherry trees, thanks to last year’s Year 3’s, and Ayden Kripalani.

Early in 2019, Ayden brought a book that he had written himself to school and shared it with the class. It was about Billy, and an evil blue Alien Cop. There was only one problem – the book had no illustrations. Ayden asked the class to help him illustrate his story, and so the project began.

There was much discussion about what Billy and the Alien should look like. The class all drew pictures, and voted to choose the characters. Then they each chose a page to illustrate, and they all worked as a team. It was challenging making sure Billy and the Alien looked the same on every page!

When the illustrations were finished, Ayden and the class decided they would like to publish the book, and to sell copies to raise money to buy cherry blossom trees to beautify the school.

The class proof-read the draft of the book carefully, and made changes to improve it. They then made a digital copy, and got a quote for how much it would cost to print.

They approached the Principal for permission for their project, and borrowed seed money to cover printing costs. They had to get more than 80 orders to pay the school back. They created posters, and advertisements to put up in the hallways, and ran a book promotion campaign at a whole school assembly, where they took book orders. Luckily, nearly 100 people booked a copy, and the printer was given the go-ahead.

When the books arrived, the class divided into groups to deliver the books to classes and count the money. It took a lot of checking, and mathematical thinking, to make sure the money was counted accurately, and to calculate how much profit was made after the load from the school was repaid.

The Year 3 ‘finance team’ then put the profit in the school safe, until we returned to school after Covid-induced restrictions were lifted. When we were finally allowed back onto the campus, in August 2020, Ayden and a small Year 3 team worked with Miss Xixi to choose which type of trees they wanted to buy. Finally, in November 2020, they went to a nursery, and chose 4 strong young trees – and Year 3 (now Year 4) went down to watch them being planted.

In order to celebrate the end of this year long project, the students helped the whole PYP write special wishes on ribbons, which they hung on the trees, along with plaques to commemorate this event.

Ayden and all of his class are very proud of these trees, and they hope they will grow healthy and strong to bring many years of pleasure to EtonHouse students when they flower.

（For more highlights, please scan the QR code below to enter the official WeChat.）

This page was last edited on December 25, 2020


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Wednesday, March 18, 2015

This week for my pinspiration posts I have collected some of my favourite fashionable outfits from Paula Coop McCrory's Pinterest page. I'm heading to Toronto Fashion Week next week, so I'm on the hunt for some inspiring outfits and ideas. I'm so excited!!

Make sure to follow along for more inspiring Pinterest photos (Paula Coop McCrory)

-Sydney Hoffman

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Monday, March 19, 2012

NTUA, NTNU win first ever UBA titles

[Chen Che-yu]

Well, this is sort of an old news from last week, because I was too busy to write about it. Anyway, National Taiwan University of Art (NTUA) and National Taiwan Normal University (NTNU) won the men's and women's UBA title last week.

Both school won its first ever UBA title in school history – as an underdog. So you could probably say it's a Taiwanese version of the March Madness.

NTUA beat the Chinese Culture University (CCU) 83-74 in the title game as Chen Che-yu was named MVP for his 21-point, 7-assist performance and Chang Po-wei added 29 for the winner.

Hsing Wu College overcame a 14-point deficit and defeated NTNU 66-62 for the third place, its best finish in school history.

Chang Chia-jung had 28 points, including 16 of 21 from the free-throw line, and Wang Hao-chih had 12 and 17 for the winner. NTNU, the perennial powerhouse which had its worst finish in 10 years at the fourth spot, was led by Hung Kang-chiao's 26 points and 7 rebounds.

Huang Pin-chen had 13 points and 11 rebounds in NTNU's historical 61-46 win over the Chinese Culture University (CCU) for the school's first title.

NTNU opened the game with a 12-0 run and never looked back, snapping the CCU's 31-game winning streak.

Fo Guang University beat National Taipei University of Education 77-72 for the third place despite Peng Shih-ching's 39 points for the loser.


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SOA best practices

SOA, service-oriented architecture, you can't easy live without reading this term each day. SOA mostly stays on top of the executive and IT agenda's, but were to start? What best practices exist, leading to SOA success? As SOA matures, and nowadays it does, IT organizations are finding common best practices for SOA success. Next two articles give a nice overview:

10 Steps to SOA success
Five high-level action items for SOA success

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Tuesday, April 30, 2013

Fast Ustream Tonight

Hello Everybody.

