title: The Million Dollar Homepage

text: The concept was described as "simple and brilliant", "clever", "ingenious", and "a unique platform [for advertising] which is also a bit of fun". Professor Martin Binks, director of the Nottingham University Institute for Entrepreneurial Innovation, said, "It is brilliant in its simplicity ... advertisers have been attracted to it by its novelty ... the site has become a phenomenon." "Popular Mechanics" said: "There's no content. No cool graphics, giveaways or steamy Paris Hilton videos for viewers to salivate over. Imagine a TV channel that shows nothing but commercials, a magazine with nothing but ads. That's The Million Dollar Homepage. An astonishing example of the power of viral marketing." Don Oldenburg of "The Washington Post" was one of the few without praise for the site, calling it a "cheap, mind-bogglingly lucrative marketing monstrosity, an advertising badlands of spam, banner ads and pop-ups." Oldenburg continues, "it looks like a bulletin board on designer steroids, an advertising train wreck you can't "not" look at. It's like getting every pop-up ad you ever got in your life, at once. It's the Internet equivalent of suddenly feeling like you want to take a shower."


title: The Million Dollar Homepage

text: As the final pixels were being auctioned, Tew was interviewed on "Richard & Judy", and profiled in the online BBC News Magazine. "The Wall Street Journal" wrote about The Million Dollar Homepage and its impact on the Internet community. "Mr. Tew himself has taken on celebrity status in the Internet community ... the creative juice ... paints an interesting picture of online entrepreneurship".


title: The Million Dollar Homepage

text: Tew dropped out of the business degree the site was set up to fund after one term. In 2008, Tew founded Popjam, an Internet aggregation and social networking business. On May 4, 2012, Tew co-founded software company Calm with Michael Acton Smith. As of 2016, Tew was working as an entrepreneur in San Francisco.


title: The Million Dollar Homepage

text: As of 2017, only the main page of the website was available, with all sub pages returning a 404 Not Found message. A 2017 study by Harvard University found that the links on the still-live main page of the site demonstrated a considerable degree of link rot. Of the 2,816 original links, 547 (342,000 pixels, sold for $342,000) were dead, and 489 (145,000 pixels, sold for $145,000) redirected to a different domain. The report stated that, of the remaining links, that "the majority do not seem to reflect their original purpose". By April 2019, according to the BBC, approximately 40% of the site's links were suffering from link rot. The site was still receiving several thousands of viewers per day.


title: The Million Dollar Homepage

text: Many other sites sold advertising by pixels. Tew said of the sites, "[they] popped up almost immediately; now there are hundreds of Web sites selling pixels. The copycats are all competing with each other." "...they have very little ads, therefore I guess it's not going too well for them. The idea only works once and relies on novelty ... any copy-cat sites will only have pure comedy value, whereas mine possibly has a bit of comedy PLUS some actual pull in advertising dollars ... so I say good luck to the imitators!"


title: Kevin Rankin (actor)

text: Kevin Rankin (born April 18, 1976) is an American actor. He is known for his roles as Herc in the NBC series "Friday Night Lights", Tyler Briggs in the NBC series "Trauma", Roe Sanders in the CBS series "Unforgettable", Kenny in the AMC series "Breaking Bad", and Derek "Devil" Lennox in the FX TV series "Justified".


title: Kevin Rankin (actor)

text: Rankin was born in Baton Rouge, Louisiana in 1976. Up to age eleven, he also grew up there with his parents and three older sisters. The family then moved to Houston, Texas, where Rankin finished high school.


title: Kevin Rankin (actor)

text: After watching the television show "The Fall Guy", Rankin originally intended on becoming a stunt man, until he realized the main character, a stunt man, was, in fact, played by an actor, Lee Majors.


title: Kevin Rankin (actor)

text: Rankin began his acting career with an appearance on the television show "Unsolved Mysteries". He began his acting career in 1997 with a small role in the drama film "The Apostle". Starting in 2000, roles in various television series followed, notably "Buffy the Vampire Slayer", "NYPD Blue" and "Philly". In 2002, he starred as "Doc" in eleven episodes of the series "My Guide to Becoming a Rock Star". He also had other, longer-running appearances in "Undeclared", "Six Feet Under", "State of Mind", "Bionic Woman", and "Friday Night Lights".


title: Kevin Rankin (actor)

text: In 2009, he landed the role of "Tyler Briggs" in the NBC series "Trauma". However, the series was canceled after the first season with 18 episodes. In 2011, he guest-starred in five episodes of the HBO drama "Big Love". He played a main role in the criminal series "Unforgettable" from 2011-12. After a restructuring of the show, his character was dropped in the second season. Since 2017, he has played Bryce Hussar in TNT's drama "Claws".


title: Kevin Rankin (actor)

text: In 2000, Rankin moved to Los Angeles, where he met Jill Farley. At the shooting of the pilot episode of "Trauma", he proposed to her. They married on October 23, 2010, and have a son and daughter together.


title: Mrs. 'Arris Goes to Paris

text: Mrs. 'Arris Goes to Paris is a novel written by Paul Gallico and published in 1958. In the United Kingdom, it was published as Flowers for Mrs Harris. It was the first in a series of four books about the adventures of a London charwoman.


title: Mrs. 'Arris Goes to Paris

text: The plot revolves around Ada Harris, who is so enchanted by her employer's couture wardrobe that she becomes determined to go to the House of Dior in Paris to purchase an evening gown of her own. She achieves her goal with the assistance of a French marquis, whom she first meets at the house of Dior during an afternoon showing and who becomes a long-term friend as do a series of other characters revealed to have hidden hearts. The comic tale takes on a final poignant overtone when the dress is loaned to an up-and-coming actress, with disastrous consequences. Initially devastated, Mrs. Harris reflects that the experiences she had in pursuit of the dress were worth its loss.


title: Mrs. 'Arris Goes to Paris

text: Subsequent titles in the series are "Mrs. 'Arris Goes to New York" (1960), "Mrs. 'Arris Goes to Parliament" (1965), and "Mrs. 'Arris Goes to Moscow" (1974). (The original U.K. titles were "Mrs Harris Goes to New York", "Mrs Harris MP", and "Mrs Harris Goes to Moscow".)


title: Mrs. 'Arris Goes to Paris

text: In "New York", the French Count re-appears and, again, all but one or two characters reveal hidden hearts.


title: Mrs. 'Arris Goes to Paris

text: In "Parliament", Mrs Harris finds that being nice, kind and hopeful does not always lead to people being nice and kind in return. There is rather less comedy in this third book.


title: Mrs. 'Arris Goes to Paris

text: In "Moscow", Mrs Harris wins a trip there and stumbles onto the Soviet Union's most embarrassing problem: it has bought a cargo of toilet paper that has had to be marked as birdseed.


title: Mrs. 'Arris Goes to Paris

text: A musical-theatre adaptation, "Flowers for Mrs Harris", with book by Rachel Wagstaff and music and lyrics by Richard Taylor, was produced by Sheffield Theatres in May 2016, directed by Daniel Evans, having been originally commissioned by Vicky Graham Productions. The production won three UK Theatre Awards: Best Design (Lez Brotherston), Best Performer in a Musical (Clare Burt in the titular role) and Best Musical Production. The awards were presented at the UK Theatre Awards 2016 ceremony at London's Guildhall in October 2016. A new production was mounted at Chichester Festival Theatre in September 2018, again directed by Daniel Evans, starring Clare Burt once more as Mrs Harris, alongside Joanna Riding as Lady Dant/Madam Colbert, Claire Machin as Violet Butterfield, and Gary Wilmot as the Major/Monsieur Armand. The production was streamed online to great acclaim in April 2020.


title: Mrs. 'Arris Goes to Paris

text: The complete 2018 Chichester Festival Theatre cast and orchestra reassembled over 3 days in July 2020 to record the score. The recording took place on stage at the Festival Theatre, due to the COVID 19 pandemic making it impossible to record in a studio, whereas the Festival Theatre stage was large enough to accommodate full cast and band, sufficiently distanced. It was conducted by Tom Brady and recording engineer was Mike Walker. The recording was released in 2020.


title: Saola

text: The saola (Pseudoryx nghetinhensis), also called spindlehorn, Asian unicorn, or infrequently, Vu Quang bovid, is one of the world's rarest large mammals, a forest-dwelling bovine native to the Annamite Range in Vietnam and Laos. It was described in 1993 following a discovery of remains in Vũ Quang National Park by a joint survey of the Vietnamese Ministry of Forestry and the World Wide Fund for Nature. Saolas have since been kept in captivity multiple times, although only for short periods as they died within a matter of weeks to months. The species was first reported in 1992 by Do Tuoc, a forest ecologist, and his associates. The first photograph of a living saola was taken in captivity in 1993. The most recent one was taken in 2013 by a movement-triggered camera in the forest of central Vietnam. It is the only species in genus Pseudoryx.


title: Saola

text: In May 1992, the Ministry of Forestry, Vietnam sent a survey team to examine the biodiversity of the newly established Vu Quang National Park. On this team were Do Tuoc, Le Van Cham and Vu Van Dung (of the Forest Inventory and Planning Institute); Nguyen Van Sang (of the Institute of Ecological and Biological Resources); Nguyen Thai Tu (of Vinh University); and John MacKinnon (of the World Wildlife Fund). On 21 May, the team procured a skull featuring a pair of strange, long and pointed horns from a local hunter. They came across a similar pair in the Annamite Range in the northeastern region of the reserve the following day. The team ascribed these features to a new bovid species, calling it the "saola" or the "Vu Quang ox" to avoid confusion with the sympatric serow. The WWF officially announced the discovery of the new species on 17 July 1992.


title: Saola

text: According to biodiversity specialist Tony Whitten, though Vietnam boasts a variety of flora and fauna, many of which have been recently described, the discovery of as large an animal as the saola was quite unexpected. The saola was the first large mammal to be discovered in the area for 50 years. Observations of live saola have been few and far between, restricted to the Annamite Range.


title: Saola

text: The scientific name of the saola is "Pseudoryx nghetinhensis". It is the sole member of the genus "Pseudoryx" and is classified under the family Bovidae. The species was first described in 1993 by Vu Van Dung, Do Tuoc, biologists Pham Mong Giao and Nguyen Ngoc Chinh, Peter Arctander of the University of Copenhagen and John MacKinnon. The discovery of saola remains in 1992 generated huge scientific interest due to the animal's special physical traits. The saola differs significantly from all other bovid genera in appearance and morphology, enough to place it in its own genus ("Pseudoryx").


