Sunday, May 17, 2020
Essay on The Devil in Massachusetts Book Review - 796 Words
The Salem witch craft trials are the most learned about and notable of Europes and North Americas witch hunts. Its notoriety and fame comes from the horrendous amount of people that were not only involved, but killed in the witch hunt and that it took place in the late 1700s being one of the last of all witch hunts. The witch craft crises blew out of control for several reasons. Firstly, Salem town was facing hard economic times along with disease and famine making it plausible that the only explanation of the towns despoilment was because of witches and the devil. As well, with the stimulation of the idea of witchs from specific constituents of the town and adolescent boredom the idea of causing entertainment among the town was anâ⬠¦show more contentâ⬠¦When discussing the indictment of Bridget Bishop in Boyer and Nissenbaums documents it states separately the complaint, examination offense and testimonies of all the witnesss continuously from pages 36-52 . It follows a close chronological order of the proceedings from start to finish. However in Starkeys version the events surrounding Bishop are spread throughout the book. While the major focus of the indictment and trial was on pages 104-108 other information was placed in sporadically, like for example, her personal style ...she had a great store of laces. These she liked to vary, and sometimes brought pieces to Samuel Shattuck of Salem Town to have dyed. While that may be historically correct it is hardly relevant to the indictment or court proceedings and is also not even an attempt or a good one, to establish character persona. Starkeys version confuses and hinders the collection of information because of the drawn out and detailed description of each person, event and location. While it is clear with Starkeys depiction of the events that she is not going for an intellectual documentation of straight facts, however her vocabulary and the terms she uses for explanation is some what `challenging for those that this book is geared towards. Starkey uses confusing historical terms in a book that is clearly written in present day English. For example when explaining when an event takes place, ...were placed in a cart andShow MoreRelatedThe Salem Witch Trials : Crisis1601 Words à |à 7 PagesThe Salem Witch Trials: Crisis in Salem Village Many people know of the Salem witch trials that took place in Salem, Massachusetts in the year 1692 spilling over into the year 1693. But for those who do not know, the Salem witch trials were a series of trials against men, women, and children accused of being a witch and or practicing witchcraft. In ââ¬Å"The Devils Snare: The Salem Witch Trials of 1692â⬠by Mary Beth Norton, the author recollects the stories of real life accounts of those accusers andRead MoreNathaniel Hawthorne s Influence On American Literature And The Genre Of Romanticism Essay1472 Words à |à 6 Pagesinterest in what was considered the unknown such as witchcraft and science. According to the Norton Anthology Textbook Vol. B, Nathaniel Hawthorne was ââ¬Å"born in Salem, Massachusetts in 1804â⬠(370). Hawthorne belonged ââ¬Å"to a family whose ancestral roots were tied to Puritan history, with his family being among the first settlers of Massachusetts and having one of his relatives serve as a jud ge during the Salem witch trialsâ⬠(370). Hawthorne, as a young boy, ââ¬Å"had a particular interest in writings such as JohnRead MoreAllegory and Symbolism in Nathaniel Hawthorneââ¬â¢s ââ¬Å"Young Goodman Brownâ⬠1203 Words à |à 5 Pagesthat Hawthorne uses in ââ¬Å"Young Goodman Brownâ⬠is the village in which the story takes place, Salem village in Massachusetts. The reason that the village is symbolic to the story is because of what occurred in Salemââ¬â¢s history. According to Susan Balee, a writer for The Hudson Review, ââ¬Å"the witchcraft crisis overwhelmed Salem in 1692â⬠(Balee 377). During this time it was thought that the devil lived in the forests of Salem. The Puritans were accusing each other of being a witch and it led to the deathsRead MoreSalem Witch Trials : A Series Of Events That Occurred3696 Words à |à 15 PagesCitizens within Salem started to accuse the men and women who acted out as witches, increasing mistrust and hyster ia within Salem. The numerous allegations lead to hearings and prosecutions of the people who were accused of witchcraft in colonial Massachusetts. The trials resulted in the executions of twenty people, most of which were women. Additionally, the accusations lead to community wide hysteria and blood thirst for the death of nearly all the accused witches. Therefore, the Salem Witch TrialsRead MoreMinutes of Glory1451 Words à |à 6 Pagesperformance of his first major play, The Black Hermit, at the National