Tag Archives: United States

US House of Representatives passes GSP Renewal Bill; on to Senate

Alicia Nicholls

The first hurdle in the renewal of the United States’ Generalised System of Preferences (GSP) was overcome last week Tuesday when the US House of Representatives passed  H.R.4979 – To extend the Generalized System of Preferences and to make technical changes to the competitive need limitations provision of the program. This is welcomed news for the 120 countries and territories which benefit under the GSP, but just the first step towards the programme’s renewal.

The US GSP lapsed on December 31, 2017. This Bill provides a three year extension through to December 31, 2020. H.R. 4979 requires there be an annual report on the enforcement of eligibility criteria to ensure that countries designated as beneficiary developing countries are meeting the eligibility criteria.

Exporters would also be refunded for the duties collected during the lapse period. This is not the first time the GSP has expired, a fact which has created some uncertainty for exporters from GSP beneficiary countries seeking to make use of the programme. Other sources of uncertainty are that the President may graduate any country, remove products from GSP eligibility and remove products for an individual country which has exceeded competitive need limitations (CNLs). There are also a number of criteria for GSP eligibility which reflect the geopolitical  and other objectives underpinning the programme, for example, the ineligibility of communist countries.

The US GSP was instituted by the Trade Act of 1974 and it is one of several US government trade preference programmes which allow designated goods from certain disadvantaged countries to enter the US market at preferential rates of duty. According to the Office of the United States Trade Representative (USTR) fact sheet on the GSP, some 5,057 8‐digit U.S. tariff lines are eligible for duty‐free entry under the GSP, of which 1,519 are eligible for Least Developed Countries (LDCs) only.

The fact sheet further notes that in 2016, total US imports under the GSP was $18.7 billion, with the top five GSP beneficiary countries being 1. India ($4.7 billion), 2. Thailand ($3.9 billion), 3. Brazil ($2.2 billion), 4. Indonesia ($1.8 billion) and 5. Philippines ($1.5 billion).

As of March 2017, the GSP-eligible countries in the Caribbean include: Belize, Dominica, Grenada, Guyana, Haiti, St. Lucia, St. Vincent and the Grenadines, while the following non-independent Caribbean territories are eligible: Anguilla, the British Virgin Islands (BVI) and Montserrat.

Caribbean countries do not feature among top US GSP countries and there is a good reason for this. Most Caribbean countries are beneficiaries of the Caribbean Basin Initiative (CBI), while Haiti is a beneficiary of the HOPE Acts. As such, according to the 2015 Report on the Operation of the Caribbean Basin Economic Recovery Act (CBERA), in 2014, US imports under the GSP from CBI beneficiaries were just 0.02% of the total imports from those countries. As such, CBI countries’ exports under the GSP are quite small, though some countries like Belize, Jamaica and Dominica make more use of the GSP than others.

The GSP renewal Bill received bipartisan support in the House and is now before the Senate. For HR 4979 to become law, the identical bill would have to be passed in the US Senate. Failing this, there must be reconciliation of the bills passed in both houses before being signed into law by President Trump.

The text of the House Bill may be viewed here.

Linking Puerto Rico’s Debt Crisis to the US and the WTO

Namit Bafna & Shamy Ravishankar (Guest Contributors)

Puerto Rico, an island the US acquired in 1898 after the Spanish-American War, has lived in legal ambiguity with respect to its relationship with America and its statehood. It was recently declared bankrupt and has demanded that the US bail it out. This article explores if such a demand is well–founded, both in logic and in law.

A general reading of Puerto Rico’s history makes such a demand appear to be a prudent call. However, would this be desirable from the WTO law making perspective? Are bailouts allowed under WTO rules? We explore Puerto Rico’s dilemma through international relations and WTO law.

Understanding Puerto Rico’s Debt

Puerto Rico’s debt is a complex one with multiple types of debts; making it harder to negotiate agreements with various investors. Michael Williams, the Attorney who was handling Puerto Rico’s case states that its $123 billion debt is a consequence of years of economic stagnation and bad policy according to writers like Thomas Heath of the Washington Post. There is a serious need for debt restructuring, with investments needed for upgrading the island’s infrastructure (water works, waste management, and electric supply) as well as in boosting the economy.

Investors bought bonds from one of the eighteen authorised Governmental Agencies under the belief that the mainland Government would do everything necessary to prevent such an awful bailout situation from happening. However, the authorised agencies missed payments to the investors. Its cumulative bond debt is $74 billion. Even with an Oversight Board and PROMESA (Puerto Rico Oversight & Economic Sustainability Act of 2015-2016), it remains unclear how a wholescale economic turnaround can be initiated, with not only settling claims with investors (who will undoubtedly require fees for the Government’s defaulting on payments), but also improving the economy. Puerto Rico also requires funding for its pension commitments ($40 billion debt) and for MEDICAID, so that its social security obligations can also be carried out.

The Island has had a terrible recession since 2006, which has only been worsened by questionable policies of its previous Governments by borrowing more and thereby putting the island into greater debt. In addition to this, the current Government’s negotiation attempts with the aforementioned investors have not helped the situation by producing any concessions in the repayment of money owed to these creditors.

At this juncture, it is unfortunate to note that Puerto Rico has been knocking on Washington’s doors for over two years now, requesting more involvement from the mainland. It has been involved in Congressional Committee hearings and submissions before the United States Supreme Court. This invites the question: If any, what is the extent of Washington’s obligations to Puerto Rico, and in particular to this debt crisis? To ascertain this, we must go back in time and establish the exact nature of their relationship.

The US & Puerto Rico’s Relationship

The United States of America (US) has several categories of land holdings that it acquired over time, none of which are considered “Federal States”. These categories include territories (Guam, American Samoa, and US Virgin Islands), Possessions (which includes Baker, Howland, Midway, Wake, Palmyra, Kingman Reef, Jarvis and Johnston, that are all islands), and finally land holdings that are a Commonwealth (Northern Mariana Islands and Puerto Rico). It is to be noted that the Commonwealth category of land holdings are “insular political communities” that have affiliations with the mainland Government of the US. They are above territories in prestige and status but below the level of states. The Possessions and Territories have low levels of political and legal power on account of their fluctuating populations and not desiring self-determination. An another interesting nuance is the fact that the Commonwealth category of nations works with the US Congress and has an established political system that works for both the Congress and the Commonwealth land holding. However where the territories are concerned, the US Congress as more power to impose measures and in effect rule over the populations on the given territory. Citizens of the territories also cannot vote for the members of the Congress.

Over time the offshore territory policy of the US has varied and has even come before the US Supreme Court. In one case (Puerto Rico v. Sanchez) which went into the question of whether or not double jeopardy was applicable to Puerto Rico, the Judges of the Supreme Court had some interesting ideas of what Puerto Rico really was. If it was considered a Federal State then double jeopardy would not apply because federal proceedings could not disallow a state government to try a person for the same crime. If it wasn’t a Federal State then double jeopardy would disallow the person from being tried twice for the same crime (once by the US and once by Puerto Rico). This is because double jeopardy in the US does not apply where the person is being tried by “separate sovereigns” which in this case would be the State Court and the Federal Court. The counsellor for Puerto Rico suggested that it be given “Semi-sovereign status” so as to avoid the political implications of calling it a sovereign and thereby the 51st Federal State of the US, while also ensuring that Puerto Rico would also be able to prosecute Sanchez. Justice Kennedy then sought clarification on whether this would be an “interim sovereignty”? In the end, however, the Supreme Court held that the sources of power for itself and for the Court in Puerto Rico were the US Constitution because Puerto Rico was not a State and therefore the double jeopardy principle did not apply. This meant that the Court in Puerto Rico could not also prosecute Sanchez.

This reasoning is the strongest for the US Congress to allow the bailing out of Puerto Rico. It has had many occasions to either grant freedom to Puerto Rico or to make it the 51st federal state, as the US Constitution empowers the Congress to deal with matters of allowing a new state to be a part of the federation [Article IV. Section 3. Clause 1]. Given the fact that the US has both promised the United Nations to respect Puerto Rico’s sovereignty in 1953 (after allowing Puerto Rico’s Constitution to come into force in 1952), but also never fully allowed it to be a free independent nation, it would suggest that the US wants continued association with Puerto Rico. The fact that on several occasions, the US Government has rejected even the commonwealth status of Puerto Rico, deeming it as merely a territory, also points towards the same conclusion. The US wants these “land holdings” because it clearly benefits from the culture, natural resources and of course the population, who have served in the US military forces. That being said, the US Government does not want to give it full power that a State has. Regarding the bankruptcy bailout, the current US Administration has said it would not extend a helping hand, to what is undoubtedly (based on facts and legal precedent), a US problem.

The US policy on its offshore holdings seems to be one of granting those populations a “second class citizenship” status. It must be noted that when the US conceived the idea of a commonwealth, it was used to mean that the path to self-determination was automatic. This, however, has not taken place for Puerto Rico. Could this be a new twist to an already floundering and ever changing US policy on its offshore land holdings? Could this be the impetus necessary for the Puerto Ricans to demand freedom over their own affairs and formation of a new country that is divorced from the US?

The WTO perspective!

May be yes! But an underlying problem with bailouts would be that it may not be allowed under the WTO norms. Though bailouts are not anything new and the 2008 financial crisis triggered a few bailouts, every forthcoming bankruptcy should push for a clearer stance of the WTO on whether such bailouts would be considered as a subsidy and thus prohibited under SCM? Is it trade distortive under GATS? Is it time to introduce special WTO rules to deal with economic crises; making state actions non-vulnerable from WTO consequences?