title: Saola

text: A recent sequencing study of ribosomal mitochondrial DNA of a large taxon sample divides the bovid family into two major subfamilial clades. The first clade is the subfamily Bovinae consisting of three tribes: Bovini (cattle and buffaloes, including the saola), Tragelaphini (Strepsicerotini) (African spiral-horned bovids) and Boselaphini (the nilgai and four-horned antelope). The second clade is the subfamily Antelopinae, which includes all other bovids. Antelopinae is composed of the three tribes: Caprini (goats, sheep, and muskox), Hippotragini (horse-like antelopes), and Antilopini (gazelles).


title: Saola

text: Since its physical traits are so complex to classify, "Pseudoryx" had been classified variously as member of the subfamily Caprinae and as belonging to any of the three tribes of the subfamily Bovinae: Boselaphini, Bovini and Tragelaphini. DNA analysis has led scientists to place the saola as a member of the tribe Bovini. The morphology of its horns, teeth and some other features indicate it should be grouped with less-derived or more ancestral bovids. Scientific consensus may lead to classifying the saola as the sole member of a proposed new tribe, Pseudorygini.


title: Saola

text: The name 'saola' has been translated as "spindle[-horned]", although the precise meaning is actually "spinning-wheel post horn". The name comes from a Tai language of Vietnam. The meaning is the same in Lao language (, also spelled /sǎo-lǎː/ in Lao). The specific name "nghetinhensis" refers to the two Vietnamese provinces of Nghệ An and Hà Tĩnh, while "Pseudoryx" acknowledges the animal's similarities with the Arabian or African oryx. The Hmong people in Laos refer to the animal as "saht-supahp", a term derived from Lao ( /sàt supʰáːp/) meaning "the polite animal", because it moves quietly through the forest. Other names used by minority groups in the saola's range are "lagiang" (Van Kieu), "a ngao" (Ta Oi) and "xoong xor" (Katu) In the press, saolas have been referred to as "Asian unicorns", an appellation apparently due to its rarity and reported gentle nature, and perhaps because both the saola and the oryx have been linked with the unicorn. No known link exists with the Western unicorn myth or the "Chinese unicorn", the qilin.


title: Saola

text: In a 1998 publication, William G. Robichaud, the coordinator of the Saola Working Group, recorded physical measurements for a captive female saola he dubbed 'Martha', in a Laotian menagerie. She was observed for around 15 days until she died from unknown causes. Robichaud noted the height of the female as at the shoulder; the back was slightly elevated, nearly taller than the shoulder height. The head-and-body length was recorded as . The general characteristics of the saola, as shown by studies during 1993–5 as well as the 1998 study, include a chocolate brown coat with patches of white on the face, throat and the sides of the neck, a paler shade of brown on the neck and the belly, a black dorsal stripe, and a pair of nearly parallel horns, present on both sexes.


title: Saola

text: Robichaud noted that the hair, straight and long, was soft and thin–a feature unusual for an animal that is associated with montane habitats in at least a few parts of its range. While the hair was found to be short on the head and the neck, it thickened to woolly hair on the insides of the forelegs and the belly. Studies before 1998 reported a hint of red in the inspected skins. The neck and the belly are a paler shade of brown compared to the rest of the body. A common observation in all the three aforementioned studies is a thick stripe extending from the shoulders to the tail along the middle of the back. The tail, which measured in Robichaud's specimen, is divided into three horizontal bands, brown at the base, black at the tip and white in the middle. Saola skin is thick over most of the body, but thickens to near the nape of the neck and at the upper shoulders. This adaptation is thought to protect against both predators and rivals' horns during fights.


title: Saola

text: The saola has round pupils with dark-brown irises that appear orange when light is shone into them; a cluster of white whiskers about long with a presumably tactile function protrude from the end of the chin. The specimen Robichaud observed could extend its tongue up to and reach its eyes and upper parts of the face; the upper surface of the tongue is covered with fine, backward-pointing barbs. Robichaud observed that either of the two maxillary glands (sinuses) had a nearly rectangular hollow with the dimensions , covered by a thick flap. The maxillary glands of the saola are probably the largest among those of all other animals. The glands are covered by a thick, pungent, grayish green, semi-solid secretion beneath which lies a sheath of few flat hairs. Robichaud observed several pores, used probably for secretion, on the upper surface of the lid. Each white facial spot shelters one or more nodules from which originate long white or black hairs. These secretions are typically rubbed against the underside of vegetation, leaving a musky, pungent paste. The spoor of the forelegs measured long by wide, and long by for the hindlegs.


title: Saola

text: Both sexes possess slightly divergent horns that are similar in appearance and form almost the same angle with the skull, but differ in their lengths. Horns resemble the parallel wooden posts locally used to support a spinning wheel (thus the familiar name "spindlehorn"). These are generally dark-brown or black and about 35–50 cm long; twice the length of their head. Studies in 1993 and 1995 gave the maximum distance between the horn tips of wild specimens as , but the female observed by Robichaud showed a divergence of between the tips. Robichaud noted that the horns were apart at the base. While studies prior to Robichaud's claim the horns are uniformly circular in cross-section, Robichaud observed his specimen had horns with a nearly oval cross-section. The sides of the base of the horns is rugged and indented.


title: Saola

text: The saola has one of the smallest ranges of any large mammal. It inhabits wet evergreen or deciduous forests in eastern Southeast Asia, preferring river valleys. Sightings have been reported from steep river valleys at above sea level. In Vietnam and Laos, the species' range appears to cover approximately , including four nature reserves. During the winters, it migrates to the lowlands. In the northern Annamite Mountains, it was sighted mostly near streams at elevations of .


title: Saola

text: Local people reported that the saola is active in the day as well as at night, but prefers resting during the hot midday hours. Robichaud noted that the captive female was active mainly during the day, but pointed out that the observation could have been influenced by the unfamiliar surroundings the animal found herself in. When she rested, she would draw her forelegs inward to her belly, extend her neck so that her chin touched the ground, and close her eyes. Though apparently solitary, saola have been reported in groups of two or three as well as up to six or seven. Grouping patterns of the saola resemble those of the bushbuck, anoa, and sitatunga.


title: Saola

text: Robichaud observed that the captive female was calm in the presence of humans, but was afraid of dogs. On an encounter with a dog, she would resort to snorting and thrust her head forward, pointing her horns at her opponent. Her erect ears pointed backward, and she stood stiffly with her back arched. Meanwhile, she hardly paid any attention to her surroundings. This female was found to urinate and defecate separately, dropping her hind legs and lowering her lower body – a common observation among bovids. She would spend considerable time grooming herself with her strong tongue. Marking behaviour in the female involved opening up the flap of the maxillary gland and leaving a pungent secretion on rocks and vegetation. She would give out short bleats occasionally.


title: Saola

text: Robichaud offered spleenwort ("Asplenium"), "Homalomena", and various species of broad-leaved shrubs or trees of the family Sterculiaceae to the captive animal. The saola fed on all plants, and showed a preference for the Sterculiaceae species. She did not pull at leaves, she would rather chew or pull them into her mouth using her long tongue. She fed mainly during the day, and rarely in the dark. The saola is also reputed to feed on "Schismatoglottis", unlike other herbivores in its range.


title: Saola

text: Very little information is available about the reproductive cycle of the saola. The saola is likely to have a fixed mating season, from late August to mid-November; only single calf births have been documented, mainly during summer between mid-April and late June. In the absence of more specific data, the gestation period has been estimated as similar to that of "Tragelaphus" species, about 33 weeks. Three reports of saola killings from nearby villagers involved young accompanying mothers. One possessed long horns, another an estimated , and the third ; these varying horn lengths suggest a birth season extending over at least two to three months.


title: Saola

text: The saola is currently considered to be critically endangered. Its restrictive habitat requirements and aversion to human proximity are likely to endanger it through habitat loss and habitat fragmentation. Saola suffer losses through local hunting and the illegal trade in furs, traditional medicines, and for use of the meat in restaurants and food markets. They also sometimes get caught in snares that have been set to catch animals raiding crops, such as wild boar, sambar, and muntjac. More than 26,651 snares have so far been removed from saola habitats by conservation groups.


title: Saola

text: The key feature of the area occupied by the saola is its remoteness from human disturbance. Saola are shot for their meat, but hunters also gain high esteem in the village for the production of a carcass. Due to the scarcity, the locals place much more value on the saola than more common species. Because the people in this area are traditional hunters, their attitude about killing the saola is hard to change; this makes conservation difficult. The intense interest from the scientific community has actually motivated hunters to capture live specimens. Commercial logging has been stopped in the nature reserve area of Bu Huong, and there is an official ban on forest clearance within the boundaries of the reserve.


title: Saola

text: Species of conservation concern are frequently hard to study; there are often delays in implementing or identifying necessary conservation needs due to lack of data. Because the species is so rare, there is a continuous lack of adequate data; this is one of the major problems facing saola conservation. Trained scientists have never observed saola in the wild. Unfortunately, because it is unlikely that intact saola populations exist, field surveys to discover these populations are not a conservation priority.


title: Saola

text: The Saola Working Group was formed by the IUCN Species Survival Commission's Asian Wild Cattle Specialist Group, in 2006 to protect the saolas and their habitat. This coalition includes about 40 experts from the forestry departments of Laos and Vietnam, Vietnam's Institute of Ecology and Biological Resources, Vinh University, biologists and conservationists from Wildlife Conservation Society, and the World Wide Fund for Nature.


title: Saola

text: A group of scientists from the Vietnam Academy of Science and Technology in central Hanoi, within the Institute of Biotechnology, investigated a last resort effort of conserving the species by cloning, an extremely difficult approach even in the case of well-understood species. However, the lack of female saola donors of enucleated ovocytes and receptive females, as well as the interspecific barriers, greatly compromise the potential success of the cloning technique.


title: Saola

text: The mascot of the 2021 Southeast Asian Games is "Sao La". This design by Ngô Xuân Khôi defeated 557 other mascot submissions to emerge as the winner of the 2019 searching contest.


title: Sweetener World Tour

text: The Sweetener World Tour was the fourth concert tour and third arena tour by American singer, songwriter and actress Ariana Grande in support of her fourth and fifth studio albums, "Sweetener" (2018) and "Thank U, Next" (2019). Led by Live Nation Entertainment, the tour was officially announced on October 25, 2018. It began on March 18, 2019, at the Times Union Center in Albany, New York, and concluded on December 22, 2019, in Inglewood, California at The Forum, visiting cities in North America and Europe throughout 101 dates. Frequent collaborators and backup dancers of Grande, Brian and Scott Nicholson who were enlisted by her, served as creative directors and LeRoy Bennett was enlisted as production designer.


