R v. Brown 1996 - Free Essay Example

Analyse how the House of Lords interpreted the word â€Å"use† in 5(2)(b) of the Data Interpretation Act 1984 in the case of R v Brown (1996) 1 ALL ER 545 Introduction The case of R v Brown, 1996, concerned two uses of a police force Computer by an officer, for the purpose of obtaining registration numbers of cars owned by the debtors of a collection company that was run by a friend of the officer. The police officer was a registered data user[1] and as such, he was prohibited under the Data Protection Act 1984 to ‘hold personal data’[2]. The charge was for the criminal offence[3] under s 5(2)(b) of the1984 Act, which stated that: â€Å"A person in respect of whom such an entry (an entry pertaining to the identity of registered data user) is contained in the registrar shall not†¦(b) hold any such data, or use any such data held by him, for any purpose other than the purpose or purpose descried in the entry†¦Ã¢â‚¬  In the origina l trial, the judge directed to jury to consider that the act of simple retrieval from the computer, coupled with the intention of utilizing the information for a purpose that had not been registered was enough to satisfy a conviction. The Court of Appeal[4] rejected the initial convictions of attempt on the first count, and full commission of the crime on the second count. It was held that the term, â€Å"use† when interpreted with sole reference to its ordinary, everyday meaning, required that the offence could only be committed when more than mere retrieval of data had been done. It was therefore necessary to â€Å"do something to the data†¦Ã¢â‚¬  which meant that the case was decided entirely on the appropriate answer to the legal question, which was: â€Å"Whether the word ‘use’ in section 5 of the Data Protection Act 1984 should be construed so as to include processing the data so as to gain access to information stored within a computer without doing any further act with the information†¦Ã¢â‚¬  This paper analyses the decision reached by the House of Lords with regard to the interpretation of the word ‘use’. An account of both the decision of the court, as espoused by Lord Goff of Chieveley and Lord Hoffman and the dissenting ratio decidendi, as stated by Lord Griffith is given 1.The decision of the court (a)Lord Goff of Chieveley Lord Goff followed the line of reasoning of the Court of Appeal and stated that: â€Å"since the word, ‘use’ is not defined in the Act, it must be given its natural and ordinary meaning. Synonyms of the verb ‘use’ are ‘to make use of’ or to ‘employ for a purpose’.[5]† He then analysed the context of the word in relation to the specific item that was purported to have been used by ascertaining the sort of activities that would be regarded as ‘use’ of ‘data’. He ascertained from this analysis that the act of retrieval therefore did not constitute ‘use’ of the computer information but was a mere prerequisite[6] to that use. Further to this, with reference to the meaning of the word ‘disclos ing’[7], which also has no definition within the statute, Lord Goff made the crucial observation that: â€Å"†¦if the purpose of this provision had been to provide that, exceptionally, disclosure may occur after the information has been retrieved from the database, it would surely have been drafted in a different form; and a similar provision would have been made in respect of use†¦[8]† This statement directs towards an acceptance that the statute is clear on the matter of the intentions of parliament and Lord Goff arrived at this decision by referring exclusively to the ordinary and everyday definition of ‘use’ within the context of the provision within the statute. As well as analysing the equivalent provisions for the word ‘disclosing’, he also referred to other provisions within the 1984 Act, including part I of the Schedule, which stated that: â€Å"Personal data held for any purpose or purposes shall not be used or di sclosed in any manner incompatible with that purpose or those purposes.[9]† This provision clearly shows the word ‘use’ within a provision where there is clear protection by the law of data outside its electronic form, thereby showing the intention of parliament to criminalise subsequent ‘use’ of data after retrieval and inevitable transfer from the electronic format. This reasoning is based on the linear timescale of the criminal act of ‘use’ of personal data. There is first retrieval, followed by transfer from electronic form, analysis and application. If criminality were to be established exclusively at the point of retrieval prior to the transfer of the subject matter from data into information, it would therefore mean that all other subsequent steps would be irrelevant for the criminal law and Lord Goff pointed out that all unregistered retrieval by a registered data enterer would constitute a criminal act, whereas completion of a ll four steps by someone who is not registered, would not be criminal at all[10]. This in itself would lead to a great injustice of the law. In his analysis, Lord Goff referred to no other issues as, since there was no ambiguity following this literal interpretation, the analysis of other sources, such as Parliamentary Hansard, was wholly unnecessary. This is very much an embodiment of the literal approach to the interpretation of statutes, which has proved to be utterly essential for the purposes of ascertaining the meaning of words, as shown in the far earlier case of Fisher v Bell[11]which concerned the meaning of ‘offers for sale’ under s 1(1) of the Restriction of Offensive Weapons Act 1959. Here it was held that an offer could not be anything other than a binding contractual proposal to which an unqualified acceptance would constitute an obligation for the offeror to fulfil the offer. This therefore distinguished the ‘offer’ from the far more gener al ‘invitation to treat’ and, had the court stretched the meaning of ‘offer’ to include non binding invitations, the law of contract would have been badly distorted. (b)Lord Hoffman Unlike Lord Goff, Lord Hoffman rejected the arguments of the Crown in relation to the identification of retrieval as external to the application of acts within the meaning of use but instead stated that the acts of this particular case were in relation to use of the computer as opposed to the data. However, this was not the crucial point of his argument as he did state that this in itself would not preclude ‘retrieval’ being an acceptable element of the meaning of ‘use’. Lord Hoffman’s argument instead hinged crucially on the belief that the acts of the defendant fell in line with the definition of ‘processing’, which, under s 1(7) of the 1984 Act includes: â€Å"†¦extracting the information constituting the data†¦[12]† Lord Hoffman then stated that processing is entirely different from ‘using’ as there was no reference to it within the prohibitions of the 1984 Act, which means that the act of processing, as protected under principle 1 of the Schedule, did