The WTO has a well drafted subsidy discipline under the SCM Agreement. Any financial contribution which provides some benefits to an enterprise or an industry would result in a subsidy. Bailouts being sponsored from public money may attract provisions of GATS as they may provide benefit to the bank and its dependent (read “whole economy” of a major bank). As financing of banks would ultimately assist manufacturers, exporters and other players; they may affect other trading partners by creating artificial competitive processes.

However, as banks provide services, a bigger case forms under the GATS; for affecting competition in banking & financial services and making market competitive artificially. This may violate GATS’ obligation of National Treatment, Most Favoured Nation and Anti–Competitive provisions.

Despite its widespread use as a tool for economic reconstruction, no member state of the WTO has challenged bailouts at the WTO. But even if one appears in future, would it be desirable? As financial crises are unavoidable and it is practically impossible to pin down fault to any one entity, group of entities or even a state – bailouts are inevitable. They are required not just to save the bank but the whole economy. Thus, desirability of an “economic crisis exception” in the SCM and/or GATS should be put on table for member states and WTO expert committees before we witness another Puerto Rico-like situation in some other part of the world.

It is unfortunate that today, much after colonialism and colonialist tendencies have lost international relevance, that Puerto Rico’s relationship with the US is still not well-defined in law. However, for the purpose of alleviating this crisis, this article firmly backs considering Puerto Rico to be an integral part of the US; although it may not be necessary to use the terminology of “federal state”. Puerto Rico must be treated for all intents and purposes as a federal state, that entitles them to federal support and involvement, as was granted when Detroit required an $18 million debt restructuring in 2013. This is because, the US still claims Puerto Rico as a land holding, and the US Congress is still empowered under the US Constitution to manage the same. It may have given Puerto Rico some degree of sovereignty but the fact is that the US still has not granted it independence. By the very fact of this lack of independence from US policies and control, Puerto Rico has a right to seek and get aid from the Federal government.

Even if Bankruptcy is declared and the Federal Government pumps money into the Commonwealth, the question of its legality from WTO perspective still remains unresolved. Nevertheless, the bigger question is would bailouts even be challenged at the WTO? As bailouts are used by every member state to safeguard its economy from financial crisis, it is unlikely that it they will be challenged at the WTO, much like the fossil fuel subsidies.

Namit Bafna is a Corporate Lawyer working in Bangalore. His area of interest includes derivatives & trade law.

Shamy Ravishankar is a 2015 Felix Scholar, now working as a Human Rights Lawyer. Her areas of interest include environmental law, public international law and of course Human Rights Law. Follow her on twitter: @shamy27 or on her blog: https://theworldweknowsite.wordpress.com/

  1. Mark Joseph Stern, Second-Class Sovereignty, Slate (14 Jan., 2016), available at: http://www.slate.com/articles/news_and_politics/supreme_court_dispatches/2016/01/the_supreme_court_considers_puerto_rico_s_sovereignty_in_sanchez_valle.html
  2. Puerto Rico v. Sanchez, https://www.oyez.org/cases/2015/15-108
  3. Puerto Rico Report, The Relationship Between Puerto Rico and the U.S. (27 Feb 2016), available at: http://www.puertoricoreport.com/relationship-puerto-rico-u-s/#.WSAl_uuGPcd
  4. Thomas Heath & Tory Newmyer, Puerto Rico, with $73 billion in debt, forced toward bankruptcy, The Washington Post (3 May 2017), available at: https://www.washingtonpost.com/business/economy/puerto-rico-with-73-billion-in-debt-forced-toward-bankruptcy/2017/05/03/92e39d76-3020-11e7-9534
  5. Jaemin Lee, Beneath the Tip of the Iceberg – Global Financial Crisis, Bank Bailouts and the SCM Agreement, 10 Asian Journal of WTO & International Health Law and Policy (2015)

Will US Financial Deregulation help mitigate the de-risking phenomenon?

Alicia Nicholls

The exigencies of complying with a complex and often confusing maze of overlapping regulations, coupled with steep fines for compliance breaches, have been identified as principle drivers for United States-based global banks’ restriction and termination of correspondent banking relationships with respondent banks in other jurisdictions. As part of his promise to “Make America Great Again”, US President Donald Trump has pledged to cut the regulatory noose argued to be strangling US enterprise and growth. Will this deregulatory push have the unintended spin-off of mitigating the de-risking phenomenon facing several countries around the world, including Caribbean States?

President Trump has been adamant that ‘burdensome’ regulations passed during the Obama administration to avert a repeat of the Global Economic and Financial Crisis of 2008, have been fetters on US business activity and prosperity. While most available data point to the contrary, the Trump Administration and Corporate America posit that Obama-era regulations like the Dodd-Frank Wall Street Reform and Consumer Protection Act (2010) have reduced bank profitability and risk appetite, culminating in dampened bank lending to consumers and businesses.

President Trump has so far signed two executive actions on financial deregulation. The latter, an executive order dated February 3, 2017, sets out seven core principles for regulating the US Financial System. It mandates Treasury Secretary, Steve Mnuchin, to consult with the heads of the member agencies of the Financial Stability Oversight Committee (FSOC) and to submit to the President within 120 days a review of “laws, treaties, regulations, guidance” inter alia, which among other things inhibit regulation in sync with the Core Principles. There has been reportedly a shift towards more ‘pro-business’ regulators. Perhaps most telling, in contrast to his anti-Wall Street rhetoric during the campaign, President Trump has picked several former bankers (notably Goldman Sachs) for key cabinet and administration positions, including for Treasury Secretary.

Stringent compliance burdens and costs, as well as uncertainty about the interpretation of the regulations, are major drivers for banks’ avoiding, rather than managing risks. Will an unintended consequence of financial deregulation in the US be a mitigation of the de-risking phenomenon? While at first blush this conclusion may appear tempting, I respectfully submit that this may be an overly optimistic view, at least at this early stage, for the reasons which I outline below.

Firstly, the Trump Administration has set its cross-hairs firmly on the Dodd Frank Act which President Trump termed a “disaster”. This Act, which is hundreds of pages long, was passed in the aftermath of the Great Recession. It includes, for instance, rules against predatory lending, sets measures to deal with banks which become “too big to fail”, prohibits proprietary trading by banks for their own profit (Volcker Rule), inter alia. While Dodd Frank is not perfect and has been blamed for contributing to de-risking, repealing it would not only create an environment for a resumption of the pre-crisis risky behaviours by banks and other financial institutions. It would set the stage for a repeat of 2008, in much the same way that deregulation during the 1990s to early 2000s, including changes to the (now repealed) Glass-Steagall Act, laid the groundwork for the Great Recession, almost a repeat of the Great Depression of the 1930s.

Secondly, Dodd-Frank is just one aspect of the de-risking problem. There appears to be no indication that the Trump Administration intends to tackle the constellation of other regulations, including international anti-money laundering, countering the financing of terrorism (AML/CFT), tax and banking regulations (Basel III), with which banks, including in the US, must comply.

In the World Bank’s seminal 2015 global survey on the Withdrawal from Correspondent Banking, some 95% of large banks had cited “concerns about money-laundering/terrorism financing risks” as a driver for withdrawing from correspondent banking relationships. However, it is unlikely that the Trump Administration will try to rollback AML/CFT rules. President Trump’s ‘America First’ ethos has a strong national security undertone. Weakening the US’ AML/CFT rules would likely make him appear ‘soft’ on money laundering and countering the financing of terrorism. International pressure is also a factor as the US’ last Financial Action Task Force (FATF) Mutual Evaluation Report (2016) highlighted some AML/CFT weaknesses, including gaps in timely access to beneficial ownership information.

Thirdly, replacing existing regulators with so-called pro-business regulators does not necessarily mean that there will be a more lenient approach to fines imposed on banks for compliance breaches. Unlike popular belief, most of the large banks which have been made to pay record fines had indeed knowingly committed serious AML/CFT breaches.

Fourthly, even if financial deregulation in the US eases the regulatory pressure on US global banks, it does not affect two core problems which appear to be driving the de-risking of regional banks, namely the perceived unprofitability of providing correspondent banking services to indigenous Caribbean banks, and the Caribbean region’s unjustified characterisation as a ‘high risk’ region for conducting financial services. In the previously mentioned World Bank 2015 Survey, some 80% of large banks cited “lack of profitability of certain foreign CBR services/products” as a driver of exiting correspondent banking relationships.

Further to the latter point, Caribbean countries, particularly international financial centres (IFCs) are consistently and unjustifiably placed on US government lists deeming them as money laundering threats, despite the fact that no Caribbean IFC is currently on any CFATF list of ‘high-risk and non-cooperative jurisdictions’. The most notorious example of this unfair practice is the US’ annual International Narcotics Control Strategy Report, the latest edition of which listed 21 Caribbean jurisdictions without providing (as usual) any evidence to support the conclusions drawn.

Caribbean countries are consistently branded as tax havens in spite of the fact that all Caribbean countries have signed intergovernmental agreements (IGAs) with the US Government pursuant to the extra-territorially applied US Foreign Account Tax Compliance Act (FATCA) passed in 2010. Most Caribbean governments have already passed implementing legislation to bring their IGAs into force. In addition, while the US has opted not to be a part of the OECD’s Common Reporting Standard, several Caribbean countries have elected to be early adopters!

Added to this is that compliance officers in overseas banks usually view the Caribbean as a “collective” and not as individual countries; any perceived risks in one country are transposed to the Region as a whole.

Granted, it is still early days of the Trump Administration and the findings of the Treasury Secretary’s report on which regulations may possibly be earmarked for axing would not be known for some time. What does help, however, is where there is clarification of the rules through clearer guidance. For instance, for a long time it was unclear how far banks’ due diligence requirements were to go. In addition to knowing their customer (KYC), there appeared to be a growing consensus that banks were also supposed to know their customer’s customers (KYCC).  Definitive guidance through the FATF Guidance in October 2016 showed that KYCC was not required. Turning to the US, that same month the US Office of the Comptroller of the Currency (OCC) released guidance to assist banks in the periodic risk reevaluation of foreign correspondent banking relationships.