title: Sweetener World Tour

text: The tour was a commercial and critical success - it received positive reviews from critics and fans, who complimented the stage design and Grande's ethereal vocals. The Sweetener World Tour was attended by 1.3 million people and grossed $146.6 million from 97 shows, surpassing her previous concert tour, the Dangerous Woman Tour, as her highest-grossing tour to date. Throughout the tour, Grande partnered with nonprofit organization HeadCount to register new voters ahead of the 2020 United States presidential election, breaking its all-time voter registration record with 33,381 registrations.


title: Sweetener World Tour

text: Multiple shows across the tour were recorded for the live concert tour album, "K Bye for Now (SWT Live)." It was released on December 23, 2019, following the final show of the tour in Inglewood, California on December 22, 2019. A concert film documenting the tour entitled "", was released on Netflix on December 21, 2020, one day prior to the one year anniversary of the final show.


title: Sweetener World Tour

text: On May 6, 2018, Grande finally hinted a tour via her official Twitter account, shortly after announcing the title for her upcoming album on "The Tonight Show Starring Jimmy Fallon". Three months later, she announced that there were plans for a tour, stating that her team were "workin [sic] on it all now". Grande embarked on a promotional concert tour for "Sweetener", The Sweetener Sessions, which began on August 20, 2018, in New York City and ended on September 4, 2018, in London, United Kingdom. Tour passes were also made available via her official website shortly after. Grande announced the title of the tour as the "Sweetener World Tour" on October 24, 2018, announcing its North American dates a day later.


title: Sweetener World Tour

text: The first leg of the tour had 50 shows across North America and visited 45 cities, beginning on March 18, 2019, in Albany and concluding on August 4, 2019, at Lollapalooza. Pre-sale for the tickets for the first leg of the tour took place between November 1 and November 3, 2018. On November 5, 2018, tickets were opened to the general public, and Grande announced Normani and Social House as her opening acts. On December 10, 2018, due to popular demand, second shows were added in Chicago, Los Angeles, Miami, Brooklyn, New York City, Washington, D.C., Boston, Philadelphia, and Toronto. On January 14, 2019, the shows in Chicago, Indianapolis, Columbus, Milwaukee, St. Louis, Saint Paul, Denver and Salt Lake City were rescheduled and the shows in Omaha and Raleigh were cancelled due to Grande headlining the Coachella Valley Music and Arts Festival on April 14 and April 21, 2019, and a new show was added in Las Vegas. On May 28, 2019, the shows in Tampa and Orlando were cancelled and rescheduled due to illness.


title: Sweetener World Tour

text: On December 14, 2018, Grande announced the European dates for the tour. A special show was being planned in Manchester. The second leg of the tour had 30 shows and visited 19 cities across Europe, beginning on August 17, 2019, in London and concluded on October 16, 2019, in London. Pre-sale for the tickets for the second leg of the tour took place between December 19 and December 21, 2018, for the United Kingdom, and between December 18 and December 20, 2018, for all other dates. On December 20, 2018, tickets were opened to the general public (excluding the United Kingdom), and due to popular demand, additional shows were added in Amsterdam, Paris and Dublin. On December 21, 2018, tickets were opened to the general public in the United Kingdom, and due to popular demand, additional shows were added in London and Birmingham. On February 25, 2019, due to popular demand, additional shows were added in Hamburg and Dublin. On March 5, 2019, Grande announced that Ella Mai would be the opening act for the European leg of the tour. On June 11, 2019, due to popular demand, additional shows were added in London. On August 9, 2019, the first show in Hamburg and the show in Prague were rescheduled, and the show in Kraków was cancelled.


title: Sweetener World Tour

text: On June 20, 2019, Grande announced another North American leg of the tour. The third leg of the tour visited 18 cities and had 20 shows across the United States, including the rescheduled Tampa and Orlando shows, beginning on November 9, 2019, in Uniondale and concluding on December 22, 2019, in Inglewood. Pre-sale for the tickets for the third leg of the tour took place between June 26 and June 30, 2019. On July 1, 2019, tickets were opened to the general public. On July 11, 2019, due to popular and high demand, additional shows were added in San Francisco and Inglewood.


title: Sweetener World Tour

text: Grande announced she would be partnering with nonprofit voter registration group HeadCount to register new voters ahead of the 2020 presidential election in March via Instagram. She encouraged fans to "use your voice and get your 'thank u, next gen' sticker." In July, it was reported that HeadCount registered twice as many voters in partnership with Grande than any other tour over the last three years and that the Sweetener World Tour was the most successful artist tour for voter registration HeadCount has seen since 2008. In December, it was announced that the tour broke the organization's all-time record, with 33,381 voter registrations and actions.


title: Sweetener World Tour

text: Grande wore costumes from Versace and Michael Ngo on stage. She enlisted Brian and Scott Nicholson as creative directors, LeRoy Bennett as production designer, and Jason Baeri as lighting director. Designed based on the idea of a sphere, the tour stage was intended to deliver an abstract and "ethereal" aesthetic. It included a semicircular runway that looped around an audience pit, a large screen at the back with a hemisphere-like projection, and a large orb—nicknamed "the moon" by fans and Grande herself—that descended briefly as Grande sang on the B-stage in the middle of the pit. The moon and the projection screen were both inflatable, requiring a set-up period of six to eight hours, although Grande's team assembled everything in 45 minutes for her Coachella set. Bennett likened the show's feel more to a play than to a pop show: "Usually you are trying to appropriately match the energy of a song with action and accent to tell a story along with the music and lyrics; the language of this show was different in that we were striving to create static tableaus and grand gestures as an environment for her to play in front of, much like a unit set in a play."


title: Sweetener World Tour

text: The tour has received positive reviews from critics. Brittany Spanos from "Rolling Stone" gave the opening night at Albany a positive review, stating that "Grande's new world tour is full of emotional drama, iconic looks, and undeniable hits". Spanos also commented on Grande's looks, stating that "fewer and fewer young stars today have the kind of distinctive aesthetic that can be reproduced en masse by fans, but Grande has dedicated years to perfecting how she has presented herself. In 2019, it seems the world has finally caught up to her. Or, as her frequent collaborator and friend Nicki Minaj predicted on “Side to Side” three years ago: “Ariana run pop." Chris Richards of the "Washington Post" gave a positive review to Grande's show in Washington D.C, stating that "Ariana Grande reached the height of her fame by making heavy feel light". He praised her vocals stating that "Grande's voice is equal parts breathy and acrobatic, and she knows how to hit a big note like she's whispering it". Chris Willman of "Variety" praised Grande's two night show at the Staples Center in Los Angeles, calling the show "giddy, splendorous, beautifully designed, expertly performed and almost a little bit avant-garde in its staging". He also stated that it was "much more than at Coachella, her visually experimental Staples stop was revealed as a thing of inventive beauty, not to mention expertly sung fun."


title: Sweetener World Tour

text: The second leg of the tour in Europe has also received positive reviews. Adam White of "The Telegraph" gave the show a 5 out of 5 stars, stating that the show was "a night of magic and melancholy from the most exciting young star in pop". Cydney Yeates of "Metro" gave the show 4 out of 5 stars, stating that "there's nothing more to say now besides God*is*a woman and her name is Ariana Grande." Hannah Mylrea of "NME" noted that "the production was fairly understated, putting the full focus on her impressive vocals, but there were moments of impressive choreography".


title: Sweetener World Tour

text: Grande's headlining performance at the 2019 Coachella Valley Music and Arts Festival was praised by critics, with many praising her vocals, visuals, and guest appearances, particularly the appearance of NSYNC. Shad Powers of "USA Today" stated that "Grande closed out Weekend One of Coachella in style, putting together a set that included special guests, stunning visuals, and of course her undeniable voice." Rhian Daly of "NME" called her set "a breathtaking moment of light in a dark world". She also stated that, after the end of the set, "the feeling was already mutual long before Grande took to the stage but [...] its foundations are more solid than ever". In another positive review, Ben Beaumont-Thomas of "The Guardian" stated that "with her headline set surveying her entire career, [Grande's] work forms a fascinating, still-unfolding pop Bildungsroman: every sexual epiphany and personal milestone sketched out in real time, resulting in a uniquely involving opus. You can see why she is such an icon to a generation who also tell their own stories in public, via Snapchat and Instagram." Claire Shaffer from "Rolling Stone" stated that "Grande gave a star-studded headlining performance", naming NSYNC's guest appearance as one of the best moments of the 2019 Coachella. Suzy Exposito continued, "Grande became one of the boys that night, claiming Timberlake’s verses from the center stage and whipping her lustrous, anime pony like a boss." Lyndsey Havens of "Billboard" called Grande's set "epic" and stated that she "continues to rewrite the rule book for pop stardom and admittedly fosters a new relationship with herself." She praised Grande's collaboration with NSYNC, stating "all together with Grande, they delivered well-practiced choreography, sang the track she samples with her filling in for Timberlake and finally ended with "Tearin' Up My Heart."


title: Sweetener World Tour

text: The Sweetener World Tour grossed over $146.4 million with 1.3 million tickets sold. It surpassed her previous tour, the Dangerous Woman Tour (which grossed $71.1) as her best-grossing and biggest tour to date. The tour grossed $106.9 million in the U.S. and Canada and $39.5 million in Europe. Overall, Grande's total tour figures extend to $243.5 million with 2.7 million tickets sold from 229 shows. Due to high demand, seconds shows were added in Boston, Washington D.C., Philadelphia, Toronto, Los Angeles, Phoenix, Dallas, Miami, Chicago, Atlanta, Nashville, Brooklyn (another show would be added later on), New York City, London (4 more shows were added later on), Amsterdam (another show would be added), Paris, Birmingham, Hamburg, Dublin (two more shows would be added), San Francisco, and Inglewood.


title: Sweetener World Tour

text: This set list is representative of the first show in Albany, performed in March 18, 2019. It does not represent all concerts for the duration of the tour.


title: The November Man

text: The November Man is a 2014 spy action thriller film based on the novel "There Are No Spies" by Bill Granger, which is the seventh installment in "The November Man" novel series, published in 1987. A British-American production, it stars Pierce Brosnan, Luke Bracey and Olga Kurylenko, with Bill Smitrovich and Will Patton also appearing, with the screenplay written by Michael Finch and Karl Gajdusek. The film is directed by Roger Donaldson, who previously worked with Brosnan on "Dante's Peak". The film was released on August 27, 2014 in the United States.


