Masculinity Essay - 1321 Words

Part A: Bronies and the Social Construction of Masculinity According to Connell, there are four masculinities present in our society: hegemonic, complicit, marginalized, and subordinate. Hegemonic masculinity is the dominant form of masculinity in society. It is culturally valued as the most type of masculinity. Connell states that the qualities of hegemonic masculinity include heterosexuality, whiteness, physical strength, and suppression of emotions. When men do not fit the characteristics of hegemonic masculinity but they do not challenge it means they belong to the complicit masculinity category. These men often admire the characteristics of hegemonic masculinity. Marginalized masculinity is when men cannot fit into the hegemonic†¦show more content†¦Bronies experience gender policing by family, friends, and the media. â€Å"Gender policing is the responses to the violation of gender rules aimed at promoting conformity (Wade 355).† In the film Bronies: The Extreme ly Unexpected Adult Fans of My Little Pony, some Bronies could tell their stories about telling their friends and family and how other peers viewed them when they came out as a Brony. Lyle told his story about his Brony journey. One-day Lyle asked his mother what she would think if he liked the show My Little Pony, and she said she would be worried about him so he played it off as a joke. He felt his own mother would not accept the fact that he liked the show. He did not want his father to ever find out because he did not want his dad to think he was gay or a man-child. He did not want his parents to view him differently all because he liked a show aimed for younger girls. Alex was another guy from the video sharing his story. Alex lives in a place where a people believe that if a guy is not masculine that means they are homosexual. Alex was bullied at a gas station because he had pony decals on his car. The guy who bullied Alex about his car smashed his back window where the decals were at. Then the guy â€Å"playfully† pointed a gun at Alex and told him to stop with the gay girly shit. The media only criticizes Bronies by calling them weird, gay, creepy, pedophiles, disgusting, feminine, etc. Bronies faceShow MoreRelatedEssay about Masculinity786 Words   |  4 PagesMasculinity The definition of masculinity; Is the fact of being a man or having qualities considered typical of a man. I was stuck in that sentence that what is the qualities considered typical of a man. What is the quality of man, what is considered as a typical of a man? 1. Identities According to Victor, since the 1960s the challenges of feminism made men feel uneasy and confused about their power and identity. Women insisted that men had also to be more emotionally involved in relationshipRead More Feminism and Masculinity Essay820 Words   |  4 Pagescontemporary society, hegemonic masculinity is defined by physical strength and boldness, heterosexuality, economic independence, authority over women and other men, and an interest in sexual relationships. While most men do not embody all of these qualities, society supports hegemonic masculinity within all its institutions, including the educational institute, the religious institute and other institutes which form the ideological state apparatus. Standards of masculinity vary from time to time, fromRead MoreFeminine Masculinity Essay694 Words   |  3 PagesFeminine Masculinity Given that the structure of gender qualities has been a large part of our views, in regards to a variety of issues, a number of people take exception to variances from within these rules. Keeping this in mind, we will discuss the reasons why many individuals are discouraged from crossing traditional gender traits, and closely examine parts of the article assigned for this paper. In consideration of the editorial by Newsweek (2008), the author clearly uses the following linesRead MoreEssay on Masculinity in Crisis624 Words   |  3 PagesMasculinity in Crisis What is masculinity? Look it up in the dictionary and youll be met with factual, rather than opinion based answers of: 1. The quality or condition of being masculine. 2. Something traditionally considered to be characteristic of a male. 3. The trait of behaving in ways considered typical for men [ant: femininity. Our fathers recall running down the garden path to meet their old man returning from a days work, ruggedRead More Ernest Hemingway’s Portrayal of Masculinity Essay1169 Words   |  5 PagesErnest Hemingway’s Portrayal of Masculinity When thinking of masculinity in literature, one author has who has become synonymous with manliness comes to mind, Ernest Hemingway. Critics have spent countless hours studying his writing in order to gain insight into his world of manly delights, including his views on sex, war, and sport. His views can be seen through his characters, his themes and even his style of writing. The characters in Hemingway’s stories reveal much about how he feelsRead More Masculinity At Its Straightest Essay1870 Words   |  8 Pages The misguided perception of masculinity is the absence of anything remotely homosexual. In Michael Kimmel’s novel Guyland: The Perilous World Where Boys Become Men he discusses the contradictions of masculinity and what it takes to be seen as a real men. In American, middle class white society, manhood is more than beards and sleeping around with women, it is being as far away from feminine as allowed. The most foreign idea to most would be to consider a gay man to be â€Å"manly.† This unfathomableRead MoreHegemonic Masculinity Essay1114 Words   |  5 Pagesthan not people get their ideas of masculinity from the shows and movies they watch throughout their lives. In the article Hegemonic masculinity in media contents, by Peter J. Kareithi, he focuses much more specifically on how the media has presented it to the public, and less of the why, and how it started. The paper by Connell and Messerschmidt, Hegemonic Masculinity: Rethinking the Concept, does a much better job at explaining the history of hegemonic masculinity and how it came to be. Though togetherRead MoreEssay about Masculinity in the Media1647 Words   |  7 Pages Masculinity in the Media Masculinity has changed and evolved since the beginning of human creation. Males have had to adhere to the social norms of their time to survive without undue persecution. In the beginning of the 19th century, there was a shift in the way men could attain manhood. It was no longer easy for a man to enter into manhood with straightforward expectations and rituals. The state of manhood became difficult to obtain because of its precarious nature. During the sameRead MoreMark Twain Masculinity Essay2068 Words   |  9 Pages19th century America was a time period in which the definition of masculinity grew through a man’s power and work. To be considered as â€Å"that man†, what was needed was power, wealth, and even the appearance of a man himself. It was often times violent in the battle for who was the â€Å"manlier man†, as it related to the real world of Twain’s 19th century. Masculinity was a way for these men to create dominance and get their w ay throughout duels and even bargaining. Twain’s view on 19th century AmericaRead More Hegemonic Masculinity in American Society Essay1497 Words   |  6 Pages Masculinity is described as possession of attributes considered typical of a man. Hegemonic masculinity is a form of masculine character with cultural idealism and emphasis that connects masculinity to competitiveness, toughness, and women subordination. Masculinity hegemonic is the enforcement of male dominion over a society. Masculine ideology dates back to the time of agrarian and the industrial revolution in Europe when survival compelled men to leave their homesteads to work in industries