However, the Region would be well-advised not to expect any serious mitigation of the de-risking phenomenon stemming from US financial deregulation. Despite being a ‘pro-business’ administration, it should be remembered that the overriding goal of the Trump Administration’s regulatory rollback is to “Make America Great Again”, point blank. Any spill-over positive benefits to the Caribbean from Trumpian financial deregulation would be welcomed but unintended, and it is more likely that the regulatory rollback may perhaps be more harmful than helpful to the region.

There is no panacea for the de-risking phenomenon as it is caused by a multiplicity of factors. Regional governments and private sector stakeholders should continue their lobbying and advocacy efforts, including engagement with key US administration officials, regulators and the banking sector. Given the Trump Administration’s ‘America First’ disposition, lobbying efforts which emphasises the implications that possible derisking-related economic and social destabilisation in the Caribbean may have on the US’ homeland security would be more impactful than pure moral suasion.

These advocacy efforts should also highlight to US officials and to US correspondent banks Caribbean countries’ own efforts at continuously improving their AML/CFT frameworks and the compliance efforts of Caribbean banks. Regional banking stakeholders should also continue to explore the possibility of investing in technologies such as Know Your Customer (KYC) utilities and legal entity identifiers (LEIs) to assist in customer due diligence (CDD) information sharing between themselves and their US correspondents.

These were part of the remarks I gave as a panellist at the Barbados International Business Association (BIBA) International Business Forum 2017

Race for the White House and US-Caribbean Relations

Alicia Nicholls

US presidential election campaigns are keenly followed in the Caribbean not just for the riveting debates and endless intrigue, but for the important consequences which any change in US domestic and foreign policy will portend for the region. The US is not just the largest trading partner for many Caribbean countries and a valued ally. It is a major tourism source market and is also home to a large and growing Caribbean diaspora.

As of writing, the US presidential race has narrowed down to billionaire business mogul Donald Trump as the presumptive nominee for the Republicans. Former Secretary of State, Hillary Clinton, appears to be mathematically on track to securing the Democratic nomination, despite a continued spirited fight by Vermont senator, Bernie Sanders.

More so  than in any other election season in recent memory, trade policy has been a hot button topic in both the Democratic and Republican presidential primaries. Echoing sentiments long held by some Americans who are fed up with what they see as America getting a raw deal from free trade, the talking points of the presidential candidates have adopted a more protectionist and anti-trade tone than has been seen in recent election cycles. Strong criticisms are being leveled at the recently signed but not yet ratified Trans-Pacific Partnership Agreement with Pacific-Rim countries, as well as the longstanding tri-nation North American Free Trade Area (NAFTA) with Canada and Mexico.

Feeding into the populist, anti-establishment anger, candidates of both major parties have raised concern about the US’ large trade deficits with Mexico and China, the offshoring of US companies to countries with lower labour and production costs, and the consequential loss of American manufacturing jobs. The presumptive Republican nominee, known for his hardline positions on immigration and trade, colourfully equated the US’ deficit with China to rape.

As small island developing states, Caribbean countries have long posited that trade must be fair, foster sustainable development, and not be to the detriment of the local jobs and industries. However, the current tone of the US presidential campaign equates fair trade with trade which supports only US interests. It is maybe fortunate for the region that the Caribbean has not featured in any of the foreign policy discussions or debates during either the Democratic or Republican Primaries, although discussions around tax havens in light of the Panama Papers will have implications for the offshore financial centres in the Region. Anti-immigration rhetoric on the Republic side, while aimed primarily at the anti-immigration lobby’s favourite “villains” like Mexican and Muslim immigrants, could have implications for Caribbean migration to the US as well.

It would be naïve to think that any country would put another’s ahead of the needs of its own people. However, the current “America first” rhetoric raises issues of the future of unilateral preferential arrangements like the Caribbean Basin Initiative which provide beneficiary countries duty-free access to the US market for most originating goods, without the beneficiary country having to confer reciprocal access to US originating goods. Seventeen Caribbean countries and dependencies currently benefit from such status. Perhaps one saving grace is that the programme is seen to be a benefit to the US and the region has a trade deficit with the US. According to the Report to Congress released in December 2015, “[t]he value of U.S. exports to CBERA beneficiary countries grew 2.5 percent in 2014, exceeding the growth rate for total global U.S. exports, which grew 2.1 percent”.

The anti-trade, “America first” message which pervades the current US presidential election campaign brings into question whether there will be any resolution in sight to the long-running US-Caribbean rum dispute. Caribbean rum producing countries have long raised concerns about subsidies given by the US federal government to rum producers in its territories, namely Puerto Rico and the US Virgin Islands. The cover-over programme allows tax revenues raised by the Federal Government from the excise tax on both local and foreign produced rums to be transferred to the “location of production”, that is, the Puerto Rico and US Virgin Islands. The treasuries of both territories depend heavily on these subsidies for revenue to support investments in infrastructure, education and health and it is no surprise that both territories have increased rum production in order to increase their share of these revenues.

However, Caribbean rum producers like Barbados have argued these subsidies amount to unfair competition, by making Caribbean rums less competitive in the US market. The loss of market share not only means the loss of foreign exchange flows to cash-strapped Caribbean countries and a weaker current account position, but it also threatens jobs in the rum sector in Caribbean countries. So far there has not been any real progress on this issue and it is not pessimistic to think that this may very well go the same way as the US-Antigua Gambling case went after the US failed to comply with the World Trade Organisation’s rulings – nowhere.

An issue which is not directly trade-related but which would also have an impact on US-Caribbean trade, investment and remittance flows is that of the loss of correspondent banking relationships due to de-risking practices by US-based banks. Fears of harsh sanctions by US regulators has led several US banks to abandon the risk-based approach by avoiding risk altogether and terminate correspondent banking relationships with banks and money transfer providers in the region. It is an issue which CARICOM, in conjunction with the Caribbean Association of Banks, has been raising at the bilateral, and increasingly the hemispheric and multilateral level. Last week, St. Kitts & Nevis Prime Minister Dr. Timothy Harris led a delegation which raised the issue again with officials from the US State and Treasury Departments at a consultation in Washington DC.

Another key issue is that of climate change. Climate change is a threat to the world, but is an existential threat to the small island developing states of the Caribbean which bear the brunt of the adverse impacts. President Obama’s stance and support for tackling climate change may not be replicated by his successor. As one of the world’s largest emitters of greenhouse gases (GHG), US emission cuts and whether it ratifies the Paris Agreement will have important implications for whether the target of temperature increases of no more than 1.5 degrees or 2 degrees above pre-industrial levels is met.

Historically seen as the US’ backyard, the Caribbean has lost much of its geostrategic importance to US administrations in recent years. Conflicts in the Middle East, Africa, as well as tensions with Russia and China have occupied US foreign engagement. It has opened the door for greater engagement by the Caribbean with China which has expanded its influence in the region. However, there are issues on which the US and Caribbean still share common concerns, including issues of security, energy, combating drug and human trafficking, to name a few. At the U.S.-Caribbean-Central American Energy Summit in Washington DC, chaired by Vice President Joe Biden, the US reaffirmed its commitment to regional energy integration with the Caribbean and Central America.

There does appear to be another nugget of hope. On April 20th, H.R. 4939 – United States-Caribbean Strategic Engagement Act of 2016, a bi-partisan bill sponsored by New York Representative Eliot Engel (Democrat)  won the unanimous consent of the House Foreign Committee. The objective of the bill is “to increase engagement with the governments of the Caribbean region, the Caribbean diaspora community in the United States, and the private sector and civil society in both the United States and the Caribbean, and for other purposes”.

Though still in need of debate and approval by both Houses of Congress, the bill could be a catalyst for constructive re-engagement of US-Caribbean relations. Some of the objectives include increasing US-Caribbean diplomatic relations and economic cooperation, supporting regional economic, political and security integration efforts in the Caribbean, encouraging sustainable economic development , reducing crime and improving energy security, inter alia. Section 3 of the draft Bill provides that a multi-year strategy for US engagement with the Caribbean must be submitted no later than 180 days after the Act’s enactment. Whether this new re-engagement with the Caribbean will fit within the foreign policy agenda of the next president will have to be seen.

The US relationship with the Caribbean is a valued relationship with ties which go beyond trade. Despite these bonds, there is indeed need for deeper constructive dialogue, engagement and cooperation with the US on a number of pressing issues which have sustainable development and macroeconomic implications for the Caribbean. The Caribbean region does have supporters in the DC Beltway. These include members of the Caribbean diaspora who have ascended to positions of influence in Congress and which have been instrumental in lobbying the US government on issues of concern to the region. However, like everything else, the future tone of US-Caribbean trade relations, will depend heavily on who takes the presidential oath of office in January 2017.

Has the Caribbean Basin Initiative Outlived its Usefulness to CARICOM countries?

Alicia Nicholls

This September the United States International Trade Commission (USITC) released its biennial report on the operation of the Caribbean Basin Economic and Recovery Act (CBERA), one of the components of the Caribbean Basin Initiative under which CARICOM countries currently enjoy non-reciprocal, preferential access to the US market for most merchandise exports.

Three years ago I authored an article questioning whether the CBI was still relevant and beneficial to CARICOM countries. In that article I had highlighted that while the CBI still has relevance for CARICOM countries, its structure meant that CARICOM countries have benefited unequally and risk losing any margin of preference if its WTO waiver is not extended. I had concluded that a reform of the CBI would have been a preferred option but that a CARICOM-US FTA which had a trade and development focus could be more beneficial in the long term to CARICOM countries once it allows for special and differential treatment and capacity building assistance.