title: The November Man

text: In 2008, CIA agent Peter Devereaux supervises a young operative, David Mason, during a protective mission in Montenegro. Mason disobeys Devereaux's orders not to fire. He shoots and kills an assassin but also kills a child.


title: The November Man

text: Five years later, Devereaux is retired in Lausanne, Switzerland. His former boss, John Hanley, arrives and convinces him to extract Natalia Ulanova, the aide of Russian President-elect and former Army General Arkady Fedorov. Ulanova breaks into Fedorov's safe and copies old photos depicting his war crimes. She contacts the CIA extraction team, and escapes. Fedorov alerts the FSB, who pursue her through the streets of Moscow until Devereaux rescues her. She gives him a name, Mira Filipova, which he relays to Hanley. The CIA team, co-ordinated by Hanley, is unaware of Devereaux's presence.


title: The November Man

text: The station chief, Perry Weinstein, gives the order to kill Ulanova, which Mason does. A dying Ulanova hands Devereaux her phone containing the photos. As the CIA team leaves the parking lot, Devereaux kills everyone in the squad until he faces Mason at gunpoint. The two separate without shooting. It is revealed that Devereaux and Ulanova were involved before. Hanley is detained for interrogation.


title: The November Man

text: Meanwhile," New York Times" journalist Edgar Simpson tracks down refugee case worker Alice Fournier and requests her assistance to write an exposé of Fedorov's war crimes during the Second Chechen War. Alexa, an assassin, arrives in Belgrade, and finds out that Fournier will meet Simpson in a cafe. Devereaux also arrives in Belgrade, Serbia then heads to Hanley's house and finds Fournier as Filipova's only known contact. He arrives at the cafe and rescues Fournier from both Alexa and Mason's team.


title: The November Man

text: Fournier says that Filipova pretended to Federov to be mute. She actually spoke Russian and overheard Fedorov's conversations, including the 'false flag' conspiracy to bomb a Russian Army building to initiate war and seizure of Chechen oil fields. A former Fedorov associate, Denisov, confirms the conspiracy and reveals the CIA's involvement. Devereaux sends Fournier away.


title: The November Man

text: Fedorov arrives in Belgrade for an energy conference. Fournier meets Simpson at his apartment where Alexa attacks them and kills him; but Fournier escapes. Devereaux infiltrates the CIA site where Hanley is being held; and Hanley claims Weinstein aided Fedorov and reveals that Fournier is actually Filipova. Mason also discovers the real Fournier died years ago and Filipova stole her identity. Filipova, disguised as a prostitute, goes to Fedorov's hotel room. It is revealed that her family was murdered in front of her by Federov, who raped her later. She surprises Federov but is unable to kill him as her body betrays her; Devereaux ascends the stairs in the Hotel, shoots the bodyguards, and saves her.


title: The November Man

text: Devereaux interrogates Federov, demanding to know the name of the CIA operative involved in the operation. Federov, filmed by Filipova's phone, admits it was Hanley, not Weinstein; and Filipova confirms it. Mason arrives at the hotel but Devereaux and Filipova escape after he knocks out Mason and leaves him Fedorov's recorded confession. However, when Mason and Celia arrive in Langley to present the evidence, they realize that Weinstein has been replaced by Hanley.


title: The November Man

text: Devereaux calls Lucy, his and Ulanova's daughter; Hanley answers the phone, having kidnapped her. Devereaux convinces Filipova to go to a train station and wait for him. There, she goes to a public computer to write her story regarding Fedorov. Devereaux meets with Hanley and Mason, stating she will be waiting at a bus station. Mason is tasked to go and recover her. Alexa finds Filipova at the station; but is knocked unconscious by her, who returns, finishes typing and sends it to the press. Hanley reveals his intention to blackmail Federov after he becomes the President, forcing Russia to join NATO against the Middle-East. Celia, Mason's CIA partner, finds the kidnappers' location and he rescues Lucy. He returns to Hanley and helps Devereaux kill Hanley's men and subdue Hanley. Devereaux unites with Lucy and Filipova and they leave on the train.


title: The November Man

text: Later, Filipova testifies at the International Criminal Court against Fedorov, annulling his candidacy. Fedorov is later shot in the head by an unknown sniper.


title: The November Man

text: When Pierce Brosnan retired from playing the role of James Bond in 2005, it was reported that along with his then-business partner, Beau St. Clair, through their Irish DreamTime production company, he would be producing a down-to-earth spy thriller based on Bill Granger's book series, called "The November Man", focusing on one particular novel in the series titled "There Are No Spies", with shooting scheduled to begin in 2006. The project, however, was shelved sometime in 2007 for unknown reasons, while Brosnan held on to the screen rights to the novel with the plan to produce an adaptation in the future.


title: The November Man

text: Eventually, in 2012, it was reported that Brosnan had the project resurrected and was put back on the trail with Dominic Cooper reportedly joining the production shortly after its announcement. In April 2013, whilst promoting his then-latest romantic comedy, "Love Is All You Need", Brosnan told the media: "I am about to go off to Serbia and do my own spy movie. Finally I have the director I want in Roger Donaldson and we’re gonna do a piece called "November Man" so I shall jump back into that arena".


title: The November Man

text: Brosnan revealed that Olga Kurylenko, who had a leading role in "Quantum of Solace" and the recent "Oblivion", would co-star alongside him, commenting "I think there’s another room on the stage for another spy! Daniel [Craig] can’t have it all to himself. My co-star is a lovely actress called Olga Kurylenko, who seems to be going through leading men like hot dinners. She started with Daniel Craig and she’s gonna end up with Brosnan! She’s a gorgeous actress, beautiful woman. She’s in and it’s the older spy, younger spy". A month later, it was announced that shooting on the film would begin on 20 May 2013, with Luke Bracey and Bill Smitrovich joining the cast. Dominic Cooper, however, left the project to star in "Need For Speed", and was replaced with Bracey in the role of the main character's protege. In June 2013, it was reported that Will Patton and Caterina Scorsone joined the cast; the former played an old-school senior CIA operative, while the latter played an "ambitious up-and-comer".


title: The November Man

text: Principal photography began on May 20, 2013 in Belgrade, with Brosnan, Bracey, and many other supporting actors seen on site, but nothing particularly came out of the regular photographers and journalists, because it was moved away from public eye, and the sets were closed down for filming, guarded by tight security against all unauthorized personnel. In the original novel, Berlin was the main setting, but Brosnan stated that the production couldn't afford shooting there. Meanwhile, the second unit production team shot additional scenes in Montenegro locations posing as Switzerland. On June 2, 2013, Olga Kurylenko was spotted filming an action scene with Brosnan. Production on the film officially wrapped in late July 2013, and entered its post-production phase in September, later that year.


title: The November Man

text: On December 3, 2013, it was announced that Marco Beltrami would be composing the soundtrack for the film. "I wanted to create a taut score incorporating a guitar theme with a slightly Eastern European meets Western motif befitting an action thriller about international espionage," said Beltrami. A soundtrack album was released by Varèse Sarabande on September 9, 2014.


title: The November Man

text: The film was released on August 27, 2014. On June 6, 2014, the first trailer for the film was released worldwide. The seventh novel in the original book series, "There Are No Spies", was republished as "The November Man" to promote the release. The film was released on Blu-ray on November 25, 2014.


title: The November Man

text: "The November Man" grossed $25 million in North America and $7.5 million in other territories for a worldwide total of $32.6 million, against a budget of $15 million.


title: The November Man

text: On Rotten Tomatoes, the film has an approval rating of 35%, based on 124 reviews, with an average rating of 4.7/10. The site's critical consensus reads, ""The November Man" has a few of the ingredients necessary for a better-than-average spy thriller, making it all the more disappointing that it falls back on dull genre clichés." On Metacritic, the film has a score of 38 out of 100, based on 32 critics, indicating "generally unfavorable reviews". On CinemaScore, audiences gave the film an average grade of "B+" on an A+ to F scale.


title: The November Man

text: Bilge Ebiri of "Vulture" wrote, "Brosnan, who was a better James Bond than he often gets credit for, doesn’t like to smile much, but he still brings a weary likability to a grim part, just enough to keep us invested as the movie trots through its gauntlet of familiar twists and double-crosses."


title: The November Man

text: On June 12, 2014, it was revealed that Sriram Das' production company, Das Films, had commissioned a sequel to the film. On August 20, 2014, while on "The Tonight Show Starring Jimmy Fallon", Brosnan officially announced that a sequel was in preparation, and Relativity Media would soon be entering pre-production. However, nothing further has been reported since then, and it is presumed that the project has been shelved.


title: Gonzo (Muppet)

text: Gonzo, also known as The Great Gonzo or Gonzo the Great, is a Muppet character known for his eccentric passion for stunt performance. Aside from his trademark enthusiasm for performance art, another defining trait of Gonzo is the ambiguity of his species, which has become a running gag in the franchise. He has been considered to be of various origins, including a Frackle, in his debut appearance in "The Great Santa Claus Switch"; extraterrestrial in "Muppets from Space"; or avian creature.


title: Gonzo (Muppet)

text: Developed and performed by Dave Goelz, Gonzo made his first appearance in the 1970 special "The Great Santa Claus Switch", as the "Cigar Box Frackle". Originally a minor figure in "The Muppet Show", he soon evolved into one of the franchise's primary characters. Gonzo has appeared in every Muppet film, including "The Muppet Christmas Carol", where he portrayed author Charles Dickens and developed a double act with Rizzo the Rat.


title: Gonzo (Muppet)

text: The prototype of Gonzo appeared in "The Great Santa Claus Switch", "as a generic gruff baddie". Jim Henson selected this Frackle as the basis for Gonzo, and gave the character to puppeteer Dave Goelz. Gonzo was created as a character with low self-esteem, as written by Jerry Juhl, with Goelz acknowledging he put himself into that interpretation. Later, with Jim Henson's approval, they reworked the eyes to allow the character to convey more excitement, and a "zany, bombastic appreciation for life".


title: Gonzo (Muppet)

text: Gonzo has several memorable performances such as his 1979 song from "The Muppet Movie", "I'm Going to Go Back There Someday". He became known for his stunts as acts within "The Muppet Show" and beyond, with the famous quote "I shall now eat a rubber tire to the music of "The Flight of the Bumblebee"...music, maestro!"


title: Gonzo (Muppet)

text: In 1992, he played the part of Charles Dickens in "The Muppet Christmas Carol", as director Brian Henson said Gonzo was the most improbable Muppet to do so. Here, he developed a double act with Rizzo the Rat, narrating and breaking the fourth wall, with Rizzo challenging Gonzo's claims to be Dickens. The Gonzo and Rizzo partnership was continued in "Muppet Treasure Island" (1996) and "Muppets from Space" (1999). Along with Kermit and Rizzo, Gonzo gave an audio commentary for the "Muppets from Space" DVD.