Compulsory Voting For A Representative Democracy - 2013 Words

Voting compulsion can very simply be defined as the process of electoral participation being law binding. However, the process and fundamentals of compulsory voting are not as simple. Twomey, in her article Compulsory Voting In A Representative Democracy: Choice, Compulsion, And The Maximization Of Participation In Australian Elections describes compulsory voting to stand â€Å"†¦ at the intersection between the principles of maximum participation of the people in elections and the expression of genuine choice.† Within this essay, I critique compulsory voting to show that it is a contradiction to basic civil liberty, it will be straining in terms of cost to enforce, and that random voting is most likely to distort results and with it the validity of our governmental system. I show this through the analyzation of several scholarly works in contrast to the arguments of critics who ensure that compulsory voting is for the greater good of society. However, this essay will ref ute this point by addressing the downfalls to this system and how these downfalls cannot be overlooked simply because of turnout. While people or individuals who are part of a democratic system may have the responsibility to vote, compulsory voting isn t necessarily justifiable under a democracy. This is not to say that only countries that are democratic practice voting compulsion-take Egypt and Singapore for example. However, the right to vote, a privilege within the western world, is also a primary counterShow MoreRelatedCompulsory Voting: Moral Issues and Necessities in A Democratic Nation1686 Words   |  7 PagesCompulsory Voting: Moral Issues and Necessities in A Democratic Nation Compulsory voting as defined by Merriam Webster is a system in which electors are obligated to vote in elections, or be subject to punitive measures such as fines or community service if violated. It is a system of voting that has been implemented successfully in over 30 countries, and has seen the increase in voting turnout on average of 20%. When compulsory voting was abandoned turnout after a period of mandatory votingRead MoreInfluence of Compulsory Voting1626 Words   |  7 PagesThe Idea of Compulsory Voting After Australia, Singapore, and Switzerland implemented compulsory voting and the turnout of voters grew, other democratic countries began wondering if the idea should be implemented globally. Research began on how this implementation affected countries with compulsory voting in place and how it would affect other countries such as Canada (Twomey, 2013). The idea that Canada, or another similarly democratic country, should pass a policy of compulsory voting would be againstRead MoreGiven The Increasing Decline In Turnout For Elections,1477 Words   |  6 Pageswhether a compulsory system of voting should be introduced in the UK and other advanced democracies. Proponents of compulsory voting would argue that voting is a civic duty, similar to paying tax or serving on a jury. They would also contend that it would lead to increased political participation and engagement and that parliament would become more truly representative and considerate of the whole electorate. Opponents, on th e other hand, would mainly argue that making voting compulsory would be anRead MoreLiterature Review : Compulsory Voting1605 Words   |  7 PagesLiterature Review: Compulsory Voting The American people and government pride themselves on the freedom of choice; the freedom to pursue life goals, happiness, and religion without fear. This ability was even written into the American Constitution as the First Amendment, giving the public the ability to voice opinions and express religious ideas without interference from the government. One of the liberties encompassed in the Constitution is the freedom to choose who to elect into power, givingRead MoreThe Issue Of Compulsory Voting1214 Words   |  5 PagesIn 2001, Gareth Thomas, a Labour MP for Harrow West for the past 18 years introduced a Private Members’ Bill for compulsory voting. However it did not progress beyond its first reading. Yet the question has not died out and whether the UK should follow the likes of Australia and Belgium still remains a hotly debated issue. The UK prides itself in being a leading force for democracy worldwide. It is thought to have become truly democratic in 1918 with the passing of the Representation of the PeoplesRead MoreUnited States Election Project Headed By Dr. Michael Mcdonald At University Of Florida961 Words   |  4 Pages it was the lowest overall turnout since World War II which occurred 70 years ago. Mid-term elections are congressional elections that occur halfway through the president’s term. Congressional ballots are held every two years and all House of Representative seats are contested as well as one-third of Senate seats. Most state legislature and governor elections(about thirty six out of fifty states) occur the same day(M.D.). These elections have the ability to change the way America is governed. ForRead MoreCompulsory Voting Vs. Mandatory Voting976 Words   |  4 Pagesmake a choice, are you still making that choice? Compulsory voting, or mandatory voting, is a system in which electors are required to vote in elections or at least attend a polling place on Election Day. If a voter does not appear at a polling place, and is eligible to vote, he or she may have to contribute community service or fines. This voting system exists in about a quarter of all democracies in the world. The core goals of compulsory voting are to increase voter turnout and to have an electionRead MoreVoluntary And Compulsory Voting Systems2125 Words   |  9 Pages Voluntary and Compulsory Voting Systems: The Affect on Democracy Across the globe day after day, nations have been progressively attempting to improve the political systems in which they inhabit, the most prominent political system currently standing as democracy. But what exactly constitutes as democracy? Democracy is a term holding a spectrum of meanings, many frequently overlapping. In its simplest, most basic form, democracy is referred to â€Å"rule of the people.† Being the broad term it isRead MoreVoting Is The Most Influential Tool874 Words   |  4 Pagesthe poles and it isn t a coincidence. voting is the backbone of democracy and yet voter turn out has been declining since the 1960 s, several factors effect the number of votes such as the feeling that our votes don t really count, the loss of the American dream and not being prioritized s a voter. Voting is the most influential tool we have as citizens of the united states to make changes to our country, it is how we choose our local representatives, all the way up to the president. In 2014Read MoreIs Voter Turnout Not A Single Citizen?3733 Words   |  15 Pagesparticipate in a democracy, that democracy would cease to exist. The very idea of a democracy is the notion that the people are in power and, therefore, will participate. Nevertheless, the trends of American voters in recent years have revealed that turnout is at a low point. According to Thomas Cavanagh, since the peek of electoral participation in post war 1960, voter-turnout has continually been on the decline (53). In other words, people just aren’t participating in the voting process as they