Just wanted to give you a heads up on my Ustream tonight.

I will be streaming at 7 p.m. tonight, however its just going to be for a bit as I need to get ready to go to Chico Scrapbooks In California early Thursday Morning.  Actually making kits up for the next weekend in Tumwater....LOL!

So no project, just a wee bit of a chat and to check on y'all to catch up....

See you tonight if you make it...

The Gentleman Crafter

  1. Can't wait to hear all the wonderfulness of Your Adventure to NJ!!!!

  2. PLEASE, PLEASE, PLEASE RECORD! I have to work, but want to hear about your Ranger U trip!!!

  3. Does that mean a show & tell on all of the Ranger U projects????? I hope so.

  4. I'll try and stay up as I want to hear all the details about Ranger U!

  5. Keeping my fingers crossed that you will share Ranger U projects with us. It will be good to "see" you again...I've been missing you!!!

  6. I was on the way back from Waco, and tried to reach you in the car via UStream, but it just wouldn't work right on the road...crapper!!!! I wanted to say CONGRATS to you on Ranger U...again!

Note: Only a member of this blog may post a comment.


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Avocado Oil
I love eating avocados and not only are they a healthy source of vitamin A, C, and E  but they are also extremely moisturizing when used on the skin. Which is great in the summer time in hot, sunny Abu Dhabi!

The oil is especially abundant in fatty acids which help in balancing the skin's moisture levels. They are also high in sterolins which are great in reducing brown spots, reducing skin damage, and helps in the process of healing scars. It also is proven to increase the amount of collagen the skin produced which by default decreases when we age. The oil is wonderful for dry or dehydrated skin, mature skin, and anyone who is looking for a natural moisturizing effect for their skin.

Avocado Moisturizing Recipe:
1/2 tablespoon of avocado oil
1/2 tablespoon of primrose oil
Small Towel

Combine the avocado oil with the primrose oil in a small bowl. Mix the oils and apply it to the areas that need moisture, like your face, neck, and lips. Grab a small face towel and dip in warm water. Put the warm towel on the area for about a minute so that the oils are absorbed in the skin.

Stay beautiful ladies!

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stuffed with pepper jack cheese & spinach

A while back, I found this recipe in a fashion magazine. The photo looked so enticing I ripped the page right out and mentally put it on my to-make list. The problem was I forgot about it until very recently. It was obviously a big hit with the fam, and I thought to myself, I should have made it sooner given how EASY it was to make.

Since then I have made it some more/ tweeked it here and there. I found that you can also use red chili powder in place of the cajun seasoning and mozzarella cheese in place of the pepperjack if you would like. I have also tried it this way and it is not much different- still so moist and just delicious. Most people have olive oil, spinach, chicken breast, and red chili powder in their kitchens (if that’s you you know what you’re making for dinner tonight 😉

The recipe page credits cooking creation.

1 lb boneless, skinless chicken breasts
4 oz pepper jack cheese, shredded (you can use up to 6 oz)
2 c frozen spinach, thawed and drained (you can also use fresh cooked spinach)
2 tbsp olive oil
2 tbsp GF Cajun seasoning
Sea salt, to taste
Freshly ground black pepper, to taste (I use lawry’s)
Lots of toothpicks

Preheat oven to 350 degrees.

Flatten the chicken to 1/4-inch thickness.

Cook your spinach until it is limp

run cool water over it to cool. Then use your hands to squeeze out all water. Chop and dice the clump of spinach.

Grate your pepperjack cheese or chop in into teeny teeny cubes. In a medium bowl, combine the grated pepper jack cheese, spinach, and some generous dashes of salt and pepper. mix it up.

spoon about 1/4 c of the spinach mixture onto each chicken breast.

Roll each chicken breast tightly and fasten the seams with several toothpicks. I used 6 toothpicks in each “roll” to ensure none of the filling seeps out.

Brush each chicken breast with the olive oil. Sprinkle the Cajun seasoning evenly along the top. I finish with a tiny dash of pepper too. Sprinkle any remaining spinach and cheese on top of chicken if you’d like to.

Place the chicken seam-side down onto a greased baking pan or onto a tin foil-lined baking sheet.

Bake for 35 to 40 minutes, or until chicken is cooked through.

Remove the toothpicks before serving.

Serve with mash &/or your fave salad or greens.

every bite


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The artwork of artist Todo

Where were you born and where are you from?
I was born in Kenosha, Wisconsin, but grew up mostly in California and Virginia.