title: Gonzo (Muppet)

text: In "The Muppets", it was revealed that he had become a powerful plumbing magnate since the Muppets split up. In the 2015 television series "The Muppets", Gonzo is a major character and the head writer of Miss Piggy's late night talk show, "Up Late with Miss Piggy".


title: Gonzo (Muppet)

text: Gonzo is not a puppet version of a human or a recognizable animal. He has an awkward, non animal-like appearance, which includes purple-blue fur, purple feathers on his head, bug-eyes, and a long, hooked nose, referred to as a "beak". In "The Muppet Show" and "The Muppet Movie", he performed as a performance artist, stunt double and daredevil under the name "The Great Gonzo" (or "Gonzo the Great").


title: Gonzo (Muppet)

text: Gonzo is good friends with all of the Muppets, but performed a double act with Rizzo the Rat since "The Muppet Christmas Carol". Gonzo has a long-standing romantic relationship with Camilla the Chicken, whom he first courted in the Leslie Uggams episode of "The Muppet Show", and directed Camilla and the other chickens in 2008 YouTube videos.


title: Gonzo (Muppet)

text: A running gag related to Gonzo is that it is not clear what species he is supposed to be. Gonzo's self-identity is a "whatever". In "The Muppet Movie", Kermit, while conversing with his inner self, says "And a thing, whatever Gonzo is. He's a little like a turkey", to which his inner self replies "but not much". In the film "The Great Muppet Caper", he is shipped to England in a crate labeled "Whatever" (while Kermit the Frog and Fozzie Bear are respectively labeled "Frog" and "Bear"). Not long afterward, the three land in a pond in front of Robert Morley who ponders if it's raining cats and dogs; Kermit and Fozzie respectively reply, "Actually, we're bears and frogs." "And Gonzos." In "A Muppet Family Christmas", when Gonzo states to the Christmas Turkey that Camilla is his girlfriend, the Christmas Turkey says "You're not even a bird!" In the "Muppet Treasure Island CD-ROM Game", Gonzo and Rizzo the Rat land in a bucket of molasses, following the dialogue of a carriage driver saying "It's raining rats and... whatevers". In "The Muppets' Wizard of Oz", Gonzo played a Tin Man-ish character primarily known as the "Tin Thing". In "Jim Henson's Muppet Babies", Gonzo (voice of Russi Taylor) is simply referred to, most often by Baby Piggy, as a "weirdo" or "blue weirdo".


title: Gonzo (Muppet)

text: In "Muppets from Space", Gonzo has a starring role. In the film, he is revealed to be an alien, and his alien family tracks him down with the intention of welcoming him back into his long-lost community; before their departure, they ask him to return to space with them. Gonzo says a sad farewell to the Muppets, but soon realizes that he would be abandoning the friends who have been like his family all along, prompting him to decline the aliens' offer.


title: Gonzo (Muppet)

text: In a 1984 "Muppets" comic strip, Gonzo is seen passing by the gendered bathroom options of "Women" and "Men", and instead walking through a door labeled "Whatever", which some members of the LGBTQ+ community have interpreted to mean that Gonzo is non-binary.


title: Gonzo (Muppet)

text: On a 2021 episode of "Muppet Babies" parodying Cinderella, Gonzo puts on the glass slipper and transforms into "Gonzorella". Gonzo later admits to his fellow Muppets that "the princess who came to your ball tonight... was me." When Miss Piggy asks why Gonzo did not tell them, Gonzo replies, "Because you all expected me to look a certain way. I don't want you to be upset with me... but I don't want to do things just because that's the way they've been done, either. I wanna be me." When asked about the episode producer Tom Warburton said that early on the plan was to make Gonzo appear in a skirt as if it were no big deal, because "Gonzo is always 200 percent Gonzo 347 percent of the time", but the writing team decided to take it further with the Cinderella arc. Warburton remarked that "It was just SO wonderfully Gonzo. We hope he inspires kids watching to be 347% of themselves in their own way, too."


title: Gonzo (Muppet)

text: Though primarily performed by Dave Goelz, he has also been voiced in animated form by Hal Rayle in "Little Muppet Monsters". Brett O'Quinn performed Gonzo in "Muppets Ahoy!", a 2006 Disney Cruise Line show. An infant-aged version of Gonzo appeared as a regular character in the animated spin-off television series "Muppet Babies", voiced by Russi Taylor, alongside Kermit, Miss Piggy, and other central "Muppet Show" figures. Baby Gonzo is one of the cartoon characters featured in "Cartoon All-Stars to the Rescue". Baby Gonzo later returned in the 2018 "Muppet Babies" series, voiced by Benjamin Diskin.


title: Gonzo (Muppet)

text: Gonzo was featured on the #28 Havoline Ford of Ricky Rudd in the 2002 Tropicana 400 in an advertising campaign in which Gonzo and his fellow Muppets were featured on a select few NASCAR Nextel Cup Series race cars. Gonzo also appeared alongside Gonzo's fellow Muppets on the Halloween 2011 episode of "WWE Raw".


title: Gonzo (Muppet)

text: Gonzo was announced as the Grand marshal for the Auto Club 400 NASCAR Sprint Cup Series race at Auto Club Speedway in Fontana, Ca. to give the famous command of "Drivers, Start your engines". Gonzo fulfilled his duty on March 23, 2014.


title: Gonzo (Muppet)

text: Gonzo is also the namesake to the CT-142 Bombardier Dash 8 used by the Canadian Armed Forces for Air Combat Systems Officer training due to the blue paint job and elongated nose housing a specialized radar. A similar flying example is the Gulfstream IV light jetliner bearing US registration "N49RF", flown for severe weather research by the US Federal National Oceanic and Atmospheric Administration, and is also named for Gonzo as portside nose art.


title: Gonzo (Muppet)

text: Reviewing "Muppets from Space" in 1999, Roger Ebert found the most humorous part to be Gonzo being denied entry in Noah's Ark for not having a second member of his species, and expressed sympathy for his loneliness as an extraterrestrial, stranded since the Roswell UFO incident, adding "Poor guy (or whatever he is)". In 2012, "The Guardian"s Lizzy Dening, reviewing the Muppet films, identified Gonzo as a favorite. That year, "The Daily Beast" wrote about appreciation for the Muppets in the LGBT community, calling Gonzo "the queerest Muppet of all".


title: Gonzo (Muppet)

text: In 2015, Today.com, in reviewing the Humpty Dance YouTube video, referred to Gonzo himself as a "classic Muppet". That year, "The Huffington Post" identified Gonzo as a popular Muppet, saying to his fans, "People just don't GET you" adding "And nothing would ever be the same without you."


title: Equity (law)

text: Equity is a particular body of law that was developed in the English Court of Chancery. Its general purpose is to provide a remedy for situations where the law is not flexible enough for the usual court system to deliver a fair resolution to a case. The concept of equity is deeply intertwined with its historical origins in the common law system used in England. However, equity is in some ways a separate system from common law: it has its own established rules and principles, and was historically administered by separate courts, called "courts of equity" or "courts of chancery".


title: Equity (law)

text: Equity exists in domestic law, both in civil law and in common law systems, and in international law. The tradition of equity begins in antiquity with the writings of Aristotle ("epieikeia") and with Roman law ("aequitas"). Later, in civil law systems, equity was integrated in the legal rules, while in common law systems it became an independent body of law.


title: Equity (law)

text: In jurisdictions following the English common law system, equity is the body of law which was developed in the English Court of Chancery and which is now administered concurrently with the common law. In common law jurisdictions, the word "equity" "is not a synonym for 'general fairness' or 'natural justice'", but refers to "a particular body of rules that originated in a special system of courts."


title: Equity (law)

text: For much of its history, the English common law was principally developed and administered in the central royal courts: the Court of King's Bench, the Court of Common Pleas, and the Exchequer. Equity was the name given to the law which was administered in the Court of Chancery. The Judicature Reforms in the 1870s effected a procedural fusion of the two bodies of law, ending their institutional separation. The reforms did not effect any substantive fusion, however. Judicial or academic reasoning which assumes the contrary has been described as a "fusion fallacy".


title: Equity (law)

text: Jurisdictions which have inherited the common law system differ in their treatment of equity. Over the course of the twentieth century some common law systems began to place less emphasis on the historical or institutional origin of substantive legal rules. In England and Wales, Australia, New Zealand, and Canada, equity remains a distinct body of law. Modern equity includes, among other things:


title: Equity (law)

text: The latter part of the twentieth century saw increased debate over the utility of treating equity as a separate body of law. These debates were labelled the "fusion wars". A particular flashpoint in this debate centred on the concept of unjust enrichment and whether areas of law traditionally regarded as equitable could be rationalised as part of a single body of law known as the law of unjust enrichment.


title: Equity (law)

text: After the Norman Conquest of England in the 11th century, royal justice came to be administered in three central courts: the Court of King's Bench, the Court of Common Pleas, and the Exchequer. The common law developed in these royal courts, which were created by the authority of the King, and whose jurisdiction over disputes between the King's subjects was based upon the King's writ. Initially, a writ was probably a vague order to do right by the plaintiff, and it was usually a writ of grace, issued at the pleasure of the King.


title: Equity (law)

text: During the 12th and 13th centuries, writ procedure gradually evolved into something much more rigid. All writs to commence actions had to be purchased by litigants from the Chancery, the head of which was the Lord Chancellor. After writs began to become more specific and creative (in terms of the relief sought), Parliament responded in 1258 by providing in the Provisions of Oxford that the Chancellor could no longer create new writs without permission from the King and the King's Council (the curia regis). Pursuant to such authorization, litigants could purchase certain enumerated writs "de cursu" (as a matter of course) which later became known as writs "ex debito justitiae" (as a matter of right). Each of these writs was associated with particular circumstances and led to a particular kind of judgment. Procedure in the common law courts became tightly focused on the form of action (the particular procedure authorized by a particular writ to enforce a particular substantive right), rather than what modern lawyers would now call the cause of action (the underlying substantive right to be enforced).


title: Equity (law)

text: Because the writ system was limited to enumerated writs for enumerated rights and wrongs, it sometimes produced unjust results. Thus, even though the King's Bench might have jurisdiction over a case and might have the power to issue the perfect writ, the plaintiff might still not have a case if there was not a single form of action combining them. Lacking a legal remedy, the plaintiff's only option would be to petition the King.