not constitute a criminal offence. Instead it was a civil breach that constituted a ground for removal from the registrar of authorised data processors[13]. Lord Hoffman therefore identified the intentions of Parliament as the creation of separate treatment for ‘processing’ and ‘using’ whereby the former was principle 1 (Sched) enforcement of data protection and the latter, as a ‘more extreme form of data processing’[14] was a criminal offence. This was therefore a clear departure from the difficulty of having to ascertain that something more than retrieval had to have been done to the information in order to constitute the criminal offence and is a simpler finding than tha t of Lord Goff as it denied existence of a gap in the law and established the differing treatment of the non-criminal punishments inherent in ‘processing’ 2.The dissenters[15] Lord Griffith Lord Griffith began in concurrence with Lord Goff by rejecting the submission of the prosecution in the Court of Appeal, who had made a crucial distinction between the concept of data as ‘electronically readable’ subject matter that, when translated into text on the screen, became the wholly distinguishable ‘information’ that was intelligible to the human mind. The result of this shift in the designation of the subject matter from ‘data’ to ‘information’ is that it is not protected by the 1984 Act[16]. His departure from the Lords who dismissed the appeal was simply that the word ‘use’ should be given a ‘broad construction’ and he rationalised this finding by pointing out the clear weakening of the protective powers of the 1984 Act. His reasoning was that the enactment of the 1984 Act was for the primary intention of ratifying the Council of Europe Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data.[17] With reference to Article 1 of the Convention, Lord Griffith stated that the retrieval of information, to be displayed in a screen, constituted an invasion of privacy as the display was illegitimate. He further believed that extension of the meaning of ‘use’ to illegitimate display and retention for potential dissemination in the future would by no means constitute a stretch of the definition of ‘use’ but also accepted the difficulty that prosecution would face in having to prove the actual way in which information would be utilised following retrieval. 3.Feedback (a)The approach of the court As regards the methodology of the House of Lords in its interpretation of the word â€Å"use† ther e were two distinct poles of thought. The first was seen in the opinions of Lord Goff and Lord Hoffman who both realised that questions of law that pertain to verbal meaning must be approached from the point of view of establishing an answer based on statutory definitions or, in absence of such guidance, the nearest possible definition that will ensure the fundamental requirement of certainty in the law. For vocabulary, this certainty is maintained by utilizing the ordinary and everyday meaning of words. The second pole of thought, as utilised by Lord Chieveley, looked towards the teleological side of statutory interpretation and ascertained that the intentions of parliament, as to the meaning of a statute, was the key method for assurance of the legal goal of equity and Lord Chieveley used the very reason for enactment of the 1984 as the embodiment of the Parliamentary intention to create a right of privacy against illegitimate displays of data under the European Convention. (b)Was the decision correct? This case is a primary example of an obvious disparity between the common sense approach of the layman and the judicial predicament of verbal anomalies that force the wrong decision as far as justice is concerned. The question to therefore ask is, was the House of Lords simply over literal in its interpretation of the word â€Å"use† or were they right and, as a result of their correct actions, revealed a gap in the law that had been created by careless wording of the statute? It is this latter notion of the ‘gap in the law’ which Earl Russel refers to in his parliamentary feedback to the case[18]. The appropriateness of the House of Lords cannot be blamed for finding itself forced to follow bad law. Statutory interpretation, for the purpose of obtaining the correct decision as required under current law is the primary role of the judge, regardless of the construction of that law. Their job is most certainly not the task of inte rpreting the law in order to meet the most equitable decision[19] unless of course the area of law has no governing statute and there are no clear precedents from which to draw the correct answer. As for Lord Hoffman, it is clear the same priority of statutory analysis was utilised in his decision but his more favourable reasoning denied a gap in the law for a jurisdiction such as the United Kingdom that, at that time, did not possess any Human Rights legislation and was therefore under no national obligation to interpret legislation in light of concepts of privacy[20], as was done in the teleological approach of Lord Chieveley. Conclusion The approach of Lord Hoffman was the correct interpretation of the statutory provisions at the time in which the case was decided but Human Rights Law has now fundamentally changed the approach of the courts whereby affected legislation can now no longer be decided on the basis of verbal distinctions. Bibliography Legislation Restri ction of Offensive Weapons Act 1959 Data Protection Act 1984 Human Rights Act 1998 European Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data 1981 European Convention of Human Rights and Fundamental Freedoms 1951 (As contained in the schedule of the Human Rights Act 1998) Case Law R v Brown [1996] 1 ALL ER 545 Fisher v Bell [1960] 1 QB 394 and Others v Woolwich Building Society (Thompson) [1997] SC (HL) 66 Governmental Publications Parliamentary Hansard, 13 Mar 1997 : Column 438 Footnotes [1] As described under s 1(2) of the 1984 Act [2] s 5(1) [3] The offence is deemed to be criminal under s 5(5) [4] R v Brown [1994] QB 547 [5] R v Brown [1996] 1 ALL ER 545 at p 548g [6] ibid at p 549a [7] Which appears under s 1(9) of the 1994 Act [8] ibid per Lord Goff at p 549h [9] Referred to by Lord Goff at p 550b [10] ibid at p 550f-h [11] [1960] 1 QB 394 [12] Referred to by Lord Hoffman at p 560h of the judgement. [13] Per Lord Hoffman at p 560j [14] Per Lord Hoffman at p 561b [15] Lord Januncey of Tullichettle also dissented but merely concurred with Lord Chieveley. See the judgement at p 555h [16] All the judges of the House of Lords rejected this premise, see also ibid per Lord Hoffman, at p 558h [17] Cmnd 8535, Annex A [18] Parliamentary Hansard, 13 Mar 1997 : Column 438 [19] See the bad result in the case of Sharp and Others v Woolwich Building Society [`997] SC (HL) 66 [20] Since enactment of the Human Rights Act 1998, it is now the duty of judges to interpret legislation in line with the rights set out under the European Convention of Human Rights