The USITC reports that average CBERA utilisation rates fell in 2014 and that the impact, though positive, has been small and again limited to a few exports and a few countries. This prompts two questions: has the CBI outlived its usefulness and is it time for CARICOM countries to negotiate a free trade agreement (FTA) with the US?

Current CARICOM-US Trading Arrangements

Most CARICOM countries currently enjoy non-reciprocal duty-free or reduced duty access for most merchandise exports (about 5,700 HTS 8-digit tariff lines) to the US market under the Caribbean Basin Initiative. The CBI is comprised of CBERA (non-expiring) and CBTPA (expiring September 30, 2020). Haiti also enjoys additional preferences under the HOPE Acts (Haitian Hemispheric Opportunity through Partnership Encouragement Acts of 2006 (HOPE I) and of 2008 (HOPE II)) and the Haitian Economic Lift Program (HELP) Act of 2010 which give preferential treatment to Haitian apparel, textiles, and certain other goods.

The stated goal of the CBI is to contribute to the economic growth and development of beneficiaries. The seventeen Caribbean beneficiary countries and territories are: Antigua and Barbuda, Aruba, The Bahamas, Barbados, Belize, British Virgin Islands, Curaçao, Dominica, Grenada, Guyana, Haiti, Jamaica, Montserrat, St. Kitts and Nevis, St. Lucia, St. Vincent and the Grenadines, and Trinidad and Tobago. Though a CARICOM country, Suriname is not a CBERA beneficiary.

In May 2013, CARICOM countries signed a Trade and Investment Framework Agreement (TIFA) in Port of Spain, Trinidad following a meeting between CARICOM Heads of Government and US Vice President Joe Biden. The TIFA, an updated agreement to one signed in 1991, is not an FTA. While it outlines several objectives and goals, it does not create binding commitments or market access. It does however create a CARICOM-US Trade and Investment Council which will be charged with executing the agreement. An annex to the Agreement called the Initial Action Agenda sets out priority areas for action. Currently, Grenada, Jamaica and Trinidad & Tobago are the only CARICOM countries which currently have bilateral investment treaties in force with the US.

Current Level of CARICOM-US Trade

The US is CARICOM countries’ largest trading partner for goods and services trade and a major tourism source market for CARICOM countries. However, the $8.5 billion USD worth of total US exports from CBERA countries (with and without preferences) only accounted for 0.36% of total US’ imports from the world, and declined from $8.9 billion in 2013 and $12 billion in 2012 (USITC 2015).

US product imports from CBERA countries are concentrated primarily in the energy and mining and manufacturing sectors (USITC 2015). Trinidad & Tobago, Haiti, The Bahamas, and Guyana jointly accounted for 89.1 percent of the value of US CBERA imports in 2014 (USITC 2015).

The USITC 2015 reports that CBERA utilisation rates, that is, CBERA imports as a percentage of total US imports from that country, have fluctuated over the past five years and have varied by country. After rising to 26.5% in 2013, average CBERA utilisation rates fell to 23.1% in 2014, although a few countries saw an increase in their utilisation rates during this period. This means that of the CBERA countries’ exports to the US in 2014 ($8.5 billion), only 23.1% ($1.97 billion), or less than a quarter, were done under CBERA. Most CARICOM merchandise exports to the US are therefore not under the CBERA but are either under the Generalised System of Preferences (GSP) or under Most Favoured Nation (MFN) applied rates.

According to the USITC Report, while Belize had the highest CBERA utilisation rate (62.5%) and was the fifth largest source of US imports under the CBERA in 2014, Trinidad & Tobago was the leading source of US imports under CBERA but registered the 6th highest CBERA utilisation rate for the same period. Trinidad & Tobago which has been the main beneficiary of CBERA due to its energy exports (mainly methanol and crude petroleum) has seen its total imports and utilisation rate decline due to declining US consumption, increased US production of crude oil and maintenance and shutdown of some factories in Trinidad (USITC 2015).

CBERA is of less importance for smaller islands of the region whose economies are services-based, mostly tourism and financial services. St. Lucia’s utilisation rate dropped from 51.7% in 2010 to just 7.5% in 2014. While Barbados saw its utilisation rate increase from a mere 3.8% in 2013 to 10.6% in 2014, this still is down from its rate of 17% in 2010.

The good news is that despite my prediction back in 2012, the WTO Council for Trade in Goods considered and approved the US’ waiver request for CBERA again and it is now up to the General Council to adopt it. Additionally, some of the products which are eligible for dutyfree access under the CBERA are not eligible under the GSP. However, more sobering is that the weaknesses of the CBI remain, including the exceptions in its product coverage, the lack of eligibility for services trade and certain stringent product eligibility requirements. Another problem is its unpredictability due to its unilateral nature. A beneficiary’s status may be revoked or the programme discontinued at any time. As an example, the US recently indicated it will suspend South Africa’s benefits under AGOA, a preferential programme for African countries, for allegedly failing to make continual progress towards eliminating barriers to U.S. trade and investment.

Generalised System of Preferences

Besides CBI, certain CARICOM countries also currently benefit under the Generalised System of Preferences (GSP), the oldest of the US’ trade preference programmes. Similar to the CBI, the GSP is a unilateral arrangement providing non-reciprocal duty-free access to eligible products originating in qualifying countries. Unlike the CBI which currently applies only to Caribbean countries, according to the USTR Report 2015, as of January 1, 2015, there were 122 designated GSP beneficiary developing countries, of which 43 were LDCs.

Under the GSP less tariff categories and products benefit from preferences than under the CBERA. However, LDCs, such as Haiti, are entitled to additional product coverage.

The only CARICOM countries currently eligible for benefits under the US GSP are Belize, Dominica, Grenada, Guyana, Haiti, Montserrat, St. Kitts & Nevis, St. Lucia, Suriname, St. Vincent and the Grenadines. Eligibility of a country for beneficiary status is subject to both economic and political considerations. Among other things, the US President is prohibited by statute from designating any communist countries (with exceptions) or countries which have expropriated, imposed taxes or other measures on US property as GSP beneficiaries.

If he/she finds that a country is sufficiently competitive or developed, the President may withdraw, suspend or limit the GSP status of any beneficiary country. Antigua & Barbuda, the Bahamas, Barbados, and Trinidad & Tobago are not currently GSP beneficiaries.

The GSP expired on July 31 2013 and was renewed retroactively on June 29, 2015. It has been extended to December 31, 2017. The future of the GSP beyond December 2017 is uncertain. However, some in the US believe GSP benefits should only be extended to LDCs, in which case only Haiti would benefit among current CARICOM beneficiary countries. Some so-called import sensitive products for the US, especially those in which developing countries have a competitive advantage such as most textiles and apparel, are not eligible. GSP imports are also subject to more stringent rules of origin than those under CBERA.

Would an FTA with the US be the answer?

Several former CBERA beneficiaries have concluded FTAs with the US, including five Central American countries (Costa Rica, El Salvador, Guatemala, Honduras, Nicaragua) and the Dominican Republic (CAFTA-DR in 2004) and Panama (US-Panama FTA in 2012). Given the issues outlined with both the CBI and the GSP, should CARICOM countries do the same?

Since the failure of the CARICOM-Canada negotiations, CARICOM still only has one FTA with a developed partner (the Economic Partnership Agreement with the EU). CARIFORUM’s negotiation position during the EPA negotiations was strengthened by the presence of the Dominican Republic. Such would not be the case in FTA negotiations with the US.
US FTAs, even those with developing countries such as CAFTA-DR and US-Panama, are generally light on development provisions and strong on those which provide protection for US investors and their investments, and for intellectual property rights.

For a sense of the US’ negotiation prowess, just take into consideration that with just a few exceptions the Trans-Pacific Partnership (TPP)’s investment chapter agreed to by 11 other negotiating partners is practically a carbon copy of the US’ Model BIT 2012. CARICOM countries will have to be strategic and clear on what they want to achieve and what are their deal breakers.

Priorities for CARICOM would be recognition of CARICOM countries’ small size and economic vulnerability and asymmetry in the commitments. As such they would likely be lobbying for special and differential treatment, development cooperation provisions, including technical assistance and capacity building to assist them, especially CARICOM lesser developed countries, in taking advantage of the market access opportunities an FTA with the US would open. With regards to services trade, CARICOM countries would likely seek enhanced commitments from the US in regards to (Mode 4) temporary entry for CARICOM natural persons.

Under the CBI, Caribbean countries are not required to extend duty-free treatment to like US imports into their territories. One of the main drawbacks to an FTA with the US will be the loss of tax revenues from the removal and reduction of tariffs on US imports as would be required under an FTA. One way to mitigate this would be lobbying for asymmetric and phased tariff removal, similar to what was committed to under the CARIFORUM-EPA with the EU. However, US FTAs, including CAFTA-DR are always ambitious in their scope in regards to liberalisation. Under the EPA, CARIFORUM was able to exclude a number of their most sensitive sectors from liberalisation. A deal breaker for any FTA with the US would be the extent to which CARICOM countries are able to protect nationally-important and sensitive industries from the stiff competition and possible death of these sectors and job losses if liberalised to competing US products too quickly. Civil society and industry consultations thus would be crucial to determining which sectors are most sensitive.

While an FTA with the US will likely increase the volume of US goods into CARICOM, the reverse is not necessarily guaranteed. Most CARICOM merchandise goods exports are already competing with other countries’ exports under normal trade conditions (i.e. at the MFN applied rate), and not under preferences. Therefore, the margin of preference secured for some CARICOM goods under a trade agreement may be negligible.