title: Equity (law)

text: Litigants began to seek relief against unfair judgments of the common law courts by petitioning the King. Such petitions were initially processed by the King's Council, which itself was quite overworked, and the Council began to delegate the hearing of such petitions to the Lord Chancellor. This delegation is often justified by the fact that the Lord Chancellor was literally the Keeper of the King's Conscience, although Francis Palgrave argued that the delegation was initially driven by practical concerns and the moral justification came later. By the 14th century it appears that Chancery was operating as a court, affording remedies for which the strict procedures of the common law worked injustice or provided no remedy to a deserving plaintiff. Chancellors often had theological and clerical training and were well versed in Roman law and canon law. During this era, the Roman concept of "aequitas" influenced the development of the distinctly different but related English concept of equity: "The equity administered by the early English chancellors ... [was] confessedly borrowed from the aequitas and the judicial powers of the Roman magistrates." By the 15th century the judicial power of Chancery was clearly recognised.


title: Equity (law)

text: Equity, as a body of rules, varied greatly from Chancellor to Chancellor, until the end of the 16th century. Because the early Chancellors lacked formal legal training in the common law tradition and showed little regard for precedent, their decisions were often widely diverse. In 1529, a lawyer, Sir Thomas More, was appointed as Chancellor, marking the beginning of a new era. After this time, all future Chancellors were lawyers. Beginning around 1557, records of proceedings in the Court of Chancery were regularly kept, several equitable doctrines developed, and equity started to evolve into a system of precedents like its common law cousin. Over time, equity jurisprudence would gradually become a "body of equitable law, as complex, doctrinal, and rule-haunted as the common law ever was."


title: Equity (law)

text: Chancery continued to be the subject of extensive criticism, the most famous of which was 17th-century jurist John Selden's aphorism:Equity is a roguish thing: for law we have a measure, know what to trust to; equity is according to the conscience of him that is Chancellor, and as that is larger or narrower, so is equity. 'Tis all one as if they should make the standard for the measure we call a foot, a Chancellor's foot; what an uncertain measure would this be? One Chancellor has a long foot, another a short foot, a third an indifferent foot: 'tis the same thing in a Chancellor's conscience.


title: Equity (law)

text: One indicator of equity's evolution into a coherent body of law was Lord Eldon's response to Selden in an 1818 chancery case: "I cannot agree that the doctrines of this court are to be changed with every succeeding judge. Nothing would inflict on me greater pain, in quitting this place, than the recollection that I had done anything to justify the reproach that the equity of this court varies like the Chancellor’s foot."


title: Equity (law)

text: A criticism of Chancery practice as it developed in the early medieval period was that it lacked fixed rules and that the Lord Chancellor was exercising an unbounded discretion. The counter-argument was that equity mitigated the rigour of the common law by looking to substance rather than to form.


title: Equity (law)

text: Litigants would go 'jurisdiction shopping' and often would seek an equitable injunction prohibiting the enforcement of a common law court order. The penalty for disobeying an equitable injunction and enforcing an unconscionable common law judgment was imprisonment.


title: Equity (law)

text: The Chief Justice of the King's Bench, Sir Edward Coke, began the practice of issuing writs of "habeas corpus" that required the release of people imprisoned for contempt of chancery orders.


title: Equity (law)

text: This tension reached a climax in the Earl of Oxford's case (1615) where a judgment of Chief Justice Coke was allegedly obtained by fraud. The Lord Chancellor, Lord Ellesmere, issued an injunction from the Chancery prohibiting the enforcement of the common law order. The two courts became locked in a stalemate, and the matter was eventually referred to the Attorney General, Sir Francis Bacon. Sir Francis, by authority of King James I, upheld the use of the equitable injunction and concluded that in the event of any conflict between the common law and equity, equity would prevail. Equity's primacy in England was later enshrined in the Judicature Acts of the 1870s, which also served to fuse the courts of equity and the common law (although emphatically not the systems themselves) into one unified court system.


title: Equity (law)

text: One area in which the Court of Chancery assumed a vital role was the enforcement of uses, a role that the rigid framework of land law could not accommodate. This role gave rise to the basic distinction between legal and equitable interests.


title: Equity (law)

text: In order to avoid paying land taxes and other feudal dues, lawyers developed a primitive form of trust called ‘the use’ that enabled one person (who was not required to pay tax) to hold the legal title of the land for the use of another person. The effect of this trust was that the first person owned the land under the common law, but the second person had a right to use the land under the law of equity.


title: Equity (law)

text: Henry VIII enacted the Statute of Uses in 1535 (which became effective in 1536) in an attempt to outlaw this practice and recover lost revenue. The Act effectively made the beneficial owner of the land the legal owner and therefore liable for feudal dues.


title: Equity (law)

text: The response of the lawyers to this Statute was to create the 'use upon a use'. The Statute recognized only the first use, and so land owners were again able to separate the legal and beneficial interests in their land.


title: Equity (law)

text: Equity remains a cornerstone of Australian private law. A string of cases in the 1980s saw the High Court of Australia re-affirm the continuing vitality of traditional equitable doctrines. The High Court has recently affirmed the importance of Equity and dismissed the suggestion that unjust enrichment has explanatory power in relation to traditional equitable doctrines such as subrogation.


title: Equity (law)

text: The state of New South Wales is particularly well known for the strength of its Equity jurisprudence. However, it was only in 1972 with the introduction of reform to the Supreme Court Act 1970 (NSW) that empowered both the Equity and Common Law Division of the Supreme Court of NSW to grant relief in either equity or common law. In 1972 NSW also adopted one of the essential sections of the Judicature reforms, which emphasised that where there was a conflict between the common law and equity, equity would always prevail. Nevertheless, in 1975 three alumni of Sydney Law School and judges of the NSW Supreme Court, Roderick Meagher, William Gummow and John Lehane produced "". It remains one of the most highly regarded practitioner texts in Australia and England. The work is now in its 5th edition and edited by Dyson Heydon, former Justice of the High Court, Justice Mark Leeming of the New South Wales Court of Appeal, and Dr Peter Turner of Cambridge University.


title: Equity (law)

text: Equity remains a distinct part of the law of England and Wales. The main challenge to it has come from academic writers working within the law of unjust enrichment. Scholars such as Peter Birks and Andrew Burrows argue that in many cases the inclusion of the label "legal" or "equitable" before a substantive rule is often unnecessary. Many English universities, such as Oxford and Cambridge, continue to teach Equity as a standalone subject. Leading practitioner texts include "Snell's Equity", "Lewin on Trusts", and "Hayton & Underhill's Law of Trusts and Trustees".


title: Equity (law)

text: The courts of Scotland have never recognised a division between the normal common law and equity, and as such the Court of Session (the supreme civil court of Scotland) has exercised an equitable and inherent jurisdiction and called the "nobile officium". The "nobile officium" enables the Court to provide a legal remedy where statute or the common law are silent, and prevent mistakes in procedure or practice that would lead to injustice. The exercise of this power is limited by adherence to precedent, and when legislation or the common law already specify the relevant remedy. Thus, the Court cannot set aside a statutory power, but can deal with situations where the law is silent, or where there is an omission in statute. Such an omission is sometimes termed a "casus improvisus".


title: Equity (law)

text: In India the common law doctrine of equity had traditionally been followed even after it became independent in 1947. However, in 1963 the "Specific Relief Act" was passed by the Parliament of India following the recommendation of the Law Commission of India and repealing the earlier "Specific Relief Act" of 1877. Under the 1963 Act, most equitable concepts were codified and made statutory rights, thereby ending the discretionary role of the courts to grant equitable reliefs. The rights codified under the 1963 Act were as under:


title: Equity (law)

text: With this codification, the nature and tenure of the equitable reliefs available earlier have been modified to make them statutory rights and are also required to be pleaded specifically to be enforced. Further to the extent that these equitable reliefs have been codified into rights, they are no longer discretionary upon the courts or as the English law has it, "Chancellor's foot" but instead are enforceable rights subject to the conditions under the 1963 Act being satisfied. Nonetheless, in the event of situations not covered under the 1963 Act, the courts in India continue to exercise their inherent powers in terms of Section 151 of the Code of Civil Procedure, 1908, which applies to all civil courts in Australia and India.


title: Equity (law)

text: There is no such inherent powers with the criminal courts in India except with the High Courts in terms of Section 482 of the Code of Criminal Procedure, 1973. Further, such inherent powers are vested in the Supreme Court of India in terms of Article 142 of the Constitution of India which confers wide powers on the Supreme Court to pass orders "as is necessary for doing complete justice in any cause of matter pending before it".


title: Equity (law)

text: In modern practice, perhaps the most important distinction between law and equity is the set of remedies each offers. The most common civil remedy a court of law can award is monetary damages. Equity, however, enters injunctions or decrees directing someone either to act or to forbear from acting. Often, this form of relief is in practical terms more valuable to a litigant; for example, a plaintiff whose neighbor will not return his only milk cow, which had wandered onto the neighbor's property, may want that particular cow back, not just its monetary value. However, in general, a litigant cannot obtain equitable relief unless there is "no adequate remedy at law"; that is, a court will not grant an injunction unless monetary damages are an insufficient remedy for the injury in question. Law courts can also enter certain types of immediately enforceable orders, called "writs" (such as a writ of habeas corpus), but they are less flexible and less easily obtained than an injunction.


title: Equity (law)

text: Another distinction is the unavailability of a jury in equity: the judge is the trier of fact. In the American legal system, the right of jury trial in civil cases tried in federal court is guaranteed by the Seventh Amendment "in Suits at common law", cases that traditionally would have been handled by the law courts. The question of whether a case should be determined by a jury depends largely on the type of relief the plaintiff requests. If a plaintiff requests damages in the form of money or certain other forms of relief, such as the return of a specific item of property, the remedy is considered legal, and a jury is available as the fact-finder. On the other hand, if the plaintiff requests an injunction, declaratory judgment, specific performance, modification of contract, or some other non-monetary relief, the claim would usually be one in equity.


title: Equity (law)

text: Thomas Jefferson explained in 1785 that there are three main limitations on the power of a court of equity: "If the legislature means to enact an injustice, however palpable, the court of Chancery is not the body with whom a correcting power is lodged. That it shall not interpose in any case which does not come within a general description and admit of redress by a general and practicable rule." The US Supreme Court, however, has concluded that courts have wide discretion to fashion relief in cases of equity. The first major statement of this power came in "Willard v. Tayloe", 75 U.S. 557 (1869). The Court concluded that "relief is not a matter of absolute right to either party; it is a matter resting in the discretion of the court, to be exercised upon a consideration of all the circumstances of each particular case." "Willard v. Tayloe" was for many years the leading case in contract law regarding intent and enforcement. as well as equity.