Whispered Economics Free Essay Samples Secrets

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Tips For Choosing Civil Rights Essay Topics

<h1>Tips For Choosing Civil Rights Essay Topics</h1><p>How to choose Civil Rights Essay Topics that will resound with a youthful peruser is a significant issue. That is the reason each educator should set aside the effort to survey the entirety of the distinctive composing subjects that are accessible for their understudies. Your objective, obviously, is to get them amped up for the subject and to keep them intrigued through the entire task. Here are a few points you may need to consider.</p><p></p><p>The Civil Rights development has been a necessary piece of the American lifestyle. Previously, the Constitution was a lot of worried about the insurance of the privileges of minorities. In any case, today, it has extended and the United States ensures a considerable lot of its residents their social equality. A social equality paper on this theme will give your understudies a thought of what we mean by common rights.</p><p></p> <p>Of course, Oprah Winfrey has caused her name as a national fortune and it to can be hard to abstain from talking about her well known TV program. You'll need to incorporate a tad of Winfrey history in your understudies' Civil Rights Essay. Obviously, her TV programs have sat idle yet carry exposure to her brand.</p><p></p><p>During the beginning of the nation, numerous individuals accepted that high contrast guardians brought up their kids in an unexpected way. Today, a great many people acknowledge the way that youngsters ought to be raised by their organic guardians. Yet, with regards to issues like reception, youngsters have more opportunity than any time in recent memory. They can have a state in the choice to be embraced by a specific family.</p><p></p><p>This sort of exposition could go far towards getting your understudies intrigued by human rights issues. Our legitimate framework shields us from the activities of indiv iduals who need to remove our privileges. In the event that you ask somebody who they believe is liable of human rights infringement, you'll likely discover them think the legislature. Along these lines, it is a smart thought to address this issue ina Human Rights Essay topic.</p><p></p><p>Religious bunches additionally have incredible subject to expound on. Obviously, the holy book will consistently be a most loved of most youngsters. You can give your understudies a prologue to different religions, including Christianity, Judaism, and Islam.</p><p></p><p>Another incredible social equality exposition subject is national parks. With expanding improvement, our national parks are getting less available. Be that as it may, the National Park Service keeps on ensuring a significant number of our most lovely characteristic regions. Make your understudies mindful of how this taxpayer supported organization secures our environment.</p>&l t;p></p><p>Before you round out the structure for the school or article rivalries, you can without much of a stretch quest online for Civil Rights Essay Topics. A ton of secondary schools have various distinctive point choices to browse. To get the best ones, you have to inquire about altogether and ensure your paper is well written.</p>