Investment treaty practice has evolved since the days when Grenada, Jamaica and Trinidad & Tobago signed their BITs with the US. The investor protections provided by a comprehensive investment chapter in a US-CARICOM FTA, coupled with robust investment promotion provisions, could serve as a signal for greater US investment to the region, while at the same time include development-friendly provisions and provisions which reinforce the right of the State to regulate.

As CARICOM service providers enjoy no preferential access to the US market, they face competition from service providers of countries which already have FTAs with the US. However, even when market access is created under an FTA for cross border services trade, there will be the need for mutual recognition agreements and visa waiver agreements in order to translate market access into market penetration.

The US will likely insist on a negative list approach to market access liberalisation of service sectors, the approach used in NAFTA and its subsequent FTAs. The negative list approach requires liberalisation of all sectors unless a reservation is specifically made in a country’s list of reservations. CARICOM countries and other developing countries have preferred to use the positive list approach used under the General Agreement on Trade in Services (GATS). It is a more development friendly approach which means only sectors specifically listed in a country’s schedule of commitments are liberalised and thus allows for the gradual liberalisation of sectors in keeping with each country’s development goals.
The US will also likely insist on no less favourable treatment than what CARICOM countries had agreed to with the EC under the EPA. CARICOM will also have to bear in mind that given a provision in the MFN clause in the EU-CARIFORUM EPA, the EU can insist on any more favourable treatment given to US than was given the EU under the EPA.

US treaty practice typically includes binding commitments on non-trade issues, such as labour. It has an on-going claim against Guatemala before the CAFTA-DR dispute settlement body in which it claims Guatemala has failed to meet its obligations under the CAFTA-DR agreement relating to effective enforcement of labour laws.

There are currently three main trade issues between the US and CARICOM countries which have to be addressed expeditiously even without an FTA. CARICOM rum exports are losing market share in the US market because of large subsidies given to rum producers in two US territories: the USVI and Puerto Rico. Secondly, the US/Antigua & Barbuda cross border gambling services dispute remains unresolved despite a WTO ruling in Antigua & Barbuda’s favour. An FTA will not necessarily resolve these issues as the DR which is a part of CAFTA-DR has complained about the rum issue as well.

Thirdly, the US has for a long time criticised copyright protection and enforcement in the Caribbean, a possible issue which might trigger disputes under any future US-CARICOM FTA. Caribbean countries constantly feature on the US Watch Lists under its annual Special 301 Report. The 2015 Special 301 Report is no different.

The Bottom Line

CARICOM countries should continue to take advantage of the non-reciprocal duty-free access to the US market provided by the CBI for their goods while these benefits last. However, while I do not think the CBI has outlived its usefulness just yet, it has several deficiencies which means it should not be treated as a long term strategy for boosting CARICOM trade with the US.

As mentioned, CBERA exports as a proportion of total CARICOM exports to the US are small and declining. The beneficial impact on regional exports has been unevenly spread and its unilateral nature, like the GSP, means benefits may be discontinued by the US at any time.

For the short term, the updated TIFA presents the best opportunity for CARICOM through the US-CARICOM Trade Council to lobby for reform of the CBI, address the long-standing rum and internet gambling disputes, and to negotiate concrete frameworks for increasing trade and investment between the US and CARICOM countries. Success on this front will not be automatic and will require strong regional cooperation, as well as effort on the part of both CARICOM and the US to ensure that concrete initiatives and commitments come out of these efforts.

However, given the importance of the US market for CARICOM and the growing importance of services-trade to regional economies, CARICOM will at some point  in the future have to consider, albeit cautiously, negotiating an FTA with the US as part of a long term plan to create a more predictable trade framework for US-CARICOM trade.

I say in the future because negotiations are an expensive and human-resource intensive exercise and require extensive research and stakeholder consultations. At the moment CARICOM countries are still grappling with the lingering effects of the 2008/2009 crisis on their economies and are also still struggling to implement many of the commitments made to the EU under the EPA. Progress on deepening CARICOM integration itself has ground to a halt and it would be easier to formulate a consolidated negotiating position as a more integrated region. I say cautiously because based on its current treaty practice the US is unlikely to extend the same level of special and differential treatment or development assistance which CARIFORUM was able to secure from the EU.

An interesting space to watch would be the on-going Trans-Atlantic Trade and Investment Partnership (TTIP) negotiations between the US and EU. The EU is currently insisting on the inclusion of certain sustainable development provisions into the agreement. An example is its recently released proposed text for the investment chapter. It would be interesting to see whether these provisions make it into the final TTIP text and that could help make it easier for CARICOM to insist on some of the same provisions in any future FTA with the US.

For my previous article on the relevance of the CBI, please click here.


1. What is IDEA?

IDEA (International Data Encryption Algorithm) is the second version of a block cipher designed and presented by Lai and Massey. It is a 64-bit iterative block cipher with a 128-bit key and eight rounds. While the cipher is not Feistel, decryption is carried out in the same manner as encryption once the decryption subkeys have been calculated from the encryption subkeys. The cipher structure was designed to be easily implemented in both software and hardware, and the security of IDEA relies on the use of three incompatible types of arithmetic operations on 16-bit words. The speed of IDEA in software is similar to that of DES.

2. What is the RC5?

RC5 is a fast block cipher designed by Rivest for RSA Data Security. It is a parameterized algorithm with a variable block size, a variable key size, and a variable number of rounds. The block size can be 32, 64, or 128 bits long. The number of rounds can range from 0 to 255. The key can range from 0 bits to 2048 bits in size. Such built-in variability provides flexibility in levels of security and efficiency.

There are three routines in RC5: key expansion, encryption , and decryption. In the key-expansion routine, the user-provided secret key is expanded to fill a key table whose size depends on the number of rounds. The key table is then used in both encryption and decryption. The encryption routine consists of three primitive operations: addition, bitwise exclusive-or, and rotation. The exceptional simplicity of RC5 makes it easy to implement and analyze. Indeed, like RSA, RC5 can be written on the "back of the envelope" (except for key expansion).

3. What is RC2?

RC2 is a variable key-size block cipher designed by Rivest for RSA Data Security. "RC" stands for "Ron's Code" or "Rivest's Cipher." It is faster than DES and is designed as a "drop-in" replacement for DES. It can be made more secure or less secure than DES against exhaustive key search by using appropriate key sizes. It has a block size of 64 bits and is about two to three times faster than DES in software. The algorithm is confidential and proprietary to RSA Data Security. RC2 can be used in the same modes as DES.

4. What are G-DES, DESX?

G-DES was devised by Schaumuller-Bichl to improve on the performance of DES by defining a cipher based on DES with a larger block size, but without an increase in the amount of computation required. It was claimed that G-DES was as secure as DES since the cipher was based on DES. However, Biham and Shamir showed that G-DES with the recommended parameter sizes is easily broken and that any alterations of G-DES parameters that result in a cipher faster than DES are less secure than DES.

5. How does One Use Triple-DES in CBC Mode?

Until recently, the most significant use of triple-DES was for the encryption of single DES keys, and there was really no need to consider how one might implement various block cipher modes when the block cipher in question is actually one derived from multiple encryption. However, as DES nears the end of its useful lifetime, more thought is being given to an increasingly widespread use of triple-DES.

6. What is Triple-DES?

For some time it has been common practice to protect and tansport a key for DES encryption with triple-DES. This means that the plaintext is, in effect, encrypted three times. There are, of course. a variety of ways of doing this; we will explore these ways below. See Question 85 for a discussion of multiple encryption in general.

A number of modes of triple-encryption have been proposed:

DES-EEE3: Three DES encryptions with three different keys.
DES-EDE3: Three DES operations in the sequence encrypt-decrypt-encrypt with three different keys.
DES-EEE2 and DES-EDE2: Same the previrous formats except that the first and third operations use the same key.

Attacks on two-key triple-DES have been proposed by Merkle and Hellman [MH81] and Van Oorschot and Wiener [VW91], but the data requirements of these attacks make them impractical.

7. What is DES with Independent Subkeys?

The DES algorithm derives sixteen 48-bit subkeys, for use in each of the 16 rounds, from the 56-bit secret key supplied by the user. It is interesting to consider the effect of using a 768-bit key (divided into 16 48-bit subkeys) in place of the 16 related 48-bit keys that are generated by the key schedule in the DES algorithm.

8. Is DES a Group?

No, DES is not a group. This issue was settled only after many years of speculation and circumstantial evidence and this result seems to imply that techniques such as triple encryption do in fact increase the security of DES.

9. What are the Alternatives to DES?

Over the years, various new block cipher algorithms have been designed as alternatives to DES. One is FEAL, a cipher for which numerous attacks have been discovered. IDEA is a cipher designed by Lai and Massey that seems much more promising and two more recent designs are RC5 and SAFER. In addition, the U.S. government announced in 1993 an algorithm called Skipjack as part of its Capstone project. Skipjack operates on 64-bit blocks of data, as does DES, but uses 80-bit keys, as opposed to the 56-bit keys in DES. However, the details of Skipjack are classified, so Skipjack is only available in hardware from government-authorized manufacturers.

10. Can DES be Exported from the United States?

Export of DES, either in hardware or software, is strictly regulated by the U.S. State Department and the NSA. The government rarely approves export of DES, despite the fact that DES is widely available overseas; financial institutions and foreign subsidiaries of U.S. companies are exceptions.

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LEGO color themes as topic models

Last updated: 04-15-2018

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LEGO color themes as topic models

So I’m back to the LEGO dataset. In a previous post, the plot of the relative frequency of LEGO colors showed that, although there is a wide range of colors on the whole, just a few make up the majority of brick colors. This situation is similar to that encountered with texts, where common words – articles and prepositions, for example – occur frequently but those words’ meaning doesn’t add much to a (statistical) understanding of the text.