title: Equity (law)

text: In the United States, the federal courts and most state courts have merged law and equity into courts of general jurisdiction, such as county courts. However, the substantive distinction between law and equity has retained its old vitality. This difference is not a mere technicality, because the successful handling of certain law cases is difficult or impossible unless a temporary restraining order (TRO) or preliminary injunction is issued at the outset, to restrain someone from fleeing the jurisdiction taking the only property available to satisfy a judgment, for instance. Furthermore, certain statutes like the Employee Retirement Income Security Act specifically authorize "only" equitable relief, which forces American courts to analyze in lengthy detail whether the relief demanded in particular cases brought under those statutes would have been available in equity.


title: Equity (law)

text: Equity courts were widely distrusted in the northeastern United States following the American Revolution. A serious movement for merger of law and equity began in the states in the mid-19th century, when David Dudley Field II convinced New York State to adopt what became known as the Field Code of 1848. The federal courts did not abandon the old law/equity separation until the promulgation of the Federal Rules of Civil Procedure in 1938.


title: Equity (law)

text: Three states still have separate courts for law and equity: Delaware, whose Court of Chancery is where most cases involving Delaware corporations are decided, Mississippi and Tennessee. However, merger in some states is less than complete; some other states (such as Illinois and New Jersey) have separate divisions for legal and equitable matters in a single court. Virginia had separate law and equity dockets (in the same court) until 2006. Besides corporate law, which developed out of the law of trusts, areas traditionally handled by chancery courts included wills and probate, adoptions and guardianships, and marriage and divorce. Bankruptcy was also historically considered an equitable matter; although bankruptcy in the United States is today a purely federal matter, reserved entirely to the United States Bankruptcy Courts by the enactment of the United States Bankruptcy Code in 1978, bankruptcy courts are still officially considered "courts of equity" and exercise equitable powers under Section 105 of the Bankruptcy Code.


title: Equity (law)

text: After US courts merged law and equity, American law courts adopted many of the procedures of equity courts. The procedures in a court of equity were much more flexible than the courts at common law. In American practice, certain devices such as joinder, counterclaim, cross-claim and interpleader originated in the courts of equity.


title: Matthew Hoffman (murderer)

text: Matthew J. Hoffman (born November 1, 1980) is an American convicted murderer known for the triple murder of Tina Herrmann, Kody Maynard, and Stephanie Sprang, as well as the kidnapping and rape of a teenage girl, which happened over the course of four days. The murders took place in Howard, Ohio. Police traced purchases for tarps found at the scene to a local Walmart which led them to Hoffman


title: Matthew Hoffman (murderer)

text: On November 10, 2010, Hoffman broke into Herrmann’s house after camping in the woods the night before. Just as Hoffman was about to burglarize the home, Herrmann and Sprang entered the residence, surprising Hoffman. When Sprang and Herrmann confronted Hoffman, he murdered both of them, killing the family dog as well. He then began to dismember the bodies in a bathtub and place the body parts into plastic bags. While this was happening Sarah Maynard, who was 13, and Kody Maynard, who was 11, got home from school and entered the house. Hoffman then attacked and murdered Kody.


title: Matthew Hoffman (murderer)

text: After the murders of Hermann, Sprang and Kody Maynard, Hoffman took Sarah back to his house, binding and gagging her, then leaving her in his basement. He then dismembered the three victims and stuffed them inside a 60 foot tall hollow tree. The family was later reported missing, and a three day search for the four ensued. Hoffman became a suspect when he was found sitting in the same area where Herrmann's truck was found. On November 14, detectives raided Hoffman's home and Hoffman was arrested. Sarah was rescued from his basement and survived.


title: Matthew Hoffman (murderer)

text: While incarcerated, Hoffman wrote a ten-page confession letter where he admitted to the murders and abduction, as well as revealing the location of the three bodies. While admitting to the abduction, Hoffman claimed he treated Sarah nicely and let her play video games, watch movies and eat hamburgers. Hoffman’s claim was contested by Sarah, with evidence of sexual assault.


title: Matthew Hoffman (murderer)

text: Hoffman pleaded guilty to 10 counts, after his bail was set to 1 million dollars. In January 2011, Hoffman was sentenced to life without parole.


title: Matthew Hoffman (murderer)

text: In Hoffman's house, an abundance of bags containing leaves were found. Hoffman had a strange obsession with trees and leaves, as he had piles of leaves littered all over his house and bags on top of bags inside his basement, where Sarah was kept. After confessing, Hoffman pleaded that they do not damage the hollow tree, where the three bodies were stuffed, but the tree was cut down to stop it from becoming a spectacle.


title: Mitsubishi 4G9 engine

text: The Mitsubishi 4G9 engine is a series of straight-4 automobile engines produced by Mitsubishi Motors. All are 16-valve, and use both single- and double- overhead camshaft heads. Some feature "MIVEC" variable valve timing, and it was the first modern gasoline direct injection engine upon its introduction in August 1996.


title: Mitsubishi 4G9 engine

text: The "4G91" uses a bore and stroke of for a total displacement of . With a 9.5:1 compression ratio and DOHC, four-valve-per-cylinder head and multi-point EFI, this engine produces at 6,000 rpm and at 5,000 rpm. The 4G91 was a short-lived model, mainly built between 1991 and 1995 and rarely seen in export markets. There was also a carbureted model, with at 6,000 rpm and at 3,500 rpm.


title: Mitsubishi 4G9 engine

text: The "4G92" displaces . It first appeared in the late-1991 Japanese-spec Mirage RS and Super R in DOHC form. The 4G92 is basically a version of the "4G91" with the bore increased to . In the original DOHC 16V form it produces . Later, a fuel-efficient SOHC version was added, but the 4G92 is best known in its high-performance "MIVEC" equipped DOHC version, which fully replaced "ordinary" DOHC in 1993. Power output was raised as high as , as found in the JDM Mirage Cyborg-ZR and 1992 Lancer MR, making it one of the most powerful 1.6-litre naturally aspirated engines. A modular displacement (MD) version of the 4G92 MIVEC was also produced – MD is Mitsubishi's cylinder deactivation system which helps improve fuel consumption.


title: Mitsubishi 4G9 engine

text: The 4G93 is a engine available in both SOHC and DOHC versions. Turbocharged variants are also produced. In mid 1996 Mitsubishi released a gasoline direct injection (GDI) version of the 4G93. This GDI model saw a production of over a million units though it was a heavy polluter therefore only sold in the Japanese market. A partially cleaned up version (with less power) was later sold in Europe, and was among the first of the modern GDI engines. It brought good fuel economy and, if well serviced, long engine life.


title: Mitsubishi 4G9 engine

text: The 4G94 is a version built in Japan, used in the Mitsubishi Lancer. It has a cast iron engine block with Multi-point fuel injection and an aluminum SOHC cylinder head with forged steel connecting rods and four valves per cylinder. The 4G94 Also comes in the GDI DOHC variant which can be found in the Mitsubishi Galant.


title: David Lammy

text: David Lindon Lammy (born 19 July 1972) is an English politician serving as Shadow Secretary of State for Foreign, Commonwealth and Development Affairs since 2021. A member of the Labour Party, he has been Member of Parliament (MP) for Tottenham since the 2000 Tottenham by-election.


title: David Lammy

text: Lammy was a Minister under Tony Blair and Gordon Brown, most recently as Minister of State for Universities in the Brown ministry. He served as Shadow Secretary of State for Justice from 2020 to 2021 and has served as Shadow Secretary of State for Foreign, Commonwealth and Development Affairs in Keir Starmer's Shadow Cabinet since November 2021.


title: David Lammy

text: Lammy was born on 19 July 1972 in Whittington Hospital in Archway, North London, to Guyanese parents David and Rosalind Lammy. He and his four siblings were raised solely by his mother, after his father left the family when Lammy was 12 years old. Lammy speaks publicly about the importance of fathers and the need to support them in seeking to be active in the lives of their children. He chairs the All-Party Parliamentary Group on Fatherhood and has written on the issue.


title: David Lammy

text: Lammy grew up in Tottenham, and was educated at Downhills Primary School there, followed by the awarding of an Inner London Education Authority choral scholarship, at the age of 10, to sing at Peterborough Cathedral and attend The King's School, Peterborough. He studied at the School of Law, School of Oriental and African Studies (SOAS), University of London, graduating with a 2:1. Lammy went on to study at Harvard University, where he became the first black Briton to attend Harvard Law School; there he studied for a Master of Laws degree and graduated in 1997. He was called to the bar of England and Wales in 1994 at Lincoln's Inn. He was employed as an attorney at Howard Rice in California from 1997 to 1998, and with D.J. Freeman from 1998 to 2000. He is a visiting lecturer at SOAS. Lammy is also a presenter on LBC and hosts a weekly Sunday show, from 10am to 1pm.


title: David Lammy

text: In 2000 he was elected for Labour on the London-wide list to the London Assembly. During the London election campaign Lammy was selected as the Labour candidate for Tottenham when Bernie Grant died. He was elected to the seat in a by-election held on 22 June 2000. Aged 27, he was the youngest Member of Parliament (MP) in the house until 2003 when Sarah Teather was elected.


title: David Lammy

text: In 2002, he was appointed by Prime Minister Tony Blair as Parliamentary Under-Secretary of State in the Department of Health. In 2003, Lammy was appointed by Blair as a Parliamentary Under-Secretary of State in the Department for Constitutional Affairs and while a member of the Government, he voted in favour of authorisation for Britain to invade Iraq in 2003. After the 2005 general election, Blair appointed Lammy as Minister for Culture at the Department of Culture, Media and Sport.


title: David Lammy

text: In June 2007, new Prime Minister Gordon Brown demoted Lammy to the rank of Parliamentary Under-Secretary of State in the Department for Innovation, Universities and Skills. In October 2008, he was promoted by Brown to Minister of State and appointed to the Privy Council. In June 2009, Brown appointed Lammy as Minister for Higher Education in the new Department for Business, Innovation and Skills, leading the Commons ministerial team as Lord Mandelson was Secretary of State. He held the position until May 2010 when Labour lost the election.


title: David Lammy

text: After Labour lost the 2010 general election, a Labour Party leadership contest was announced. During the contest Lammy nominated Diane Abbott, saying that he felt it was important to have a diverse field of candidates, but nonetheless declared his support for David Miliband. After the election of Ed Miliband, Lammy pledged his full support but turned down a post in the Shadow Cabinet, asserting a need to speak on a wide range of issues that would arise in his constituency due to the "large cuts in the public services".