Theatre in Kampala, Uganda, in 1962, as part of the celebration of Ugandaââ¬â¢s Independence. ââ¬Å"Ngugi Speaks for the Continent,â⬠headlined The Makererian, the Student newspaper, in a review of the performance by Trevor Whittock, one of the professors. In a highly productive literary period, Ngugi wrote additionally eight short stories, two one act plays, two novels, and a regular column for the Sunday Nation under the title, As I SeeRead MoreThe Effects Of Hyster ia In The Crucible1489 Words à |à 6 Pagesbe accounted for. Hysteria is a major leader in past and present day society when it comes to how people act and think in different situations. The Crucible provides great examples with how hysteria can affect a group of people. Back in Salem, Massachusetts 1692, hysterics swept the town, creating storms of emotion. Everyone is wondering, what to do? What to think? In The Crucible, Arthur Miller uses the effects of mass hysteria to reveal his purpose of using it in his writing, how society at thatRead MoreHysteria In The Crucible1474 Words à |à 6 Pagesuncontrollable emotion among groups, is a major leader in past and present day society when it comes to how people act and think in different situations. The Crucible provides great examples with how hysteria can affect a group of people. Back in Salem, Massachusetts 1692, hysterics swept the town, creating a storm of emotions. Everyone wondering, what to do? What to think? In The Crucib le, Arthur Miller uses the effects of mass hysteria to reveal his purpose of using it in his writing, how society at thatRead More The Name Of War, Jill Lepore Essay859 Words à |à 4 Pages Book Review The Name of War: King Philips War and the Origins of American Identity Our history books continue to present our countrys story in conventional patriotic terms. America being settled by courageous, white colonists who tamed a wilderness and the savages in it. With very few exceptions our society depicts these people who actually first discovered America and without whose help the colonists would not have survived, as immoral, despicable savages who needed to be removed by killingRead MoreThe And Folklore Of All Hallows1629 Words à |à 7 Pagesfrightening faces on pumpkins to scare the spirits off as well.(As we do today but differs on how the person perspects this holiday). In conclusion we still carry on this tradition today, except those who find this a holiday a way of greeting the devils and his spirits. Miller Arthur Biography. www.biography.com/people/arthur-miller-9408335. Accessed August 11, 2016. Arthur Miller, born in Harlem, New York October 17, 1915, was a man who had changed many perspectives on the way peopleRead MoreReview of The Crucible Essay1479 Words à |à 6 PagesReview of The Crucible The Crucible was set in Salem, Massachusetts, 1692. The government was a theocracy, ruled by god through religious officials. Hard work and church consumed
Wednesday, May 6, 2020
William Shakespeare s Oedipus And Othello
Oedipus and Othello are two of the most known tragic heroes throughout all of literature. While there are some noticeable differences between the two there are also many similarities between the two characters. With the amount of similarities between the two plays Shakespeare must have been inspired by Oedipus and Sophocles when he was writing Othello. Oedipus the kingââ¬â¢s main conflict is based around Greek mythology in that from the time Oedipus is born it is prophesied by the Gods that he is going to kill his father and marry his mother. Sophocles uses a lot of dramatic irony in order to develop the conflict for the spectators, such as when Oedipus says to Tiresias ââ¬Å"Youââ¬â¢ve lost your power, stone-blind,stone-deaf-senses,eyes blind as stoneâ⬠(Sophocles 423-424). Oedipus says this because he refuses to believe that the prophecy that Tiresias is telling is true meanwhile the audience is already aware that Tiresias is telling the truth. The main conflict and them e of this story is between Oedipus and himself because he cannot trust anyone except for himself and in the end, it leads to his own demise. Oedipus can be seen as a dynamic character because at the beginning he is very prideful and at the end, he can be considered fearful of what fate has brought to him. Shakespeare could have been inspired by Sophocles, because Othello has a similar self conflict in that he refuses to believe the truth from the people that he is supposed to trust. Shakespeare also uses dramaticShow MoreRelatedOthello is Not a Tragic Hero Essay1481 Words à |à 6 PagesOthello has been described as one of William Shakespeareââ¬â¢s most popular plays because the play focuses on its themes of good and evil, military, politics, love and marriage, religion, racial prejudice, gender conflict, and sexuality; but the controversy and debate surrounding Othello is ââ¬Å"Why is Othello a qualification for a tragedy?