Ways has gender expectation changed over generations Free Essays

Gender expectation generally means sets of behavior that society decide how female or males should think, act or feel. Many people get confuse about thinking that sex and gender are the same; however, Ashley Grossman, sociologist, explains â€Å"sex is biologically assigned while gender is socially constructed, socially created†. (Grossman) Therefore, gender is influenced by cultural, family, environmental, religious, educational, socioeconomic and geographical setting; in other words, it Is more nurture than nature. We will write a custom essay sample on Ways has gender expectation changed over generations or any similar topic only for you Order Now Many theories have been written to describe the gender role, how It Is formed. For example, The Evolutionary Psychology Theory of Gender says that different roles in reproduction places different pressures on males and females, which creates gender roles as the man being the more competitive and violent figure, while the women being more involved in nurturing activities. The Social Role Theory of Gender says that gender roles are formed by psychological gender differences caused by contrasting social roles of women and men. The Social Cognitive Theory of gender states that children’s gender development occurs through observation and imitation of gender behavior. While my conclusions will not be based on these theories, they do help explain the formation and change of gender roles across time. Let us have a jump in the past. For more than 7000 years of human history, since agriculture and early States emerged, men were dominating the society they lived in, from the micro-world of families to the public macro-world of education and work. They have been tasked to provide for their family, from hunting and bringing home food for survival, like In our earliest days, to go to work and earn a paycheck and bringing home the bacon, like in our recent times. On the contrary, women were not even considered legal entities, persons in the legal sense. Until the end of the 19th century, an educated woman that was actually able to read books and have her own opinion, was not considerable a desirable wife. That’s how strong the Institutionalizing of differentiation between women and men within society was. Even today, In some society, women are the slaves of men, completely disemboweled and vulnerable; some they must cover their faces In public or forbidden to appear outside their home without the presence of their husband. Back o 18th Century, sex role were rigid, with women assigned to be caregiver, mother. â€Å"In classic German phase, women were expected to dedicate themselves to the four KS : Creche (Church), Chuck(Cooking) ,Kinder (Children), undo Killdeer (and cloths)†. (Tier-Anna 13) This is female expectation In the past, and If a woman tried to break out of these roles , she might risk getting server disapproval. Regarding the education of women, the intellect of woman was limited by an unjustifiable restriction: the education was not objectively given to women. They were excluded from the subjects which men were trained. In the case of few people, male or female, attaining some education beyond basic reading, writing, and little math, the higher education was reserved primarily for men. Moving on the political point of view, women were not allowed to get Involve In pollute: had no right to vote, had no chance to be a governor, been changed drastically, generation over generation, more in women than men: women have come a long way; they are getting married later in life, giving birth later and they are getting more opportunities in which in the past generation were not allowed to. Likewise, men have more responsibilities in many roles which in the past were expected from women. We can list the main differences from the past in family rules, education and work. In recent years there has been a redefinition of man and woman roles in the family. The man tends to spend more time with their children, taking advantage of a working woman. Statistically though, only the time spent with children has increased from the father side. The mother, despite working, still spends the same time with her children, which is still higher that the father. Eventually, the chores are done from a person they both hire. The role of father has changes so much that there has been a rise of men’s groups which feel been disadvantaged in this society where the legal system and the family court (in matters relating to access, child care and associated financial costs) is definitely in favor of women. Glen Sack shares his idea regarding to being househusband or stayed home dad (SHAD) that â€Å"Men need not fear a loss of power when they become a SHAD. While Shads are sometimes stereotyped as being at the mercy of their stronger wives’ commands, in reality, I have more power in the family now than I ever did