How did you get introduced to the tattoo culture?
I've had a fascination with the tattoo culture since I was a kid, I used to buy old biker mags in the 70's just to see the ink and of course read the articles.

When did you get started?
I started experimenting in the late 70's and early 80's, but didn't choose it for a career till the early 90's, when I moved to Hawaii to be trained professionally.

Do you remember the first tattoo that you did?
Yes it was an ANKH I put on myself, I had to promote my work somehow.

How would you describe your style of tattooing?
My styles are anything that's challenging, I like to tattoo Photo Realism, Animals, Portraits, Bio Mechanical and Organic freehand art.

What were you doing before you got into the tattoo business, and what made you change?
Back in the day before professional tattooing came about for me, I was a certified welder/Machinist and ran a Roofing company. I still tattooed on the side but didn't decide to make it a full time career till I headed to Maui, Hawaii in 1991 to work for Skin Deep Tattoo.

What influences your artwork?
I'm influenced by the desire to push the boundaries of art and tattooing, I'll never settle for second best.

What would you say is the best part about tattooing?
The best part of tattooing for me would have to be conventions and being around all the best talent this industry has to offer. As an artist and being around that energy helps me achieve new levels I never thought possible. Also pounding a few Heinekens and eating Sushi while talking shop with fellow artists.

What advice would you give to someone looking to get their first tattoo?
Most of the tattoos I do are the type that you can keep building on to, so I recommend to always try to see the future of your project and plan well, there is nothing worst than regret.

Do you see yourself doing anything other than tattooing?
Tattooing is one of many mediums I work in, I also work in Oil painting, Airbrush, Charcoal and Graphite, 3D CGI and Digital painting. I'm eager to be a part of the Art Gallery scene in the near future.

Do you have a favorite quote?
“Life’s most fulfilling time is when you get your second wind.”

What’s your biggest inspiration, what keeps you going?
I have to say my Family helps me push harder every day to achieve new levels in art, they are my best critics.

What is one thing that life has taught you?
Be humble and try to keep your personal Drama to yourself.

Where do you see the tattoo culture 10 years from now?
10 years from now I see tattooing as well respected form of art amongst all cultures. Also, new and improved colors that won't ever fade with time.

Anything else you would like to add?
Contact Information:
ABT Tattoo
1182 Hwy 155 South
McDonough, Georgia, 30253


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The Jazzcat

Mark Ferber with Jon Gordon at Cafe Metropol

by on May.12, 2006, under Uncategorized

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Safe sex is good sex

Graphic: James Culleton

You should care about your sexual health. Whether you’re a seasoned pro in the bedroom or you’re treading carefully, a little knowledge goes a long way.

Sexual health involves more than just avoiding Sexually Transmitted Infections (STIs). Being safe from violence and injury—as well as having control and positivity during sex—is highly important.
Your physical health is probably on your radar if you make an effort to exercise regularly. If you like to meditate, you’re taking care of your mental health. Being mindful of your sexual health is just as important.

It’s your body. You’re in control.

Control. Positivity. These two buzzwords are significant for sexual health. All too often, women and men are robbed of feelings of control during sex and positive sexual experiences through an instance of sexual assault.

In 2004, there were over 500,00 incidents of sexual assault against those aged 15 and over in Canada. Since many incidents remain unreported, the actual estimation is likely to be much higher.
Young adults—especially females—may be disproportionately vulnerable to sexual assault. In 2004, females were victimized around five times as much as males in Canada. Fifteen to 24-year-olds were victimized almost twice as much as 25 to 34-year-olds.

You deserve a sexual experience where you are in control of your body – quite unlike what Robin Thicke’s single “Blurred Lines” might suggest when he says, “Do it like it hurt, like it hurt / What, you don’t like work?”

The “lines” (what you’re comfortable and not comfortable with in bed or elsewhere) are absolutely not blurred. You and your partner have the right to do (or not do) whatever you damn well feel.
A positive sexual experience involves a ton of communication – and gratification. Both partners must be actively committed to enjoying themselves as well as making sure the other person has a great time, too. There is a lot you can do and things you can try like sex toy that you can buy from sites like and many others.

Chances are you know your own body better than you know your partner’s. It’s a good idea to let your partner know what you like, in whatever method you’re most comfortable with. No one’s a mind reader.