â⬠Most readers are aware of the many famous deaths or acts of death within the Shakespearean plays. And when the main characters die in Shakespeareââ¬â¢s plays, indeedRead MoreThe Origins Of Drama And Theatre2001 Words à |à 9 Pages(Aristotle 18-19). While these components stand strong on their own, Aristotle explains that the best plots come from those two components acting simultaneously. An exquisite example of these two components working together is in Oedipus Rex, when the shepherd tells Oedipus that there is a chance that he is the one that the long foretold prophecy is about (Sophocles 62). Aristotle explains that they are best when they are together because the reversal and recognition bring about a sense of pity andRead MoreOthello Notes2305 Words à |à 10 PagesOthello Notes: Assessment Objectives: AO1: A consistently fluent, precise writing, using critical terminology to present a coherent and detailed argument in which the question is well understood and answered. AO2: Well developed, analytical and consistently detailed discussion of effects of language, form and structure and ways in which it affects the audience. AO3: Well informed and detailed discussion of different readings of the text by various audiences, as well as different criticalRead MoreCritical Analysis Of Othello1461 Words à |à 6 Pages William Shakespeare playwrights cleverly provide the ability to generate and develop symbolism to another state. Shakespeare plays discuss a sense of morality and tend to focus on the psychological state of the character that end in these misfortunate tragedies. Like most Shakespearean plays the characters struggles with internal conflicts that are imperative to the way he or she thinks, their personal beliefs and motives. The personal struggle these characters are face upon is conveyed throughRead MoreAnalysis Of Shakespeare s The Tempest 2603 Words à |à 11 Pages Malouin 11 Measuring a Life in a Drama When many people think of William Shakespeare, they think of plays like Romeo and Juliet, Macbeth or Hamlet. One of the most influential plays written by Shakespeare is not one listed above. The play that reflects the life and all of Shakespeare?s plays is The Tempest. This work was and still is influential in both America, Britain and around the world. Although William Shakespeare was an influential writer in American and British literature, The Tempest
Scholarship Essay Master of Fine Arts Example For Students
Scholarship Essay Master of Fine Arts Earned my Bachelors of Vine Arts Degree in Art Design in 2006 from . Since graduating, I have held two artist residencies and worked as an arts educator in impoverished urban and rural communities. These experiences have made me crave the ability to affect more people in new places with my work, which is why Would like to pursue a Master of Pine Arts degree. Scotland has a rich, 10,000-year-old history. I van to investigate the history of Glasgow shipbuilding industry. M fascinated by formerly industry based urban areas, and how the populations once in these industries (whether it is shipbuilding in Glasgow, steel in Baltimore, or cars in Detroit) change and are affected differently during the height, decline, and renewal periods of the industrial-economic shift. For a performance artist, the Glasgow School of Fine Art provides the perfect academic and cultural environment. The Sagas strong support of students creating work in a variety of media, especially time-based work and perfo rmance, make it a perfect match for my approach to art making. The School is a small, highly focused international community of artists that encourages socially engaged artwork. Several of the Schools faculty members, a number OTTOMH are performances artists, have received or been finalists for the Turner prize. Because the focus of my work is on the reenactment and creative exploration of local histories, I seek to study under Julie Roberts, Edward Stewart, Stephanie Smith, and Alan Curran, Roberts is known for her paintings that investigate objects associated with medical institutions. Edward Stewart and Stephanie Smith are performance artists concerned with researching the politics of identity and gender. Alan Accrual is a master of using his elite, relationships, and surroundings as creative media. Am eager to see how my work responds to, benefits from, and is challenged by an entirely new academic and cultural environment. Anticipate my work in the MEA Program will combine historical research, performance, painting, and installation to further my creative investigation Of local histories. Vision my creative research as a sustained and thorough inquiry into the history of the people, places, and events surrounding the shipbuilding industry in Glasgow.