Essay about Where Has My Job Gone - 2366 Words

Where Has My Job Gone? With the implementation of minimum wage and rising production costs in the United States, many companies have found themselves looking for a way to save money on production. Clothing manufacturers such as Nike have used labor forces in other countries, mainly in Asia to produce their products. These countries can offer similar quality labor for a cheaper cost on wages. The lower or non existent minimum wage laws in foreign countries allow companies like Nike to cut production costs drastically, while still being able to produce quality products. Similar trends are starting to creep into software companies. They are finding a workforce able to do similar work as the American workers, but for less pay.†¦show more content†¦Similar companies can outsource less important software, but reassign current personnel to projects that would require â€Å"on site† work. Also, companies that outsource will gain access to capabilities and expertise of the countries they outsource to. The people of India grow up in a different society and have a different outlook on life. This would give them a different approach to problems in software, which can make certain problems seem simple. Furthermore, the competencies developed over in India can also be utilized by companies. Based on an economic model from Adam Smith, Countries have different endowments. Differing climates give advantages to the production of different crops. Differing histories and inclinations result in different advantages in finance, skills and manufacturing. If each country specializes in areas where its advantages are greatest or disadvantages are least, the gains from trade will make each country better off than it would be if it remained self-sufficient. 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Research Paper Topics - 2 Options For Your Research Paper

<h1>Research Paper Topics - 2 Options For Your Research Paper</h1><p>A part of understudies these days request the exploration paper subjects that they can use for their tests. Notwithstanding, there are loads of them and it is extremely difficult to pick among them.</p><p></p><p>You ought to deliberately consider what subject you will expound on with the goal that it won't be unreasonably difficult for you to compose an examination paper and you can get An in your course. Here are some examination paper subjects that you can pick from:</p><p></p><p>With the developing dangers of hacking, data fraud, security breaks, and dangers, it is imperative to contemplate the essentials. Ensure that you know all the intricate details of PC security. This incorporates breaking passwords, decoding, and how to shield your PC from security penetrates and viruses.</p><p></p><p>There are numerous issues with res pect to online security issues. On the off chance that you need to get An in your course, you have to take seminars on digital dangers, online wholesale fraud, and computerized legal sciences. In the event that you need to become familiar with web security, you have to investigate the following:</p><p></p><p>You can get more data about advanced legal sciences and the various kinds of computerized criminology. The material that you learn will assist you with finding out about web hacking, secret key splitting, and different kinds of data theft.</p><p></p><p>Many understudies imagine that arrange security can be learnt by considering the rudiments. Be that as it may, this isn't accurate. They additionally get baffled since they feel that there is no viable experience or hands-on information in PC networks.</p><p></p><p>It is a smart thought to do two or three labs in school after you graduate with the goal that yo u can get some down to earth understanding. Along these lines, you will get an involvement with which you can make malware and other sort of malignant programming. This will assist you with seeing how PC systems are utilized by programmers and viruses.</p>