hen I was the family breadwinner† ( Sacks 266). This example shows that staying home and taking care children, which is expected to be a woman Job, not only man can do, but also been accepted from society. Coming to education, women have finally gained access to all kind of education, even if there is still a margin of higher paid salary among the male gender. While there is improvement, for the social status of women in education and work participation rates, women still are experiencing conflict and differences in power in the workplace. For centuries there has been a sexual division of Jobs’ rates of pay were women were paid much lower than males. This difference was Justified by the idea that men had the responsibility to support their family, whereas women tent to work less because of family commitments, childbirth and child-bearing ; therefore, occupations dominated by men tend to be more lucrative. Today a woman has access to all kind of Jobs, but because not all women want to dedicate themselves to a career, many women prefer to work part- time or accept less demanding positions. But it is only a question of choice, a woman choice. It is important to notice that change for women in society has led to men re- evaluating their roles. In the 21st century, a group of fathers meets regularly. Their agenda is that divorce, family law and economic crisis are reducing many males to a marginalia role within society. They feel that their situation is very similar to women in the past. Many men feel that due to divorce, unemployment and shifting of social norms, they are in an inferior position. Coupled with females outperforming males in different areas, from school grades to Job performances, some males do not feel it is an advantage to be a male. Eventually, this historic conflict about social differences between men and women has come to a point where cooperation between the two could be helpful to both. The shifting of power from a man dominance world to woman dominance world means still inequality and discrimination. Maybe equality of opportunity and outcome can be better achieved difference. In the end, the competition of a Nation depends significantly on whether and how it educates its female and male talent to maximize its competitiveness and development potential; it means that each Country should strive for gender equality. How to cite Ways has gender expectation changed over generations, Papers

Battle of Salamis and Miltiades free essay sample

It was Miltiades who saw the fact that the Persian cavalary wasnt their as an advantage and to which could result in victory if the Athenian army attacked early. So Miltiades convinced Calimuchus the Polemarh to confront the Persian army and give him command. Miltiades battle tactics were both thoughtful and strategic as he used what he had learnt about the Persians against them with both ingenious and thoughful ideas. He made use of the terrain by placing his army on the top of the hill so that they had the higher ground and the best spot for when they made there way down hill so they were less tired and exhausted. It was said to be Miltiades who convinced the generals not to use their customary tactics of which hoplites (soldiers of greek cities) normally marched in an evenly distributed phanlanx of shields and spears. Miltiades was the one who had this great idea of attacking while the cavalary was not around. We will write a custom essay sample on Battle of Salamis and Miltiades or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page He knew that the Persians had there flanks set out that the strongest soldiers where in the middle of th e flank and the weakest on the outer flanks, so Miltiades devised this cunning plan to swap it around for his army. He made the strongest soldiers as the outer flanks and the weakest in the middle, so when it came to the fight the strongest soldiers could encirle the persian flanks and cause them distress and penick. His other contribution in the battle at Marathon tactics was the fact that he knew the Persians used arrow man. So miltiades had to think of a way to make it as if the Persian arrowman werent much help in inilation at all. This is the tactic i believe that sets him apart from every other commander; he made his army run into battle. as soon as miltiades army was in range of arrows he had them sprint and avoid the arrows, which this plan left the Persians dumbfounded. But as i write how genius he was i know that Munro points out that it was Miltiades who understood the Persian way of doing thins, it was Miltiades who understood his strengths and weaknesses, and Miltiades who proved to be the master of timing, waiting for just the right time to act. Miltiades was seen as the one to seize the best position and knew just when to take the offensive. But I see another person who was of even larger importance to the contribution of the Persian wars and his name is Themistocles.