Monday, April 20, 2020
Salary Negotiation Role
Introduction The success of negotiation totally depends upon the efforts of both sides. Generally, the approaches the applicant and the manager rely on are considered the basic factors, which determine the winner of the negotiation. Win-lose negotiation means both sides to be ready to understand and accept all pros and cons of the salary. In contrast, win-win negotiation provides beneficial terms for each part concerned.Advertising We will write a custom assessment sample on Salary Negotiation Role-Play specifically for you for only $16.05 $11/page Learn More In this respect, the role-play negotiation will help to define different effective tactics and strategies with regard to the goals pursued by the negotiators. A careful analysis of practices and observations will help define which tactics and approaches are the most effective ones. Distributive and Integrative Negotiations First of all, there is a need to point out that successful negotiations depen d upon the strategies the sides rely on. They say that the so-called win-lose approach is mostly based on negative perspective. It means that in most cases any side will win. However, one the other hand, one is to keep in mind that a person who negotiates a lot has more chances to succeed. For this reason, one can state that a person who is more skilled and experienced will be the winner of negotiations. Of course, there is a great difference between distributive negotiations and integrative ones. There are also mixed-motive negotiations, but the company doesnââ¬â¢t rely on them, unfortunately. So, the first two approaches are to be discussed. When win-lose tactics take place, for the applicant it is better not to answer the question, or answer the question in a special manner, so there could be no harm for negotiation position of the applicant. On the other hand, there is also an opportunity to respond with another question, or just listen to the negotiator (Hiring Manager: So, what salary do you expect to get? ââ¬â Applicant: I would like to listen to your offers). This answer means listening and gives an opportunity to respond with another question. On the other hand, the negotiator thinks that he or she has some advantages over the applicant; or he/she understands that the applicant wants to analyze the given information in the first place. Another approach, which is to be discussed, is win-win negotiation. One of the most well known tactics integrate negotiation depends on is the so-called forbearance. One can see that the applicant is searching for the issue the manager can agree with.Advertising Looking for assessment on business economics? Let's see if we can help you! Get your first paper with 15% OFF Learn More In this case, one can understand that delaying action or the so-called procrastination gives the applicant and the manager some more time to consider unresolved point differently. When analyzing the applicantââ¬â¢s int erest in another question, one can admit that the applicant wants to obtain specific information. It is one of the win-win purposes. Adjustment and Concessions Made and the Strategies and Tactics Used By Each Side While analyzing the responses of all the team members, it has been stated that adjustment and concessions are primarily made while using the tactics of integrative negotiation. Specifically, the respondents apply to assumptions and judgments leading to an agreement and compromise. This is explicitly seen from the first remark of Hiring Manager (ââ¬Å"Mr. Applicant, what salary do you expectâ⬠), as well as the one expressed by Applicant (ââ¬Å"Sir, what is the best salary you offer for the position of HR Officer?â⬠). Adjustment statements are also represented by each side of debate while making arrangement concerning when it is possible to start working (Hiring Manager: ââ¬Å"Can you start by tomorrow?â⬠ââ¬â Applicant: ââ¬Å"Yes I can start tomorrowà ¢â¬ ). Regarding other responses presented by team members, features of adjustment are presented in the distributive negotiations, particularly on the part of the Applicant who accepts all the conditions offered by the Hiring Manager, even if not all of them are suitable. Regarding the distributive bargaining represented by Team Members, the concession was made at the end of the dialogue that was accompanied by an ultimate alternative (Applicant: ââ¬Å"If you agree to pay me $ 40000, I will accept your offer otherwise I leaveâ⬠). In such a manner, the initial target point made by the Hiring Manager was an effective strategy because the probability for the Applicant to move closer to a resistant point ($ 50000) was low.Advertising We will write a custom assessment sample on Salary Negotiation Role-Play specifically for you for only $16.05 $11/page Learn More There are many other tactics and strategies used by each side of the negotiation, which a re specifically revealed in the distributive negotiations. Because distributive bargaining is often associated with competition, both the Hiring Manager and the Applicant compete with each other for better conditions. Sources of Power and the Application of Power Influences