In this post, I use a few techniques associated with text mining to explore the color themes of LEGO sets. In particular, I’ll build a topic model of LEGO color themes using latent Dirichilet allocation(LDA). Like k-means clustering, the LDA model requires that the user choose the number of topics \(k\). I try out several scoring methods available in R to evaluate the best number of color themes for the LEGO ‘corpus’.

The code for generating the analysis and plots, along with a little math background on the evaluation methods, is in this repo and this Kaggle notebook as the same analysis but run a smaller sample of sets. One motivation for doing this analysis was to try some methods from the handy Text Mining in R book by Julia Silge and David Robinson and some of my code follows their examples. In particular, in the TF-IDF section and the analysis of the distribution of documents over the topics. The LDA model is trained using the function from the package. Evaluation methods come from , , and the packages. Unit plots use the package.

The LEGO dataset contains around 11,000 LEGO sets from 1950 to 2017 and the data includes the part numbers and brick colors that make up each set. Following the text mining analogy, I take LEGO sets to be the ‘documents’ that make up the LEGO ‘corpus’, and colors are the ‘words’ that make up each document or set. I ignored part numbers but it would be possible to incorporate them in a similar analysis by considering the color-part number pair as the unit of meaning. In text mining, stop words are words that occur with similar frequency in all documents. These words are often removed before performing a statistical analysis. From the frequency plot, it’s clear a few primary colors along with black, gray, and white make up the majority of brick colors. These might have been treated as stop words and removed. Our corups has a vocabulary of just 125 unique colors so I chose to leave all of them in for the analysis. Term frequency inverse document freqeuncy(TF-IDF) is a metric of a word’s importance to a specific document. Term frequency is the frequency of a word’s appearance in each document and inverse document frequency is the count of documents the word appears in. Weighting TF by IDF means words appearing in all documents are down-weighted compared to rarely occuring words. A high TF-IDF corresponds to a color that is distinct to a LEGO set. First, we’ll look at low TF-IDF colors. Many of the colors-set pairs with a low TF-IDF score show up as common colors in relative frequency plot above. The three sets below are the 7-10th lowest TF-IDF set-color combinations. These are large sets with with a common color that appears less frequently in the set than in the corpus. For example, the darker gray in the ‘First LEGO League’ set makes up a small proportion of the set but occurs in many sets. The plot below shows the 10 set-color pairs with the highest TF-IDF score. These are sets with a high proportion of the set made up of a color that shows up infrequently in LEGO sets overall. The ‘Statue of Liberty’ set is an extreme example; It’s made up almost entirely of a single sea-green color that doesn’t occur in other sets.

After that somewhat cursory look at the LEGO sets, we’ll move on to building a topic model. The LDA model is a generative model of a body of documents (or LEGO sets or genetic markers or images). The output of the LDA algorithm is two distributions which represent the distribution of terms that make up a topic and the distribution of topics that make up a document. For our model, the term distribution is a distribution over colors that make up a color theme, while the topic distribution is a distribution of color themes that make up a LEGO set. In this generative model, the LEGO set can be generated by one theme or many themes. Tuning the number of topics in the model changes both the number of themes a set is drawn from and the colors that make up that theme.

I used several methods (chosen because they were readily available in R packages) for evaluating the number of topics that make up the topic model. This is not meant to be an exhaustive list of automated topic evaluation methods. For gauging topic coherence, for example, the Python Gensim library has a more complete pipeline which includes options to modify segmentation, word co-occurence estimation, and scoring methods. Perplexity measures the difference between distributions learned on a training and holdout set and the package used to build the LDA model has a function for computing perplexity. This was the only evaluation methods which required cross-validation. I ended up running the cross-validation twice and refined the spacing on the parameter grid to capture both the larger trend and some detail where I thought better parameters \(k\) might be located. There appears to be diminishing returns to model complexity between \(k = 20\) and \(k = 35\). After running cross-validation on the perplexity scores I reduced the number of models for the remaining evaluation methods. The remaining methods used models trained on the full data set. The package has several other metrics of the quality of the topic models. The skimmed the references in the package documentation but I don’t really understand these measures. At least two of the measures agree that fewer topics are better. There are several versions of topic coherence which measure the pairwise strength of the relationship of the top terms in a topic model. Given some score, where a larger value indicates a stronger relationship between two words \(w_i, w_j\), a generic coherence score is the sum of the top terms in a topic model: \[ \sum_{w_i, w_j \in W_t} \text{Score}(w_i, w_j), \] with top terms \(W_t\) for each topic \(t\). The coherence score used in the function uses the internal coherence(Umass) of the top terms. I compared the scores for the top 3, 5 and 10 terms. We can also treat the LDA models as a clustering of the LEGO sets by assign each LEGO set to the topic which makes up the highest proportion of that set, that is, the highest probability of a topic \(t\) given a document \(d\) \[ \text{gamma} \equiv \gamma = p(t|d). \] We then assign a document to a cluster by taking \[ \text{argmax}_t p(t|d). \] For comparison’s sake, I also ran a kmeans clustering using the weighted term(color) distribution for each document as the vector that representing that set. The kmeans and LDA clusterings were evaluated against each sets label which indicated the theme of the LEGO set. In total there were around 100 unique parent themes although this included sets who were ‘childless parents’. The clusters scores include Rand, adjusted Rand, Folkes-Mallow and Jaccard scores. All try to score a clustering on how well the discovered labels match the assigned . The Rand index assigns a score based on the number pairwise agreement of the cluster labels with the original labels. The other scores use a similar approach and two are versions of the Rand score but adjusted for random agreement. All scores except the un-adjusted Rand index decrease with more topics. There’s no reason to assume that theme labels match color topics. Poking around the data indicated that some themes ids are closely associated with a palette (Duplo, for example) while other parent themes are general categories with a mix of color theme. The last method for evaluating the learned topics is to look at how documents are distributed over the topic distributions. This example follows a this section from the tidytext mining book. The plot below visualizes this as how the documents are distributed over the probability bins for each topic. If too many topics have sets or documents in the low probability bins then you may have too many topics, since few documents are strongly associated with any topic. The chart above is also closely related to clustering based on LDA. If the distribution over the high probability bins of a topic is sparse then few LEGO sets would be assigned to that topic. (You can compare the plot above to the to the total distribution of LEGO sets over these topics below. Topic 40 had the fewest sets assigned to it.)

None of the preceding evaluation methods seem particularly conclusive. The pattern of diminishing returns on the perplexity scores is similar to other model complexity scores and suggests a value for \(k\) in the 25-35 range. This agrees somewhat with a visual evaluation of the set distribution over topic probabilities (the last chart above), where at 40 topics some topics seem to have few documents closely associated with them.

Aside from these scoring methods, we can also plot the color distribution(or relevance) for each topic or color theme directly. Below are charts for the models with 30 and 40 topics. The above plot is based on the beta \(\beta\) matrix, which gives the posterior distribution of words given a topic, \(p(w|t)\). The above plot shows a weighted \(\beta\) (or relevance) like that used in the LDAvis package. Although there may be more topics that have few sets associated with them as we increase the number of topics, the coherence of a few topics appears to improve. For example, the two plots below are selections from sets with the highest gamma, \(p(d|t)\) for each topic. When we go from 30 to 40 topics the top sets in the topic are removed by the remaining sets are more visually similar. (Also note that the sets that stayed had the top relevance score or weighted \(\beta\)). Of the automated scoring methods, the perplexity scores and the distribution of topics over term probabilities were the only two that seemed readily interpretable and matched my personal sense of which model best identified coherent color themes. I ran the same scores on a small samples of the data for this Kaggle notebook and the coherence score consistently pointed at models with fewer topics. It might be interesting to see how evaluation methods vary with parameters of the dataset like vocabulary size, variation in document size and the number of documents.

For the final model, I used the 40 topic model. Although LDA models the LEGO sets as mixtures of topics or themes, for the next two charts I assigned each set to a single topic using the same method that I used for clustering. And topics are a mixture of colors but I chose a color to represent each topic by blending the topic’s two most important color terms. In the last plot, the topics are represented by color probabilities of that topic: 1 brick represents roughly 1% of the distribution.

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Granting NSA permanent bulk surveillance authority would be a mistake
© Greg Nash

The legislation, which has left many privacy advocates aghast, comes in the form of a proposal by Sen. Tom CottonThomas (Tom) Bryant CottonGOP senator accuses Dems of ‘character assassination’ on Kavanaugh Sprint/T-Mobile deal must not allow China to threaten US security GOP senators condemn 'vulgar' messages directed at Collins over Kavanaugh MORE (R-Ark.) for a so-called "clean" reauthorization that would leave the current Section 702 intact. Of course, it isn't actually “clean,” in that Cotton's bill would remove the sunset provision that forces the program to expire Dec. 31 unless Congress explicitly re-authorizes it. In other words, even as Coats now deems it “infeasible” that the NSA will ever tell Congress how many Americans have been surveilled under Section 702—a number that likely would shock the conscience—Cotton wants to ensure 702 is never up for debate again.

If the NSA will not honor promises to Congress and civil-society groups now—when 702, a program Coats has called “the crown jewel” of the intelligence community, is up for reauthorization—how is the public to trust the agency will honor privacy and liberty when the program becomes law in perpetuity? Make no mistake, this is not fear mongering. This is a constitutional issue where the very notion of checks and balances between the branches of government is quietly under threat.

Coats explained to the Senate Intelligence Committee last month that the NSA ended “about” collection—that is, the practice of collecting digital communications in which a foreign target is mentioned, but is not the sender or recipient—due to technical limitations on the agency's ability to protect wholly domestic communications. However, he didn’t rule out resuming “about” collection if the agency discovers a technological fix. Paul Morris, deputy general counsel for operation at the NSA, told the Senate Judiciary Committee several weeks later they “might decide” to come back to it anytime. NSA representatives also have warned they would oppose a permanent legislative ban on this type of collection.