Compare and contrast analysis socio

Note or Notice

Note or Notice Note or Notice Note or Notice By Maeve Maddox A reader wonders if there is a significant difference of connotation between the verbs â€Å"to note† and â€Å"to notice.† The question arose as he tried to decide between the following sentences to express the inner dialogue of a character: Rory noted that the CEO never asked for details. Rory noticed that the CEO never asked for details. Note, as both noun and verb, has been in the language since the Middle Ages. The earliest meaning of the noun was â€Å"a sign or symbol used in writing.† An early meaning of â€Å"to note† was â€Å"to put down a mark.† Eventually, the verb acquired additional meanings such as â€Å"to observe, to take notice of, to consider or study carefully.† Current usage includes these meanings as well as others, such as â€Å"to become aware of,† â€Å"to be struck by,† and â€Å"to put down in writing.† Notice in the sense of â€Å"to give notice of something† existed in the 15th century, but notice as a verb to mean â€Å"to take notice† didn’t come along until the 17th century, at which time it was rejected as an unnecessary Scotticism or Americanism for the phrase â€Å"to take notice.† The 1763 Universal Dictionary of the English Language included this caveat: â€Å"Notice should not be used as a verb.† Writing a little later (1789), another commentator observed that some English writers were using notice as a verb, but that it was â€Å"better† to avoid it. In regard to the reader’s question, I can offer only a personal reaction to the difference between the two sentences: Rory noted that the CEO never asked for details. Rory noticed that the CEO never asked for details. To me, the use of noted in the first sentence suggests that Rory is keeping track of the CEO’s behavior for some purpose, whereas noticed implies that Rory has merely observed the behavior in passing and is not trying to discern any particular significance in it. Want to improve your English in five minutes a day? Get a subscription and start receiving our writing tips and exercises daily! Keep learning! Browse the Misused Words category, check our popular posts, or choose a related post below:60 Synonyms for â€Å"Walk†Body Parts as Tools of Measurement10 Tips About How to Write a Caption

Critically and comparatively examine the extent to which Virginia Essay

Critically and comparatively examine the extent to which Virginia Woolfe's 'to the lighthouse' and Alice Walker's 'The Colour Purple' reflects the changing role - Essay Example This emerging middle class gave birth to what has since been referred to as the Cult of the True Woman, coined first by Barbara Welter in the mid-1960s (1966), a set of ideas and beliefs regarding the proper structure of the quintessential American family. By the time the Victorian era reached America, the ideal middle class life was firmly established as consisting of a father going off to work and a mother who stayed at home and reared the children. â€Å"The onset of industrialization at the beginning of the nineteenth century highlighted differences among women just as it exacerbated those between men and women workers† (Kessler-Harris, 1991). Widows, single women and others flocked to the mill towns of New England, New York, Pennsylvania and New Jersey attracted by the relatively high wages that could be earned in the factories, but even this began to change as the factory owners began working to reduce costs, lowering wages and demanding more work. â€Å"In 1870, 60 per cent of all female workers were engaged in some aspect of domestic service and another 25 percent earned their livings in factories and workshops. Except for janitorial work, factory jobs were off-limits to black women. As late as 1900, when the proportion of white women in domestic service had dropped below 50 percent, most women of color supported themselves and their families with various forms of domestic service. Others participated in the agricultural work that continued to sustain the majority of black families† (Kessler-Harris, 1991). At the same time, the more prosperous married women were prevented from holding any kind of job, instead expected to uphold the traditional feminine values of piety, purity, submissiveness and domesticity. However, as shown in novels of the period such as Virginia Woolf’s To the Lighthouse and novels

Ancient Roman Architecture Essay Example | Topics and Well Written Essays - 1750 words