Employed by Each Side While being involved into negotiations, the opponents should have sources of power that are usually presented as ââ¬Å"best alternative to a negotiated agreementâ⬠, or BATNA (Lewicki et al., 2010, p. 21). The stronger BATNA the opponents have the more chances to win the negotiations. In this respect, the distributive bargaining represented by Team Members provides a bright example where each side takes advantage of different alternatives to gain more power in discussion. Hence, the applicant applies to general statements about qualifications and salaries, as well as companyââ¬â¢s reputation. In addition, the applicant makes the Hiring manager face a difficult choice ââ¬â to acce pt his/her offer, or lose an experienced and qualified employee. In response, the Hiring Manages makes use of facts about their own company, as well as applicantââ¬â¢s situation (The Hiring Manager: ââ¬Å"We know you present boss, Mr. Anderson. He may actually discharge you. There is reconstruction in your companyâ⬠). Judging from the given situation, ââ¬Å"good distributive bargainer identify their realistic alternatives before starting discussions with the other part so they can properly gauge how firm to be in the negotiationâ⬠(Lewicki et al., 2010, p. 21). In this respect, the Hiring Manager has less realistic alternative and, as a result, he/she has failed to stand for the initial target point. Use of Central and Peripheral Route Influence Principles to Effect The Negotiation Outcome Distributive Negotiation While using the tactics of distributive negotiation, peripheral rout is used to convince the applicant to accept a lower salary. This strategy has been used in the discussions by the Team Members who exemplify managers of higher positions, but with low salary levels.Advertising Looking for assessment on business economics? Let's see if we can help you! Get your first paper with 15% OFF Learn More In such a ways, they display the situation and distract the applicant from this intention to increase the salary minimum. Using both central and peripheral routs of influence can maximize the value of deal and provide beneficial option for either of the parties. Integrative Negotiation Indirect approaches have also been used in the integrative bargaining when the Hiring Manager applies to neutral and inviting phrases to make sure the participants that the terms and salaries are beneficial. A central route, therefore, is used to influence the applicant through direct addressing, as it has been presented in the integrative negotiation when the Hiring Manager has immediately proposed to start working the next day right after the job interview. Besides, the Manager has successfully used his/her power and authority to influence the Applicantââ¬â¢s decision. The Ethicality of the Negotiation Tactics of Each Side Achieving the highly beneficial terms is among the priorities of negotiati on. However, the negotiation should take into consideration ethical and moral concerns while using specific arguments in favor and against. In this respect, the ethicality of the argumentation should also come to the forth; alternatively, improper responses can lead to a conflict, which can bring in no benefits of either of the opponents. The probability of conflict emergence is higher while conducting distributive bargaining because it presupposes that one side of debate will lose and another one will gain much more beneficial terms. Regarding the case under analysis, the distributive bargaining has certain inconsistencies in terms of argumentation, which turned out unethical on the part of the Applicant who failed to provide evidence of his/her qualification and experience. Instead, the candidate forwards an ultimatum without reasoning. As per the integrative negotiation, ethical concerns are slightly revealed because both the Applicant and the Hiring Manager seem to agree on the identified terms. Nevertheless, exposing managers from other organizations who took on a salary cut to work at Z-firm could be considered unethical. In addition, this can increase pressure over the candidate and make him/her accept a salary cut. Conclusion Regarding the observations made, it should be concluded that both negotiation strategies have strengths and weaknesses. The study of role-play negotiations has revealed that better terms can be achieved if using persuasive argumentation (central route) and apply to convincing arguments that are not rely on empty promises but known facts and logically constructed justifications. With this in mind, distributive bargaining seems to be more beneficial because it provide more privilege for either of the debating sides. Moreover, it also generates competition and desire of the opponents to prove their assumptions. Reference Lewicki, R. J., Barry, B., Saunders, D. M. (2010). Negotiation. New York, NY: McGraw-Hill. This assessment on Salary Negotiation Role-Play was written and submitted by user Audriana Pacheco to help you with your own studies. You are free to use it for research and reference purposes in order to write your own paper; however, you must cite it accordingly. You can donate your paper here.