S.T.I.s : more common than you think

You might have an STI and be completely unaware it’s there. Many STIs—for example, chlamydia and human papillomavirus (HPV)—can be invisible to the naked eye. Left untreated, they can lead to serious health complications including infertility and death.

In 2008, chlamydia was the bacterial STI most frequently reported in Canada. It can creep up without symptoms. Chlamydia is caused by a bacterium and can be transmitted through vaginal, anal, or oral sex. It’s especially common among women ages 15 to 24 in Canada.

Even though most cases of chlamydia don’t have symptoms, some infected women may experience “vaginal discharge, [a] burning sensation when urinating, pain in the lower abdomen (sometimes with fever and chills), pain during sex, [and] vaginal bleeding between periods or after intercourse.” Without being treated, it can bring about pelvic inflammatory disease (PID). One of the effects of PID can be infertility.

HPV is another common STI in Canada. It also happens to be one of the easiest to contract. That’s because HPV can be passed through genital-to-genital contact. To translate: you don’t need to have sex to contract HPV.

“What’s the big deal? No symptoms, no problem!”

Think again. You can develop certain cancers originating from HPV without any symptoms, until the cancer has developed.

You’ve probably seen numerous advertisements in doctors’ offices promoting Gardasil and Cervarix, the two HPV vaccines currently in use in Canada. The vaccines protect against four and two strains of HPV, respectively.

How to protect yourself

Maintaining your sexual health takes a personal commitment and two decisions: all partners must be committed to safe sex.

One of the most convenient ways to protect against STIs is by using condoms. When they’re used correctly and consistently, male condoms reduce the risk of contracting STIs. You can purchase them at most drugstores and convenience stores, many of which are open 24 hours.

Peers and the Womyn’s Centre on campus, as well as many other clinics around the city, provide condoms free of charge. That’s pretty helpful for students on a budget.

Female condoms are also available at drugstores, but are slightly more expensive. However, unlike male condoms that can only be used once the penis is erect, female condoms can be inserted ahead of time – up to eight hours before having sex.

You should use protection when sexual contact occurs between any and all genders. Don’t forget about HPV – which doesn’t require penetration to be passed on.

And don’t forget the most important thing – have fun!

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If you come to visit us at The Noble Sage today in North London, you will enjoy this exhibition of South Asian contemporary art.


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Month: February 2016

The Flavor Tripping Experiment Gone Wrong

I got a job! And a girlfriend! Just joshing around. I still don’t have a full-time job yet (this blog has rendered me unemployable), and my girlfriend is still my right hand. For some reason you guys really like it when I’m miserable and barely scraping by, because I go to my secret dark place and think about how to destroy the… Read more →

Let’s Eat Dumps For Dinner: I Finally Cooked From that Dump Dinners Cookbook

I hope all of you clowns had a wonderful Valentine’s Day! I went on a romantic date with your mother. We ate hot dogs, crammed a few up our asses, then talked about food blogs for two hours straight while practicing advanced Greco-Roman wrestling moves on each other. I ended up with a sprained penis, but in the end, it was worth it. I… Read more →

Valentine’s Day For One: What It’s Like to Eat Fondue by Yourself

As you all know, Valentine’s Day is next Sunday. Many of you will wave your hands and go, “Dannis, Valentine’s Day is silly. We celebrate our love every day. Valentine’s Day is a horseshit made-up holiday.” Then you will plan a cool Valentine’s Day date, either at a restaurant, or with a fancy meal at home for you and your… Read more →

How to Make Your Own Food-Based Lip Balm

I have been horrendously sick for the past few weeks. I didn’t think I’d be ready for this week’s Pizzle post, but since I am a true champion of the people, I persevered through horrible coughs, bloody noses, explosive diarrhea, and very little sleep. However, you mothers and fathers in the world have to deal with much more misery than… Read more →


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What are PCBs?

PCBs are polychlorinated biphenyls, or a compound that links chlorine, carbon, and hydrogen atoms. These man-made chemicals were used in a number of products before being found to be severely toxic in the 1970s. Among the main uses of PCBs included in surface coatings of buildings, adhesives, paint, and electrical equipment. Because of the commonality of the use of PCBs, at least 10 percent of PCBs produced after 1929 are still in the environment today. This has occurred due to the poor disposal methods in place for PCBs. For example, when PCBs are incinerated or stored in landfills, the chemical releases more harmful toxins that can seep into the water, land, and air.