A recurring theme from law-enforcement and intelligence community representatives in recent House and Senate hearings is that technological developments can drastically change how government conducts surveillance. But even as agency representatives tell us how rapidly surveillance methods change, a permanent reauthorization of current surveillance methods presumes that future revolutions in technology won't affect Americans’ relative privacy. Not long ago, few could have conceived of an “email” or that it would become a major tool of communication.

If the intelligence community decides to resume “about” collection, a method proven to have violated Americans’ rights in the past, Congress’s oversight role should not be hamstrung by a permanent reauthorization. Eliminating the law's sunset provision would limit Congress's ability to revisit these questions and examine exactly how surveillance methods might change in the future. With far-reaching technological change always looming, Congress must periodically revisit the legal authority behind these intelligence tools — both to ensure they remain effective at protecting the nation, and that adapting an old law to new technologies doesn’t open the door to abuse.

Establishing a sunset for the program shouldn’t be anathema to those who are primarily concerned with national security. To the contrary, it is the best way to ensure the program remains viable and accomplishes the purpose of keeping Americans safe. Permanent reauthorization would limit any attempts to modify surveillance. It also increases the risk of another leak and public outcry, which easily leads to a knee-jerk reaction. Intelligence agencies could shy away from reasonable and effective procedures, absent any obligation to report to congressional oversight.

A kid genius working from a basement today may change the way our systems work tomorrow, crippling the effectiveness of Section 702 or opening the door to abuse. Giving law enforcement and the intelligence community's great power without built in opportunities to revisit that authorization would be a disservice to the security and civil rights of the American people. In the end, the most critical reform to Section 702 might already be part of the status quo.

Arthur Rizer (@ArthurRizer) is the national security and justice policy director at the R Street Institute, and Ashkhen Kazaryan (@Ashkhen) is an affiliated fellow at the non-profit TechFreedom.


Born in Tokyo in 1964, Japanese designer Nozomi Ishiguro graduated from Kuwasawa Design School in 1985 and the same year began working at Comme des Garcons until his departure from the house in 1997. Founding a personal atelier in 1998 with the concept being "Nothing is too much", Ishiguro crafts a range of products from handmade conceptual haute couture to his ready to wear line, Tambourine.

Related: Comme Des Garcons, Christopher Shannon, Facetasm


The Emerging Media major is a joint program offered by the Roy H. Park School of Communications and the School of Humanities and Sciences. Upon entering the program, students choose one of three concentrations: media entrepreneurship concentration, media computation, or media design and production.

This new major requires an exciting and demanding mix of classes including computer science, new media economics, video production, motion graphics and animation, and video game development. Beyond mastering the skills necessary to work with both communications and technology, students learn to critique and analyze the place of emerging media in modern culture.

Chad Hurley, Co-founder of YouTube and Avos, meets with students.


The US Court of Appeals for the Federal Circuit reversed the US Court of International Trade’s (CIT’s) decision in favor of US Customs and Border Protection, finding that Customs’ definition of “trademark” under the Tariff Act and its applicable regulations is unambiguous and includes unregistered trademarks and trademarks not subject to a pending application (in addition to registered marks and marks subject to a pending registration). JBLU, Inc. v. United States, Case No. 15-1509 (Fed. Cir., Mar. 2, 2016) (Moore, J).

JBLU, a California corporation registered as C’est Toi Jeans USA, imported jeans manufactured in China into the United States between September 11 and October 20, 2010. Multiple parts of the jeans were embroidered with “C’est Toi Jeans USA,” “CT Jeans USA” and “C’est Toi Jeans Los Angeles.” On October 8, 2010, JBLU filed trademark applications with the US Patent and Trademark Office (PTO) for C’est Toi Jeans USA and CT Jeans USA, but not C’est Toi Jeans Los Angeles. When the shipments arrived in the United States, Customs inspected the samples of jeans and determined that JBLU violated § 304 of the Tariff Act and the relevant regulations promulgated by Customs, 19 CFR §§ 134.46 and 134.47.

Under 19 CFR §§ 134.46, when words referring to a geographical location appear on an imported article or its container that “may mislead or deceive the ultimate purchaser as to the actual country of origin of the article,” the article must also be marked with the country of origin in a manner that is legible, permanent, in close proximity to the geographical words, and in at least a comparable size.” The more lenient requirements under § 134.37 specify that the country of origin marking must be legible and permanent, conspicuous, and either in close proximity to the geographical words or in some other conspicuous location. Customs determined that because JBLU’s jeans were marked with “USA” or “Los Angeles,” they also must meet the country of origin labeling requirements of § 134.46.

JBLU argued that its “Made in China” labels met the requirements of § 134.47. Customs agreed, but only as to the jeans that were marked with C’est Toi Jeans USA or CT Jeans USA and were imported after JBLU filed its trademark applications for those marks. Customs determined that the more stringent § 134.46 requirements applied to the jeans that were marked with C’est Toi Jeans USA or CT Jeans USA and were imported before JBLU filed its trademark application.

JBLU filed suit against the US government at the CIT. The CIT granted the government’s motion for summary judgment, giving deference to Customs’ definition of “trademark” as limited to trademarks registered with the PTO and trademarks subject to pending registration applications. The CIT found that C’est Toi Jeans USA, CT Jeans USA and C’est Toi Los Angeles were not trademarks under § 134.47, and that therefore the more stringent requirements of § 134.46 applied. JBLU appealed.

On appeal, JBLU argued that the trial court erred because an agency’s interpretation of a regulation is given deference only when the regulation is ambiguous, and that the word trademark as used in § 134.47 unambiguously includes both common law trademarks and federally registered trademarks.

The Federal Circuit agreed. The Court looked to the definition of trademark in the dictionary and in the Lanham Act, neither of which limit the term to registered trademarks or trademarks subject to pending applications. The Court reasoned that trademark rights stem from use, not registration. The government acknowledged the Lanham Act and dictionary definitions, but argued that the use of the word trademark in the intellectual property context does not inform its meaning in the context of § 134.47. The Federal Circuit disagreed. The Court looked to various regulations and the Tariff Act, and found that when the regulations intended to limit a regulation to “registered trademarks,” they expressly did so, whereas § 134.47 does not.


The DOJ's False Claims Act Memo: Its Meaning and Where We May Be Headed

GIR Just Anti-Corruption

In this article, Preston Pugh and Adam Braskich* discuss the Granston Memo, which outlines seven factors Department of Justice (DOJ) attorneys should consider when deciding whether to dismiss lawsuits brought under the False Claims Act (FCA). The article examines how companies can use the memo to their advantage when seeking dismissal of an FCA lawsuit, given what appears to be the DOJ's higher scrutiny of FCA cases. "While the Granston Memo does not purport to change DOJ policy, and only crystallises factors that have historically been considered when seeking dismissal, the full context of the memo suggests that the DOJ will indeed be taking a harder look at qui tam cases and seeking dismissals more often," Pugh and Braskich wrote. "This is a positive development for companies that have long endured a barrage of often meritless FCA lawsuits. By engaging counsel early and persuading the DOJ to use its authority where appropriate, companies may be able to avoid the expense of defending against many such suits."

*Former Miller & Chevalier attorney


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Seamus Heaney’s Regions

Length: 512 pages11 hours

Regional voices from England, Ireland, and Scotland inspired Seamus Heaney, the 1995 Nobel prize-winner, to become a poet, and his home region of Northern Ireland provided the subject matter for much of his poetry. In his work, Heaney explored, recorded, and preserved both the disappearing agrarian life of his origins and the dramatic rise of sectarianism and the subsequent outbreak of the Northern Irish “Troubles” beginning in the late 1960s. At the same time, Heaney consistently imagined a new region of Northern Ireland where the conflicts that have long beset it and, by extension, the relationship between Ireland and the United Kingdom might be synthesized and resolved. Finally, there is a third region Heaney committed himself to explore and map—the spirit region, that world beyond our ken.

In Seamus Heaney’s Regions, Richard Rankin Russell argues that Heaney’s regions—the first, geographic, historical, political, cultural, linguistic; the second, a future where peace, even reconciliation, might one day flourish; the third, the life beyond this one—offer the best entrance into and a unified understanding of Heaney’s body of work in poetry, prose, translations, and drama. As Russell shows, Heaney believed in the power of ideas—and the texts representing them—to begin resolving historical divisions. For Russell, Heaney’s regionalist poetry contains a “Hegelian synthesis” view of history that imagines potential resolutions to the conflicts that have plagued Ireland and Northern Ireland for centuries. Drawing on extensive archival and primary material by the poet, Seamus Heaney’s Regions examines Heaney’s work from before his first published poetry volume, Death of a Naturalist in 1966, to his most recent volume, the elegiac Human Chain in 2010, to provide the most comprehensive treatment of the poet’s work to date.

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Applying DevOps to Improve IoT Testing

When connected world came into being, the delivery of IoT services and its functionality has become a challenge. To make sure the IoT devices work as per their specification and interoperate with the physical world, IoT testing is a must for all companies. This article discusses about how devOps can be applied in IoT testing and how it helps to improve the services.

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Find how T&VShas developed a comprehensive and unique testing strategy to tackle any challenges associated with validating IoT applications and ensure that your product will work flawlessly, safely, and maintain a required level of quality.

2018-07-11T06:41:06+00:0011th July, 2018|Blog, Thought Leadership|


portrait of women smiling while on phone with friend

Based on the idea that it takes a village to serve those with more extreme challenges, Valley’s 24/7 Assertive Outreach Teams consist of medical staff, social workers, therapists, case managers, family advocates and peer specialists. From the moment we meet a client, we evaluate their current situation and create a treatment plan that focuses on immediate needs, like benefits, medications, counseling and housing. As clients make progress, we shift to skills development and independent living, with the ultimate goal of transitioning them to outpatient programs.