Wwi Essay Topics - How to Write Your Topic

Wwi Essay Topics - How to Write Your TopicWhen applying for a Wwi, you must use the information given in your thesis for essay topics. It is vital that you write on topics that closely relate to your learning and the subject matter of your thesis.Writing an essay is not as easy as it seems because it involves a lot of decision-making processes. Since your topic is very important, you should put your focus on it. If you do not know how to write an essay topic that will suit your subject matter and research skills, you can take some help from the Internet.There are a lot of writers who have compiled lists of topics for Wwi essay topics. If you would like to use this list to know how to write an essay, then you should take their suggestions into consideration. The point is, if you have taken the time to follow the writing tips from these sources, then you should start writing.The Internet has lots of information on different topics. You can simply browse the Web and find some lists of t opic ideas and write on them. They will teach you how to properly list your topics. It is also advisable to read this information before you start writing the essay so that you will be able to know the exact outline of your essay.You should also follow some rules for writing your Wwi essay. First, you should first think about your topic and then figure out how you can make it work. Then, you must identify your topic.For example, if you would like to write about car manufacturing, you should first think about how to make your topic related to your thesis. As long as your topic is interesting and relevant to your thesis, you can always make it more interesting by including facts that could give an idea of your topic. Then, you can choose your essay topic according to the type of study that you are doing. Therefore, you have to be specific about the type of topic you are writing about.You may also find it interesting to compare different topics. You can always use different information on your topic to show that this topic is no ordinary. For example, if you would like to write about organic food products, you can put certain points about these products that would prove to be interesting. Or, you can find some information about these products and then write about them.In writing your Wwi essay, you need to find out what it is that you would like to achieve with this essay. This is the reason why you need to learn how to write an essay topics and not just a list of topics.

Essay on Global Warming Humans Are Destroying the Planet

Everyone knows that global warming is a serious environmental health problem with its effects reflecting on nature and all of mankind on Earth since the mid-twentieth century – emission of concentrated greenhouse gases, rise of sea levels, melting of polar ice caps, and increase in global surface air temperature. The rise in global surface air temperature causes frequent droughts in dry areas and accelerated ocean warming and hence the rapid increase in sea levels and melting of the polar ice caps. Natural disasters from the unpredictable weather patterns were also observed over the past few years. With these effects in mind, we know that the biodiversity of wildlife is greatly affected. But how exactly does global warming present a threat†¦show more content†¦(Derocher, Lunn and Stirling 163-164). Based on the United States Geological Survey (USGS) studies, species such as the polar bear is an example of pagophilic mammals. Polar bears prefer habitats near the continental shelf and with sea ice partially covered, â€Å"likely due to higher biological productivity (qtd. in Dunton et al. 2005 2 ), and greater accessibility to prey in near shore shear zones and polynyas† (qtd. in Stirling 1997 2). These species are in danger because their habitat is affected by the change in climate which is melting the sea ice. Not only are their homes being melted away, this also means that there are warmer waters which affect their productivity in its marine environment. Global warming causes a longer duration of summer season in the North, where polar bears are restricted to relatively unproductive warmer Arctic waters which reduce its survival rate and may eventually reduce populations. (qtd. in Derocher et al. 2004). 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James Decartes Essay Example For Students