Ancient Roman Architecture - Essay Example The Etruscans inspired the pedestal or podium below the early Temple of Jupiter Capitolinus in 509 B.C. The true arch may or may nit have come to Rome from Etruria, but both peoples often used the corbel arch and both liked decorative terra cotta. The Punic wars I and II, during the third century B.C., brought Rome into contact with Greek culture of southern Italy and Sicily; and with the conquest of Corinth, in 146 B.C., Rome subjugated Greece itself. From the Hellenistic and later Greeks, the Romans adopted the orders of architecture but modified them. They added a base to the Doric column and lightened its proportions to eight lower diameters in height. They joined the volutes of the Ionic capital with straight lines instead of the delicate Greek curves. The Corinthians was their favorite order. To the three Greek orders they added the Tuscan, a simplified version of the Structurally, the most important innovation of the Roman was the arch, which they used widely although they had not invented it. Next to the post and lintel, arch construction is historically of greatest importance. An arch is made of wedge-shaped stones that are arranged with the small side of the wedge turned down toward the opening. When the stones have been put in place by means of scaffolding or centering, their shape keeps them from falling, just like in the aqueduct of Segovia. Each stone of the arch, by its weight, exerts constant pressure on the stones an each side of it and the arch is held in position only by an exact balancing of these pressures. If that balance is upset, the arch collapses. As an old Arabic proverb has it â€Å"An arch never sleeps (The World Book Encyclopedia, p.640).†

The Role and Function of Stock Market Research Paper

The Role and Function of Stock Market - Research Paper Example Therefore, the illegal influence of counterparty on the transaction is eliminated to an investment whether invested by an investor or corporation. The smooth execution of stock markets activities not only helps profitable development at lower costs but also project the production of industry as well as employment. Moreover, the inoperative deposits with banks are used for cultivation of various economic sectors such as agriculture, commerce and trade. Thus, by playing its vital role in promoting economic system, its also increases the societal prosperity in the state. Generally the stock markets consist of board of directors, chief executive officer (CEO), deputy chief executive officer (DCEO) and heads and staff of departments and sections. The general administrative structure of stock markets is as follows: (iii) It also suggests most suitable solutions to business problems and prepares trading announcements. Moreover, it is responsible to ensure that these reports must reach to the concerned parties, trading system operators and conducts the required investigation to license them to function. It is a sub-market of the London Stock Market. ... Moreover, it is responsible to ensure that these reports must reach to the concerned parties, trading system operators and conducts the required investigation to license them to function. (iv) It takes actions on the execution of the applicable listing instructions by security issuers. (b) Surveillance and Inspection Department. This Department undertakes the following tasks: (i) Executed trading operations are surveiled on the stock markets to ensure their agreement with valid legislations. (ii) It scrutinizes members of stock exchange and registers them to ensure their conformity with rules and regulations of the market. (iii) It receives, examines and recommends appropriate solutions to investors' complaints. (c) Legal Department. Role and task of this department is as follows: (i) This department issues legal procedures and advices to all sections of stock market regarding outgoing and incoming correspondence. (ii) All the agreements and contracts are reviewed by this department. (iii) It acts upon court decisions passed related to securities. Also it follows up the cases raised by stock market or against it. (d) Research and International Relations Department. This Department has the following tasks: (i) It collects the data and information from various departments of the stock market regarding economic and financial studies and then research on it to conclude statistical facts and figures (ii) It prepares official press releases and computes indexes. (iii) For the public awareness, this department arranges conferences, visits and training workshops. (e) IT Department. This Department does the following tasks: (i) IT department is responsible for the protection, maintenance and updating of software and hardware systems