Posts Tagged ‘Narendra Modi’

#MannKiBaat on Yoga

Monday, March 27th, 2017
Image : Isha Yoga

Image : Isha Yoga

Honorable Prime Minister : Sri Narendra Modi ji ,

Namaskaram ,

In your #MannKiBaat on 26th March 2017 you spoke about #Yoga and asked for suggestions on promoting it .

Yoga is a rich treasure of our culture . Practice of Yoga can help create a more calm and joyous world .

I would like to share some ideas on promoting Yoga in India and internationally :

-       Yoga should be taught in schools and colleges across India . This will be an invaluable gift to students . Studies in USA have shown how Yoga when taught to children has had dramatic effects on their well being . Children in India are currently being denied their heritage by way of an education system where they spend 15-18 years and are never taught yoga.

-       The world of today is way more complex and competitive . Children are subject to huge amount of pressure , stress and distractions simply because the world is a very different place . Imagine an army that has powerful weapons yet sends it’s soldiers to war without ammunition. We’re doing that to our children in India by depriving them of Yoga in our education system.

-       All Indian airports should have a meditation room where people can practice Meditation / Yoga / Pranayama .

-       This will help those who already practice it to continue even when traveling

-       It would inspire other travelers to explore Yoga / Meditation

-       Larger airports like Mumbai / Delhi should have larger spaces for this where trained teacher & videos to basic yoga can be made available.

-       Progressively train stations and large bus stations ( as have been recently inaugurated in Gujarat ) should also have this facility of a space where people can meditate / do yoga . This should become part of specs of any future transport space of a certain scale .

-       Govt of India can take up spaces in international airports – especially those that are vibrant transit hubs like Singapore , Dubai , London , Qatar etc. Passengers often have long transit at these airports . Mostly people shop / eat or go on city tours.  GOI can take up spaces that can be managed by organizations like Art of Living / Isha Foundation where there can be an introduction to Yoga by way of videos, Live classes by a trained instructor.

Organizations like Isha Foundation / Art of Living  have an international footprint . They would be able to arrange for trained yoga teachers in various locations . A common curriculum can be evolved so that irrespective of which org manages the space – the structure and content would be largely common . It would be a powerful way to present Yoga and India to the world . This would have a positive impact on Indian tourism .

( I have listed 2 org for the purpose of illustration . There may be several more who can participate ) .

I thank you for your vision , zeal and efforts to promote Yoga in India and internationally .

Kind Regards ,

Savitha Rao

India Positive : a letter to Prime Minister Modi

Monday, August 8th, 2016

Dear Mr Modi ,

Thank you for all that you are doing for India. It is the first time that a Prime Minister has invited citizens to share ideas for the 15th Aug address to the nation. One of the many firsts of this truly inclusive government under your visionary leadership.

I run a business wherein we create eco and handcrafted products that help people bring sustainability and craft into their everyday living. We believe that Each One of Us Can Make a Difference. Together we make Change‘.

This 15th Aug pl invite every citizen to do something positive for India – every week. By 15th Aug 2017 we would have potentially 52 constructive actions for the nation. There are people in India (like you) who have dedicated their life to the nation. We have millions who are focused only on their life. In my work in the space of sustainability i have seen that for a lot of people there is a peculiar combination of apathy & powerlessness. With the rise of social media people voice their views. There is a lot of arm chair activism. Which perhaps (and hopefully ) is the first step towards activism in action.

Doing something for India – is not a call just to citizens with smart phones and access to social media . EVERY citizen should be invited , challenged , inspired to do something tangible and positive for India.

An auto driver may give a free lift to an aged underprivileged person , a college student can help a local Ngo , a working professional may help a student , a bank official official makes people aware about insurance n inspires them to go for it , a housewife decides to make her home plastic free , appreciate and support the social workers in your area , pledge to stop littering. People can use their core skills to make a difference. e.g a doctor treats at least 1 patient a week free of cost , a nurse tends extra care to a patient who does not have a family. Start a hashtag e.g #IndiaPositive. Idea is not self publicity. The goal is for Indians to get inspired by other Indians. As you have seen in your journey so far – once you engage people the outcomes are brilliant. All the astrologers of the world put together cannot predict the outcomes. Think of the hashtag as a way to crowdsource ideas for Indians by Indians to make a better India. Encourage media to run programs every month . In your #MannKiBaat every time remind people to continue their ‘#India Positive’ work , ask schools to get kids to write essays on what they are doing for it. Translate the essence of the Hashtag into regional languages. The spirit of it is more important than the physical words.

1 billion people. 52 billion potential ‘India Positive’ acts . This will bring Indians closer to each other and to India. We have problems of people from some regions not feeling welcome in some places , definitely we have a socio economic divide. Conscious ‘India Positive’ acts can integrate and turbo charge India in ways we cannot even imagine. People in some states feel less of a connection to India. Imagine Indians in Kashmir and N.East thinking about what they can do for India. When a person does something consciously and ongoingly for the country – they will become more engaged & aware citizens. An engaged & aware citizen is less likely to litter India , to let women be brutalised , to watch anti national elements try to fragment India. Our police and armed forces will have 1 billion new recruits. Today overseas Indians know that if their message reaches Ms Sushma Swaraj they can expected to be helped . Imagine a India where Indians in India know that they can rely on their fellow citizens .

Giving & Doing are powerful anti dotes to helplessness . It will connect a person to their inner strength. Let this herald the start of a new tradition in India. The current generation of kids grow up watching their parents consciously doing something positive for India. What a legacy that will be ! Truly it will make India ” Saare Jahan Se Accha”.

Jai Hind

Savitha Rao

Founder , Clean Planet


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97/07/04 چهارشنبه 11:10
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Small intestinal involvement by lymphoproliferative disorders post-renal transplantation

Small intestinal involvement by lymphoproliferative disorders post-renal transplantation:
a report from the post-transplant lymphoproliferative disorder international survey

Khedmat H, Taheri S.

In this study, data on post-renal transplant lymphoproliferative disorders (PTLD) collected from the existing literature were pooled and analyzed to compare the characteristics, predictors and prognosis of small intestinal PTLDs. We performed a comprehensive search for the available data by Pubmed and Google scholar search engines for reports on this subject. Data from 18 previously published studies, comprising 120 renal allograft recipients, were included in the analysis. Renal transplant recipients with intestinal PTLD were significantly less likely to have Hogkin's and Hogkin's-like lesions (P = 0.044) and to be younger at the time of transplantation (P = 0.07). Except for Hodgkin's-like lesions, histopathological evaluations elsewhere were comparable between the group with PTLD in the small intestine and age- and sex-matched renal transplant recipients with PTLD in other sites. The overall mortality was relatively higher in the control group (P = 0.09). When death only due to PTLD was used as the outcome, a trend toward better outcome was seen for the intestinal PTLD group compared with the other localizations (P = 0.1). The 1- and 5-year survival rates for intestinal PTLD patients were 57% and 37%, respectively, compared with 54% and 21%, respectively, for the control group. According to our findings based on analysis of international data, renal transplant patients with small intestinal PTLD are more likely to be of younger age but less frequently represent Hodgkin's and Hodgkin's-like lesions. They also have better patient survival compared with transplant recipients with PTLD in other locations. Further multi-center prospective studies are needed to confirm our results.

Source: PubMed

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Telling Coworkers Goodbye

Goodbye letters to coworkers -, Why is a goodbye letter to coworkers made? there are a variety of reasons why a person leaves the company. hence, there are different reasons on why a goodbye letter to coworkers is created.. Giving a goodbye speech to coworkers |, Farewell speeches mark the ending of an important chapter in life and the beginning of a yet unwritten story. when giving a goodbye speech, it is very important to show sincerity and express gratitude to coworkers. writing down key points can prevent loss of words or awkward pauses.. 50 sincere goodbye messages to write in a farewell card, Goodbye messages to coworkers can often be the most difficult ones to write. after all, how does one even begin to sum up the weeks, months or years that you’ve worked together, and the myriad of emotions they’ve inspired in you over all this time, or all the memories that you’ve shared?.

A Proven Formula for Writing Your Goodbye Email

Gifts for coworkers you'll want to keep for yourself, Despite spending countless hours, day after day, working alongside these people, you may not actually know your coworkers all that well. this uncertainty can lead to boring gifts like a starbucks gift card.. Here's what to say to coworkers when you experience a loss, If you experience grief, millsap recommends telling a few coworkers you can confide in and to consider telling your boss, particularly if it is impacting your ability to be productive.. Funny farewell quotes, Saying goodbye is not always an easy thing to do, the very thought of it conjures up feelings of sadness and longing. however, there are many funny quotes that can be used to take the sting out of a goodbye: from silly sayings to quotes that offer a lighthearted, humorous farewell that can help replace the sadness with laughter..

8.17 goodbye stranger - super-wiki, Synopsis. in a dark, empty warehouse, dean is hunting something. he turns around and is attacked by castiel.dean pleads with cas, stony faced, cas breaks his wrist and stabs him in the chest with his angel blade, killing dean.. the lights switch on.. 8.17 goodbye stranger (transcript) - super-wiki, Now. int. warehouse - night. dean comes around the corner in a darkened warehouse, gun drawn. he brings his gun up but it's struck down. he is struck down.. Farewell poems for colleagues: goodbye poems for co-workers, Goodbye for co-workers: we spend the majority of our time, not with our friends, not with our family, not doing any hobbies, no –we spend a large majority of our time at work. so of course, it is normal to form very strong bonds with the people that we work with. saying goodbye to.

Goodbye Quotes For Friendship | - Images ...