James Decartes Essay World War I left many families dead, creating large numbers of orphans. Jamaie (later to become James) Decartes was one of those orphans. His father died in the trenches in France, and his mother was stolen away, never to be seen again. James was 14 when this happened, he hid under floor boards when his mother was taken away. His humble french hometown village, was over run with german foot traffic, traveling to and from the front line. James decided this was no life for him, so he ran south, towards Switzerland, which he knew wasnt involved in the war, trying to seek asylum. He traveled by the cover of night, seeking charity from locals, and trying dodge the german military machine. James refused to be beaten by the germans, he would sabotage trucks, and other equipment, to do his part for his country. His spirit was undominatable, which is probably why his sire Sven Troile took notice of him. Sven had recently left Russia, due to the war, and the hardships with kindred politics there. Sven sought to establish a brujah presence in the toreador dominated france after the war. For this Sven would need help, taking notice of James, he watched over him and his travel, not letting himself be known. James may very well have died, if it werent for Sven, but James didnt know that. Eventually James made it to switzerland, being a neutral party in the war, the soilders would not let him enter the country. Confused as to what to do than, he started towards spain, but feared that he would find no security there. Along his way towards spain, he met up with a swiss farmer outside the country lines (through some persuasion down the road from sven), he was invited to be smuggled inside the country. This is when he first met Sven, whos very presence awed James. James, who was still young and impressionable, quickly latched onto Svens magnetic personality. James thought Sven was hiding for the war also, which gave him more room. Sven promised James they would go back to France when the war was over, and James was eager to return home and make a name for himself. Sven and James lived out the war in Bern, Switzerland, enjoying the night life, which James never questioned, as he had become accustomed to it, as he viewed it as safer at night for people illegally in the country. No one ever asked any questions, as Svens swiss was nearly perfect. During their stay in Switzerland, Sven continually dropped hints about his true nature and society, to make it easier for James to figure out. After the war, when James was 18, He and Sven returned to France. They went to a city called Loire, a large growing metropolis in western France. James saw less of Sven than, as Sven always had business to attend too. James worked for a man Sven new, named Bennito Turen (an Italian man), down at the shipping docks. After a year of service to Bennito, he got angry, James did not know why, but he did. Bennito was beat James near death (james couldnt believe how strong bennito was), when Sven showed up. James wasnt sure why, maybe it was because his head had been hit, but Sven seemed to move with blinding speed, and hit with amazing power. Sven beat Bennito down, and into the water, and came to James. Not knowing any other way to save James, Sven embraced him, his wounds healing, and the power of unlife throbing through his now undead veins. James was shocked by his transformation, but not angered. .u1233fbb9fd9151941f4062eac02ec3f0 , .u1233fbb9fd9151941f4062eac02ec3f0 .postImageUrl , .u1233fbb9fd9151941f4062eac02ec3f0 .centered-text-area { min-height: 80px; position: relative; } .u1233fbb9fd9151941f4062eac02ec3f0 , .u1233fbb9fd9151941f4062eac02ec3f0:hover , .u1233fbb9fd9151941f4062eac02ec3f0:visited , .u1233fbb9fd9151941f4062eac02ec3f0:active { border:0!important; } .u1233fbb9fd9151941f4062eac02ec3f0 .clearfix:after { content: ""; display: table; clear: both; } .u1233fbb9fd9151941f4062eac02ec3f0 { display: block; transition: background-color 250ms; webkit-transition: background-color 250ms; width: 100%; opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; background-color: #95A5A6; } .u1233fbb9fd9151941f4062eac02ec3f0:active , .u1233fbb9fd9151941f4062eac02ec3f0:hover { opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; background-color: #2C3E50; } .u1233fbb9fd9151941f4062eac02ec3f0 .centered-text-area { width: 100%; position: relative ; } .u1233fbb9fd9151941f4062eac02ec3f0 .ctaText { border-bottom: 0 solid #fff; color: #2980B9; font-size: 16px; font-weight: bold; margin: 0; padding: 0; text-decoration: underline; } .u1233fbb9fd9151941f4062eac02ec3f0 .postTitle { color: #FFFFFF; font-size: 16px; font-weight: 600; margin: 0; padding: 0; width: 100%; } .u1233fbb9fd9151941f4062eac02ec3f0 .ctaButton { background-color: #7F8C8D!important; color: #2980B9; border: none; border-radius: 3px; box-shadow: none; font-size: 14px; font-weight: bold; line-height: 26px; moz-border-radius: 3px; text-align: center; text-decoration: none; text-shadow: none; width: 80px; min-height: 80px; background: url(https://artscolumbia.org/wp-content/plugins/intelly-related-posts/assets/images/simple-arrow.png)no-repeat; position: absolute; right: 0; top: 0; } .u1233fbb9fd9151941f4062eac02ec3f0:hover .ctaButton { background-color: #34495E!important; } .u1233fbb9fd9151941f4062eac02ec3f0 .centered-text { display: table; height: 80px; padding-left : 18px; top: 0; } .u1233fbb9fd9151941f4062eac02ec3f0 .u1233fbb9fd9151941f4062eac02ec3f0-content { display: table-cell; margin: 0; padding: 0; padding-right: 108px; position: relative; vertical-align: middle; width: 100%; } .u1233fbb9fd9151941f4062eac02ec3f0:after { content: ""; display: block; clear: both; } READ: Walt Whitmans Evolution Essay He had expected something like this to happen, througout his traveles with Sven. Over the next year, Sven taught all he could to James, who proved to be a very apt student. James, not only learning scholarly things from Sven, he taught himself how to fight. He never wanted to be beaten again, like he was by Bennito, whom James found out was also a vampire, called a Giovanni. He lived in france with Sven learning all he could know for 8 years. But as James wasnow a Brujah,