PCBs have a highly stable molecular structure that causes them to persist in the environment. This persistence affects the health of the plants and animals exposed to the dangerous chemical. In the 1970’s, it was found that PCBs are cancerous and can cause deformities and other serious health complications. This becomes hazardous when the irresponsible disposal of PCBs places the chemicals in direct contact with water, crops, and animals that are later consumed by humans. Consuming poultry, fish, and other contaminated meat is the primary cause of humans having higher levels of PCBs in their bodies.

Monsanto was the sole manufacturer of PCBs in the United States until the manufacturing of PCBs was made illegal. The main facility this took place at was outside of St. Louis, Missouri. This area currently has the highest rate of fetal death and immature births in the state due to the proximity of the PCB manufacturing plant. Other Monsanto PCBs are directly linked to pollution and contamination of entire cities such as San Diego, California and Anniston, Alabama. These contaminated spaces leave thousands of men, women, and children exposed to potentially fatal diseases.

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Trial lawyers specializing in personal injury and civil litigation

Polygraph examinations just aren't admissible....period. Farm Bureau gets new trial

Farm Bureau refused to pay Randall Dillard's homeowner's claim for vandalism and theft.  It pointed to evidence that suggested an "inside" job, despite that fact that Dillard too, and passed, a polygraph.  When the case went to trial, the Judge allowed Dillard to offer into evidence the fact of passing the polygraph and perhaps for that reason, the jury ruled in his favor.  On appeal, the Court of Appeals noted that currently neither Michigan nor Federal courts allow for the admission of polygraph evidence.  Both court systems consider the evidence to be too unreliable.  Dillard will have to prove his case without the polygraph corroboration.

Thompson O’Neil, P.C.
309 East Front Street
Traverse City, Michigan 49684
Toll Free: 1-800-678-1307
Fax: 231-929-7262


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Egypt: Hierakonpolis, A Feature Tour Egypt Story

Nekhen, Greek Hierakonpolis

By Marie Parsons

Nekhen, Greek Hierakonpolis

The ancient site of this city, called Nekhen by the Egyptians, its Greek name Hierakonpolis meaning city of the falcon, was long venerated by the ancient Egyptians as the early capital of the Kingdom of Upper Egypt. Just as Naqada or Nubt was the city of Set, Hierakonpolis or Nekhen was the city of the Falcon, first called Nekheny the Nekhenite and represented with two tall plumes on its head. He was assimilated very early with the falcon Horus, patron god of kingship, and Nekhen remained a cult center for Horus even after it was supplanted by Edfu as both provincial capital and temple center. This may have led to one of several outbreaks of strife during the First Intermediate Period. Edfu was taken over for a while by the governor of Hierakonpolis, who was named Ankhtifiy.

Nekhen lay in Upper Egypt, south of Naqada, and Thebes, and across the Nile from El-Kab, which became the city of Nekhbet the vulture deity and one of the two Ladies who guarded the kingship. It lay north of Aswan and just north of Edfu.

Nekhens history begins around 4000 BCE, when local hunter-gatherers were joined by farming and herding "colonists." Recent explorations have shown that by 3500 BCE Hierakonpolis was the most important settlement along the Nile, a vibrant, bustling city stretching for over 2 miles along the edge of the floodplain. At about that time, the population of Hierakonpolis seems to have increased by large bands of people migrating into the Nile Valley fromthe outlying areas. This may have been the final days of the old nomadic hunting way of life exchanging for the settled life of plenty in the Valley as climactic conditions and the fertility of the floodplain for agriculture pushed the people into the Valley.

Nekhen, Greek Hierakonpolis

The town remained important into the early part of the Old Kingdom, and though it declined as a settlement, its temple to Horus of Nekhen was rebuilt in both the Middle and New Kingdoms. Three or four known tombs dating from the New Kingdom have been found here, including that of Hormose. This tomb gives evidence that the temple of Horus had been renewed by Rameses XI, who had followed the building efforts of Thutmose III five centuries earlier.

A title with Predynastic significance was iri-Nkhn, "keeper of Nekhen". Perhaps "keeper of Nekhen" had prestige when Nekhen was a power center, but by the Early Dynastic period, the meaning of the title may have been lost, leaving it merely an honorary designation, for example, it was a title held by Nedjemankh in the reign of Djoser.