Sunday, March 15, 2020
design essays
design essays The Bauhaus in their historical context Architecture us always the will of the age conceived as space, nothing else(438) said Mies, and he was not far from the truth. Thus, it is necessary to place in context the architectural revolution of the Bauhaus in the early 1920s. This revolution was characterized by its constant return to efficiency, clarity and simplicity. It saw architecture as a unifying force for all arts, as well as a reflection of class and sex conflict. But conservatives strongly opposed this equality and social transformation through the arts. This revolution was deeply rooted in the need to find a new identity after Germanys defeat in WWI and the post-industrialized world of airplanes and automobiles. The Bauhaus school an amalgamation of the former Weimar Academy of Fine Art and the Weimar School of Arts and Crafts- was the precursor of the new architectural revolution. It sought to unify the arts under architecture, and develop arts by teaching crafts. Their main goal was the release of creativity. They tried to connect with the public through exhibitions and to develop an architecture that would serve everyone drawing from public funds (Bruno Taut, 432-434; Gropius, 435-438). The post-industrial era was one filled with confusion, noise from fast cars roaming the cities and planes crossing the sky. This architecture sought to simplify life to effectively solve the problems of growing population and hygienic demands. It was aimed towards efficiency, clarity and cleanliness -not only in architecture and design, but in spatial exploitation and furniture. Factory work allowed for the pre-assembly of houses and the use of new materials. Rejection had proved a mistake industrialization was inevitable and architects and arts sought to embrace it to bring it to some understanding and rationalization. It became part of the whole. Another important historical aspect ...
Friday, February 28, 2020
Engineering project management Assignment Example | Topics and Well Written Essays - 750 words
Engineering project management - Assignment Example A large number of employees would increase the rate at which the work will be done and increasing chances of completing the project on time (Panneerselvam & Senthilkumar 2009). The contractor may also employ other technologies and equipment instead of using manpower. The use of machines instead of humans to do certain tasks is normally advantageous since the tasks can be done at high rates there by increasing the chances of completing the project on time (Nagarajan 2007). The contractor may also divide the project into small and more manageable units, and each unit should have a goal to achieve. As for the case of the company, the organization should give additional funding to contract so as to fund the additional works as well as fund additional manpower and/or any new equipment acquired for the task. Another solution that might help the company meet its aims is that the organization may consider subcontracting sections of the order while it is still waiting for the new equipment to be installed. (Word count: 248) Question 2: Safety and Health ramifications and Time scale a) Time scale ramifications Due to safety concerns associated with asbestos, the scope of the project is likely to be changed (removal of the existing duct and its contents). The changing of the scope would mean that other constrains such as time and cost will be adjusted accordingly (Kanda 2011). This means that the project deliverable (installing a new machineââ¬â¢s base) will not be produced on time. The consequence of not completing this project on time is dire to the company since the organization might lose an important order, and due to the cost investment made on the new equipment the organization might be forced to close down. This means that delaying the installation of the base of the new machine is not an option for the organization. b) Safety and Health ramifications Employees are amongst the most important elements for organizations; therefore, there health should be made pri ority (CCH 2009). In addition, safety of environments in which employees work must conform to occupational safety and health standards (Lingard & Rowlinson 2005). Compromising the health of workers by making them work alongside these asbestos ducts would affect health, and consequently their productivity will also be affected (CCH 2009). The organization may also risk being closed down for not following occupational safety standards and regulation. (Word count: 202) Question 3: Consequences of the organization following strict time scales regardless of the presence asbestos a) Consequences If the organization decides to meet the strict time scale without regarding the presence asbestos, the consequences may be dire to the organization. First, as earlier mentioned the employees of the organization may be exposed asbestos to limits more than those specified by occupational health and safety authorities of the region in the organization is operating. The result of this is that the empl oyees may contract heart and lung related ailments, which may in turn affect their productivity (CCH 2009). This means that the organization may fail to meet its current production levels as well as the sales target. Another consequence of following the strict deadline without regarding the presence of asbestos is that the organization may be closed down by the safety and health occupation authority in the area in which it is operating for violating the recommended threshold values of the asbestos.