Brand Placement in the Indian Film Industry

Brand Placement in the Indian Film Industry Churning out nearly 1,000 films a year, the Indian film industry is the largest in the world. Now, aided by technological advancements, the industry is set to take a further leap across production, exhibition and marketing. In such a scenario, product placement in mainstream films deserves a renewed focus because as a marketing communication tool, it is fast emerging as the medium with maximum potential to capture and covert audiences to potential consumers. This is especially relevant in a world where traditional media vehicles are increasingly failing to reach the consumers for various reasons.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Brand/product placement is a promotional tactic used by marketers in which a real commercial product is used in fictional media, and the presence of the product is the result of an economic exchange, it is an advertising technique in which the companies pay a fee or provide service in exchange for a prominent display of their product. Product placement occurs in plays, films, television series, music videos, video-games and books. The objective of such brand communication is to expose the audience to a brand, whereby the effect can be maximized in terms of increased awareness and higher recall, so that the customer will buy the brand which has maximum recall; and to satisfy the customer to optimum level.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   This research paper looks at the rationality of brand placement, the possible congruity that can be built in the story, as indicators of success of effective brand placement in films and if so, as variables in bringing desired change in consumers attitude. The paper highlights the basic reasons for placing products and brands in Mainstream Hindi films and the effectiveness of these placements as a tool for enhancing the recall value of brands in long run brands in the films. This paper also gives insight as to how audiences react to product placement, do they think it as an effective alternative media, if it has any impact on them and if they find it ethical.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   The research incorporated case studies of four mainstream Hindi films, selected on basis of their box office fate and the amount of brand placement. These films are then anaysed in terms of effectiveness of the variety of placements in bringing the desired recall and recognition values. The four films selected include Om Shanti Om, Goal, Chak De! India, and Lage Raho Munna Bhai. The research concludes with suggestions regarding areas for future research.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Product placement has come as a blessing in disguise for both, the brand and the filmmaker. Through it, the brand managers get the clutter breaking opportunity to look beyond the 30 sec TV commercial and the filmmaker gets to earn huge revenues by just showing the brand being used by protagonist or let it exist in the background. The deal is just perfect for both of them. But the most important person in the deal is the consumer who is vigilant and smart enough to notice whats served to him and has reservations against in your face placements. Surely he does not want more intrusion in his life. Hence, product placement has arrived and here to stay. But a word of caution is to be always kept in mind, by both the brand and the filmmaker- if as communication purveyors they are looking for better and innovative means of reaching the consumer, the consumer himself is already bombarded with marketing tactics from all over and in the three hours of movie, he would want to forget about all these intrusions, including advertising. Thus overdose of brand placement will only drive away the consumers from the cinema halls, resulting in a flop film and a failed marketing endeavor. INTRODUCTION BACKGROUND The Concept of Product Placement Product Placement in Movies Types of Product Placement Brand Placement is Different from Celebrity Endorsement The Opportunity of Brand placement, Consumer Information processing and Issue of Brand Congruity WHAT IS PRODUCT PLACEMENT? A product placement is the inclusion of a product, package, signage, a brand name or the name of the firm in a movie or in a television programme for increasing memorability of the brand and instant recognition at the point of purchase. Placements can be in form of verbal mentions in dialogue, actual use by character, visual displays such as corporate logo on a vehicle or billboard, brands used as set decorations, or even snatches of actual radio or television commercials. The objective of this communication strategy is to expose audience to a brand, whereby the effect can be maximized in terms of increased brand awareness and higher recall, so that the customer will buy the brand which has the highest recall; and to satisfy the customer to optimal level. Because of proliferation of advertisements and the consequent difficulty in getting commercial messages to reach and influence potential customers, product placement appears as an interesting alternative to traditional marketing communication tools. Basically, there are three ways product placement can occur: It simply happens. Its arranged, and a certain amount of the product serves as compensation. Its arranged, and there is financial compensation. Sometimes product placement just happens. A set dresser, producer, director, or even an actor might come across something he thinks will enhance the project. Usually this has to do with boosting the level of credibility or realism of the story being told. Example can be use of Tata Indigo car in movie Aaja Nachle. The car has been used to as mode of transport for the lead actress both when she arrives from abroad and when she goes back. Interestingly the vehicle is widely used as commercial luxury vehicle in many Indian towns. So use of this car added a touch of realism in the movie. However, when contacted, the representatives of the car company denied being approached about the use of their product. Arranged product placement deals fall into two categories: Trade-off of integration or placement for a supply of product Financial compensation for placement or integration The most common type of deal is a simple exchange of the product for the placement. Example, lets say the production team wants lead actor to display a quirky affinity for a particular type of beverage. This will come across rather strongly over the course of the program which means the chosen product could get a lot of air time. It turns out that someone on the crew knows someone who works for that beverage. The production people approach the beverage company folks with a proposal and a deal is made; in exchange for the airtime, the cast and crew are provided with an ample supply of the beverage at work. Example: the movie Krish where the lead actor drinks a lot of Bournvita. Sometimes, a gift of the product isnt an appropriate form of compensation, so money powers the deal. Imagine that the marketing team at Tag Heuer has heard about this project and feels that, given the star power of the actor playing lead, this project would be a great vehicle for showcasing its product. Someone from Tag Heuer approaches the set dresser with a financially lucrative proposal. Eventually, they come to an agreement and the wristwatch casually appears in several scenes. Before product placement really