At its greatest growth Nekhen contained perhaps 7500 inhabitants, already equipped with many features that would later come to typify Egyptian culture and form the basis of its economy. Stretching for over 2 miles along the edge of the floodplain, the city held many neighborhoods, filled with farmers, potters, masons, weavers and other craftsmen, and officials. Signs of the outbuildings of a large farm have recently been discovered, including flint figurines of animals.

On the north side of the town stretched a large installation of pottery vats for brewing wheat-based beer stretched here. It is estimated that this brewery could produce about 300 gallons per day, a ration for 200 people.

A potters house was discovered at Hierakonpolis, consisting of a man-made rectangular house, surrounded by a wall, with an oven. One particular house and workshop was uncovered in 1978. It belonged to a potter, who signed his pots by impressing a crescent-shaped thumbprint into the wet clay just below the rim. Some 300,000 fragments of these pots were found littering the ground. The house was rectangular and semi-subterranean, measuring 13.1 X 11.4 feet, built of posts and mud-coated reeds.

A fire must have swept from the kiln to the house, 16 feet away, and hardened the soil and mud bricks, reducing the posts and mats to charcoal ad ash. The house was then rebuilt in stone.

Hierakonpolis increased in population as it benefited from close contacts with Lower Nubia, giving the Hierakonpolis chieftains control of or at least access to trade routes to sub-Saharan Africa. Evidence has also been recently uncovered indicating mining and trade access to the mineral resources of the eastern desert.

The first discovery a hundred years ago of rich caches of discarded temple furnishings on low mound within the modern village seemed to confirm these ancient traditions of this settlement being the early center of the 3rd Upper Egyptian nome. Since a century ago, more recent work has been uncovering objects that slowly expand the knowledge of how these people lived and died.

The macehead of Scorpion and the palette and macehead of Narmer were found in 1898 by J.E. Quibell and F.W. Green at the "main deposit" of the temple of Horus in Hierakonpolis. The Two Dog palette, possibly dating earlier than that of Narmer, a number of small ivories inscribed with the names of Kings Narmer and Den, two statues of King Khasekhemwy of the 2nd Dynasty, and inscribed stone vessels dating to his reign, have also been found.

A seated red pottery lion and the great gold plumed falcon representing Nekheny or Horus have also been found. Many ivory objects such as seals, human and animal figurines in the shapes of scorpions, baboons and dogs, and vessels, wands, plaques and inlays were found at Nekhen, prompting scholars to intimate the perhaps the city was a center for ivory carving craft.

One area excavated within the town yielded almost 4000 flint pieces including a tool kit of scrapers, microdrills, bifacial knives, serrated sickle blades, crescent drills, all for the production of stone vessels. At the same level were found more than 30 carnelian nodules. Carnelian is not a local stone, it has to be imported from the Eastern Desert, so here is more evidence that Nekhen may have been a trade center for exotic goods.

Hierakonpolis remained an important cult center for the god Horus, symbolic of the living king. A large ceremonial center was excavated out on the low desert, which dates back to early Naqada II. It has been interpreted as a temple, closely resembling shrines depicted on seals from the First Dynasty. At the end of Naqada II, religious activity locally was apparently relocated to the center of the walled town. This so far is Egypts earliest temple, occupying about one-sixth of the entire town area. A circular stone restraining wall and adjoining paved area of compacted earth reinforced by rough sandstone blocks have been found, as have the remains of limestone column bases or pedestals for statues.

In the large oval courtyard probably stood a solitary pole displaying the image of the god, while at its base, on makeshift platforms, the early kings of Upper Egypt viewed their bounty and the sacrificial slaughters for the falcon god: cattle, goats, crocodiles and even fish. Around the courtyard, in little workshops, trained craftsmen transformed raw materials from all parts of the region into luxury goods such as ivory boxes, polished stone jars, jewelry and ceremonial weapons.

The central shrine consisted of three rooms, its faade made up of four huge timber pillars that may have stood at least 20 feet high. With colored mats for the walls, the shrine must have dominated not only the temple complex, but the town itself.

Some scholars believe that Nekhen had contact with the city of Uruk in Mesopotamia. The wall enclosing the temple off from the rest of the city is but more similar to the style in Mesopotamia. Mesopotamia and the Gulf were the only two other places at this time or since that had this Temple Oval, which in both the Near East and in Nekhen was a semi-circular walled structure which contained virgin sand on which the earliest shrines were raised.