Wednesday, February 12, 2020
Australian contract law problem question Case Study
Australian contract law problem question - Case Study Example The offer may be oral, written or implied from conduct. Offers are of two kinds: a specific offer is made to a specific offeree. No one else can accept it. 'If you propose to make a contract with A, then B cannot substitute himself for A without your consent and to your disadvantage, securing to himself all the benefit of the contract': see Pollock, CB, Boulton v Jones (1857)1. A general offer can be accepted by anyone, and usually without prior notification of acceptance: Carlill v Carbolic Smoke ball Co. (1893)2. It was found in Carlil that there was: 'an offer made to all the world'; 'to ripen into a contract with anybody who comes forward and performs the condition'; and that 'as notification of acceptance is required for the benefit of the person who makes the offer, the person who makes the offer may dispense with notice to himself if he thinks it desirable to do so.' In the given situation, Elaine's statement 'I will give that bike to anyone who can fix my neck', was clearly a general offer. However, neither it was shown that Kramer has validly communicated his acceptance to Elaine nor it was shown that the latter has dispensed with the notice of acceptance. Clearly, there was no valid and enforceable contract between Elaine and Kramer considering that there was no agreement between the parties. However, it can be argued that acceptance may be done by positive conduct of the offeree as long as the acceptance must be active and that there must be some positive act by the offeree: Felthouse v Bindley (1862)3. Hence, Kramer may argue that by massaging Elaine, he has communicated his acceptance by positive conduct to Elaine. Furthermore, a valid offer has certain characteristics: certainty (a promise to pay an extra 15 or 10 buy another horse if a horse 'proves lucky to me' is too vague to amount loan offer: Guthing v Lynn [1831])4 and communication (an offer must be communicated to the offeree before it can be accepted.) Thus, if a seaman helps to navigate a ship home without informing the owners in advance, he cannot insist on payment, since the owners have not had notice of his offer, and, therefore, no opportunity to accept or reject it: Taylor v Laird (1856)5. Thus, in the given situation, the promise 'I will give that bike to anyone who can fix my neck' lacks the requirement of certainty. Such promise is similarly too vague as the promise to pay an extra 15 or 10 buy another horse if a horse 'proves lucky to me' to amount to a loan offer: Guthing v Lynn [1831]) In several cases, it has been ruled that preliminary statement may not amount to an offer. An invitation to treat which is a statement that is intended to elicit an offer from someone else has been ruled to have no legal force as the offer it elicits can be accepted or not without obligation: Gibson v Manchester City Council (1979).6 Moreover, a statement of the price at which one is prepared to consider a selling a piece of land or any communication of information in the course of negotiations is a mere preliminary statement which were held not to be an offer. In the given situation, it can be argued that Elaine's statement was a mere preliminary statement which does not constitute a valid offer. Moreover, another requirement in the creation of a valid and enforceable contract is an intention to create legal relations. In an agreement between friends in a domestic arrangements, there is a presumption
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