title: David Lammy

text: In 2010 there were suggestions that Lammy might stand for election as Mayor of London in 2012. Lammy pledged his support to Ken Livingstone's bid to become the Labour London mayoral candidate, declaring him "London's Mayor in waiting". Lammy became Livingstone's selection campaign chair. In 2014, Lammy announced that he was considering entering the race to become Mayor of London in the 2016 election.


title: David Lammy

text: Following the party's defeat in the 2015 general election, Lammy was one of 36 Labour MPs to nominate Jeremy Corbyn, whom he is good friends with, as a candidate in the Labour leadership election of 2015.


title: David Lammy

text: On 4 September 2014, Lammy announced his intention to seek the Labour nomination for the 2016 mayoral election. In the London Labour Party's selection process, he secured 9.4% of first preference votes and was fourth overall, behind Sadiq Khan, Tessa Jowell, and Diane Abbott.


title: David Lammy

text: In March 2016, he was fined £5,000 for instigating 35,629 automatic phone calls urging people to back his mayoral campaign without gaining permission to contact the party members concerned. Lammy apologised "unreservedly" for breach of the Privacy and Electronic Communication Regulations. It was the first time a politician had been fined for authorising nuisance calls.


title: David Lammy

text: Lammy endorsed Keir Starmer and Angela Rayner in the 2020 Labour leadership and deputy leadership elections. After Starmer was elected Labour leader in April 2020, Lammy was appointed to the Shadow Cabinet as Shadow Secretary of State for Justice.


title: David Lammy

text: In the November 2021 Shadow Cabinet reshuffle, Lammy was promoted to Shadow Secretary of State for Foreign, Commonwealth and Development Affairs.


title: David Lammy

text: In August 2022, an inquiry found that he had inadvertently breached the MPs' code of conduct. He apologised in a letter to Parliamentary Standards Commissioner Kathryn Stone.


title: David Lammy

text: Over his years in politics, Lammy has publicly attributed blame for certain crimes to various specific causes and persons. He has also talked about black and ethnic minority peoples, especially those who are younger, their relation with crime and how they are treated by the criminal justice system.


title: David Lammy

text: On 11 August 2011, in an address to Parliament, Lammy attributed part of the cause for England's riots of a few days earlier to destructive "cultures" that had emerged under the prevailing policies. He also stated that legislation restricting the degree of violence that parents are allowed to use when disciplining their children was partly to blame for current youth culture, that had contributed to the riots.


title: David Lammy

text: Lammy blamed Prime Minister Boris Johnson, Home Secretary Amber Rudd, and Mayor Sadiq Khan for failing to take responsibility over fatal stabbings in London; he also blames inequality, high youth unemployment among black males, and local authorities cutting youth services and outreach programmes.


title: David Lammy

text: Lammy has stated that the criminal justice system deals with "disproportionate numbers" of young people from black and ethnic minority communities: despite saying that although decisions to charge were "broadly proportionate", he has asserted that black and ethnic minority people still face and perceive bias. Lammy said that young black people are nine times more likely to be incarcerated than "comparable" white people, and proposed a number of measures including a system of "deferred prosecution" for young first time offenders to reduce incarcerations. Lammy has claimed that black and ethnic minority people offend "at the same rates" as comparable white people "when taking age and socioeconomic status into account"; however, they were more likely to be stopped and searched, if charged, more likely to be convicted, more likely to be sent to prison and less likely to get support in prison.


title: David Lammy

text: Lammy has commented on Britain's history of slavery. He has also criticised the University of Oxford for admitting relatively few black students and students from disadvantaged backgrounds. He believes the Windrush scandal concerns injustice to a generation who are British, have made their homes and worked in Britain and deserve to be treated better.


title: David Lammy

text: On 5 February 2013, Lammy gave a speech in the House of Commons on why he would be voting in favour of the Marriage (Same Sex Couples) Bill 2013, critically comparing the relegation of British same-sex couples to civil partnerships to the "separate but equal" legal doctrine that justified Jim Crow laws in the 20th-century United States.


title: David Lammy

text: In January 2016, Lammy was commissioned by then-Prime Minister David Cameron to report on the effects of racial discrimination and disadvantage on the procedures of the police, courts, prisons and the probation service. Lammy published his report in September 2017, concluding that prosecutions against some BAME suspects should be delayed or dropped outright to mitigate racial bias.


title: David Lammy

text: He has spoken out against antisemitism within the Labour Party, and attended an "Enough is Enough" rally protesting against it. Lammy stated that antisemitism has "come back because extremism has come back" and is damaging support for Labour among Britain's Jewish community. He is a member of Labour Friends of Israel.


title: David Lammy

text: Lammy recorded a Channel 4 documentary for Remembrance Sunday called "The Unremembered: Britain's Forgotten War Heroes", which was broadcast on 10 November 2019. In it he reveals how Africans who died in their own continent serving Britain during WWI were denied the honour of an individual grave, despite the Commonwealth War Graves Commission's reputation for equality. The documentary was produced by Professor David Olusoga's production company; Olusoga described the failure to commemorate black and Asian service personnel as one of the "biggest scandals" he had ever come across.


title: David Lammy

text: The documentary inspired an investigation by the Commonwealth War Graves Commission. The subsequent report found that "pervasive racism" underpinned the failure to properly commemorate service personnel. The report stated that up to 54,000 casualties of "certain ethnic groups" did not receive the same remembrance treatment as white soldiers who had died and another 350,000 military personnel recruited from east Africa and Egypt were not commemorated by name or even at all. In April 2021, Prime Minister Boris Johnson offered an "unreserved apology" over the findings of the review. Secretary of State for Defence Ben Wallace apologised in the House of Commons, promising to make amends and take action. Lammy, who was critical to bringing the matter to light, called this a "watershed moment".


title: David Lammy

text: Lammy considers himself English; he said: "I'm of African descent, African-Caribbean descent, but I am English." In March 2021, Lammy was a guest on LBC when he rejected a caller's assertion that the dual identity of African-Caribbean descent and English nationality are impossible.


title: David Lammy

text: In October 2022, Lammy called for a full investigation into an alleged security breach by Suella Braverman. Lammy said: "The home secretary is the most serious job you could have in our state. This is a person who makes judgements about terrorism and counter-terrorism, who makes judgements about very, very serious offenders, whether they should be allowed out of prison, and for that reason, it's someone who, I'm afraid, judgement is critically important. I'm afraid this is a lapse of judgement that, quite rightly, she was sacked for. The question is, why was she brought back?"


title: David Lammy

text: Lammy described the Grenfell Tower fire as "corporate manslaughter" and called for arrests to be made; his friend Khadija Saye died in the fire. He also criticised the authorities for failing to say how many people had died. He has written about what he believes to be the shortcomings of the housing market.


title: David Lammy

text: Lammy is a staunch advocate of British membership of the European Union. On 23 June 2018, Lammy appeared at the People's Vote march in London to mark the second anniversary of the referendum to leave the European Union. The People's Vote was a campaign group calling for a public vote on the final Brexit deal between the UK and the European Union. On 30 December 2020 he voted for the Brexit deal negotiated by Boris Johnson's Government.


title: David Lammy

text: He supports shared parental leave, which he maintains would "normalise" fathers being an equal parent with the mother, and would mean they become more involved in the raising of children, arguing that the barriers to "fathers playing a deeper role in family life" are not just legislative, but also cultural. He points out Scandinavian countries such as Sweden as examples of where governments have successfully made this happen, which he states has also helped increase gender equality.


title: David Lammy

text: In 2013, Lammy accused the BBC of making a "silly innuendo about the race" on Twitter during the announcement of the next Pontiff where the BBC tweeted "will smoke be black or white?" in reference to smoke above the Sistine Chapel. Lammy criticised the BBC's tweet as "crass and unnecessary." He subsequently apologised after other Twitter users pointed out the role played by black and white smoke in announcing the election of a new Pope.


title: David Lammy

text: In January 2016 Lammy claimed that one million Indians sacrificed their lives during the Second World War, not for the survival of Britain and to fight Nazism, but instead for the "European Project."; the statement was strongly criticised and ridiculed by "The Spectator".


title: David Lammy

text: In 2017, writing in "The Guardian", Lammy argued that Comic Relief perpetuated problematic stereotypes of Africa, and that they had a responsibility to use its powerful position to move the debate on in a more constructive way by establishing an image of African people as equals. His comments came after a video featuring Ed Sheeran meeting and rescuing a child in Liberia was criticised as "poverty porn" and was given the "Rusty Radiator" award for the 'most offensive and stereotypical fundraising video of the year'. In 2018, in response to Lammy's comments and the backlash to Sheeran's video, Comic Relief announced they would take steps towards change by halting their use of celebrities for appeals.


title: David Lammy

text: In February 2019, Lammy criticised Stacey Dooley for photographs she posted on social media of her trip to Uganda for Comic Relief, and said that "the world does not need any more white saviours", and that she was "perpetuating 'tired and unhelpful stereotypes' about Africa". He also stated however, that he does not question her "good motives". The donations received for the Red Nose Day broadcast in March 2019 fell by £8 million and the money raised that year was the lowest since 2007, which some have blamed on Lammy's remarks. Critics of his view included Wikipedia founder Jimmy Wales and Conservative Party MP Chris Philp. Lammy responded to criticism with a statement in which he referred to the decline in donations being due to contributing factors of austerity, declining viewing figures, trends in the charity sector and format fatigue and that he hoped his comments "would inspire the charity to refresh its image and think harder about the effects its output has on our perceptions of Africa".


title: David Lammy

text: In October 2020, as a result of Lammy's intervention, Comic Relief announced it would stop sending celebrities to Africa for its fundraising films. They stated that they would no longer send celebrities to Africa nor portray Africa with images of starving people or critically ill children, instead, they would be using local filmmakers to provide a more "authentic" perspective and give agency back to African people.


title: David Lammy

text: In January 2019, Lammy described Rod Liddle having a column in a weekly newspaper as a "national disgrace" and accused Liddle of having "white middle class privilege" for expressing the view that absent fathers played a role in violent crime involving black youths. Writing in an article for "The Spectator", Liddle disputed Lammy's claim that he was raised in a family reliant on tax credits, which were not introduced in the United Kingdom until Lammy was aged 31.


title: David Lammy

text: In April 2019, Lammy was criticised for saying his comparison of the Brexit European Research Group (which consists of Conservative MPs) to Nazis and proponents of the South African apartheid was "not strong enough".