Also, elements similar in Mesopotamian reliefs and paintings are first seen here at Nekhen. Examples of these are "the master of beasts", and the niched facades on the walls. An elaborately niched mud-brick faade within the town has been interpreted as the gateway to a palace, or at least an administrative center of the early state. The gateway wall was no less than 34 feet thick in places and consisted of a double skin of mud brick. Both as a defensive structure and a piece of urban development, the gateway shows the same niches and recessed and buttressed paneled walls that were used on the serekhs.

Nekhen, Greek Hierakonpolis

Tomb 100, called "The Painted Tomb", now lost, contained wall murals that showed similarity to Near Eastern themes. The confronted animals, the bovine turning back its head, the whirling birds, horned beasts, the two warriors with bucklers, all typical of the Gulf and Elam and the Arabian mainland. It showed scenes of hunting and the mastery of animals, fights between small groups of men, a sacrifice and several boats, including a rather non-Egyptian looking one. The figures engaged in hand-to-hand combat held maces of a type used by later culture, and in fact the Naqada II culture brought in the pear-shaped macehead which replaced the flat disc-shaped macehead used earlier.

Work progressing on the cemetery 6 burial area out in the desert show that this cemetery was used and reused. Between 1979 and 1985, Cemetery 6 was found to contain twelve tombs from the Naqada I and early Naqada II period. The tombs belonged to members of the local elite. Some of the tombs still contained valuable goods despite being heavily disturbed. This site was abandoned during the later Naqada II period, when the burials of later elite nobles were moved closer to the cultivated areas. The Painted Tomb, or Tomb 100, was found herein. During Naqada III, the ending of the Predynastic period, burials of the local elite were moved back to Cemetery 6, within massive rock-cut tombs with offering areas. Excavations at cemetery 6 reveal several large tombs containing Naqada III ware. Tomb 11, looted, still contained beads in carnelian, garnet, turquoise, faience, gold and silver, fragments of artifacts in lapis lazuli, ivory, obsidian, and crystal blades, and a wooden bed with carved bulls feet. These indicated elite burials but not quite of the quality of the royal burials at Abydos. Tomb 1 in locality 6 has a sunken pit surrounded by triple-coursed mud-brick walls, with wooden planks overlaying it. The walls were plastered, and the pit was surmounted by a replica of a temple or palace made from wooden posts and surrounded by a wooden fence. This may have been a precursor of the mastaba tombs of the First Dynasty and later.

In 1998, two more tombs were discovered at Cemetery 6. Bones within one of the two latest tombs found proved to be a mixture of bones from two human males and seven dogs. In the second tomb were also found the bones of a young savanna elephant.

Other intriguing finds here include two pottery masks with cut-out feline-shaped slanted eyes, aquiline noses, and mouths. Near one mask was found a tuft of twisted human hair, perhaps part of a headdress. The second mask had a beard colored plum red and human ears attached. Part of a third mask have also been uncovered. Masks may have been drawn on the hunters inscribed on the Two-Dog Palette and the Ostrich Palette. To date, the earliest use of human-faced masks dated back to the Fourth Dynasty. Perhaps further work on this tomb will provide more information on the ritual useage of masks, and how early that useage began.

Charcoal samples found in this tomb helped identify the original wood as cedar of Lebanon, the first time that imported wood was discovered at Nekhen, though it is possible that the temple may have also made use of cedarwood for its pillars.

In another tomb a figurine of a cow was found buried with human bodies, while in yet another tomb, a cows skeleton was found laid out with a human figurine. The cows bones as well as the human bones were impregnated with resin, a precursor to mummification.

To date, 150 burials have been found in another cemetery area, called cemetery 43, belonging to the working class inhabitants of Nekhen, as indicated by a general lack of grave goods and the robust physical nature of the bodies. Seven of these bodies show evidence of decapitation and grave goods such as copper pins and linen matting. Although these burials contained finer grave goods there was a marked absence of disturbance or robbery, unlike many of the other burials.

  • The Oxford History of Ancient Egypt ed. Ian Shaw
  • Egypts Making by Michael Rice
  • Early Egypt by A.J. Spencer
  • Egypt Uncovered by Vivian Davies and Renee Friedman
  • Ancient Egypt: Anatomy of a Civilization by Barry Kemp
  • Nekhen News, published for the Friends of Nekhen
  • Early Dynastic Egypt by Toby Wilkinson