saw a surge in the mid 1990s, it was pretty much a do it yourself effort. Now there are specific corporate positions and entire agencies that can handle the job. Some larger corporations will dedicate personnel to scout out opportunities for product integration or placement within films, television shows and even games and music. Good example would be Madisons specialized division for in-film branding, MATES. PRODUCT PLACEMENT IN MOVIES Every frame in a movie has an opportunity for branding. With that intent, a number of marketers are now using movies to project the core values of their brands. In-film advertising, in its most effective form, is about a brand being a part of cinemas content. Many global brands are now turning to this medium for the sheer impact that a movie can make on its audiences. Product placement in movies has gained momentum all over the world. The practice of using branded products in Hollywood movies started as casual process since 1940s. The earliest example would be 1945 movie Mildred Pierce with film star Joan Crawford drinking Jack Daniels bourbon whiskey. The current Hollywood movies feature a plethora of products ranging from telecommunications (Motorola, Nokia), automobile (Audi, BMW, Chrysler, Jeep, Lada and Mercedes) to other products like FMCG goods, Tobacco etc. Good examples are James Bond movies. Indian mainstream Hindi films, popularly known as Bollywood the world over, caught up with the trend in 1970s with Rajkapoor using Rajdoot in his movie Bobby. Popularity of movies as medium for product placement grew because of the increasing difficulty of using television as an effective medium to target audiences. The film medium provides an excellent message reach and message life and an effective method of popularizing and immortalizing brands. One of the key drivers for movies becoming a popular medium for product placement has been the increasing difficulty of using television as an effective medium to target audiences. The advent of cable and satellite television has meant that audiences have become more fragmented and tend to demonstrate a greater level of ad avoidance. By contrast, the film medium provides an excellent message reach and message life and an effective method of popularizing and immortalizing brands. The movie-goers vicariously experience the brand as they make a connection between the film, the actor, the product and its consumption, and argue that product placement acts as a perceptual clue which directs behavior to purchase a product to satisfy a need or reinforce a social status. Movie product placement is viewed as a cheaper and more effective alternative to traditional marketing communications, despite its inflexibility, but as a result of the establishment of specialist placement agencies, and thro ugh increased brand exposure through cable, satellite, video and DVD, a typical movie with international distribution can reach over one hundred million consumers from box office to TV. There seem to be three reasons why marketers consider product placement in movies as interesting communication strategy. First watching a movie is high attention and involving activity. The particular exposure context associated with movies in theatres (lights off, minimal noise and distraction possibilities, large screen, difficulty in moving around, no zapping) is bound to lead to a high level of consumer attention as opposed to, say, listening to television. In addition, movie goers expend some significant effort (choosing a movie, driving to the theatre, finding a parking space, staying in line, finding a seat) and money (transportation, parking, tickets) in order to go to a movie and therefore quite involved during the show. Second, successful movie attract large audiences. A blockbuster movie like Om Shanti Om for instance has been seen by millions of people, and this does not include video purchases and rentals, and eventual television broadcast. Therefore from a strict cost per viewer point of view, a product placement in a movie is a real bargain. Finally product placement represents a natural, non aggressive, non persuasive way of promoting brand or a firm. Hence it may lead to less counter arguing and internal zapping from consumers. Such success stories firmly establish the importance of product placement. The use of feature films as a strategy for introducing new products has grown increasingly sophisticated. Savvy marketers now build elaborate marketing communication plans cross-promoting films and brands. For example, Audi used 2004s Babul, a film by Ravi Chopra, as an integrated element for introducing a new model, the Audi A6. It was judged the most successful promotion of 2004. Subhash Ghai was one of the early filmmakers to do product placement on a real large scale. Bollywood insiders say Ghai recovered production cost from Coke and other products even before the release of films like Yaadein and Taal. In future 40% of a films revenue will accrue from streams like TV, online rights, product placements and digital downloads. Video-on-demand, IPTV and DTH are already fetching handsome returns. Then, of course, there is the overseas market, which is expanding fast. In 2007 alone, at least a dozen Hindi Mainstream films have crossed a US $ 1 million mark in the UK an US. As successful marketing efforts incorporating motion pictures continue to mount, the casual use of brands as props will diminish. While current practice does not require filmmakers to identify brands placed in films, viewers can reasonably assume that prominently featured brands have offered some compensation or other consideration in exchange for the appearance. TYPES OF PRDUCT PLACEMENT In films, product placement can be divided into three broad categories: Implicit Mode: in this the star appears in a situation and is seen openly stating that he is using the product/brand. For example, in the movie Chalte Chalte, Shahrukh Khan is seen asking his worker to fill Castrol in his truck. Imperative Mode: In this the star would ask his friend/co-worker/peer to use the product. For example, in the movie Koi Mil Gaya, Hritik Roshan is seen recommending Bournvita to Priety Zinta and her mother in the film. Co-present Mode: in this, the star appears in some kind of setting with the product or he or she could be seen consuming or using the product. In the movie Diljale, love is the ulterior theme, and Sonali Bendre, the lead actress is shown expressing her love through Archies cards, thus revolving around the social expression feel of the Card makers. BRAND PLACEMENT IS DIFFERENT FROM CELEBRITY ENDORSEMENT The celebrities endorse product and brands with commercial reasons, which normally come in the breaks in television programmes or in cinema halls. The phenomenon of zipping and change in television usage behavior due to surfing during the commercial breaks has reduced effectiveness of television commercials. Similarly commercials of cinema hall are found to be of low involvement as audience takes them as blocks between the reasons of visiting the cinema hall and the time available to them for entertainment. So the brand communication and the entertainment product are viewed differently from the audience of both media. Brand placement provides an opportunity where the involved audience gets exposure to the brands and products during the natural process of narration of movie or television commercial. THE OPPORTUNITY OF BRAND PLACEMENT, CONSUMER INFORMATION PROCESSING AND ISSUE OF BRAND CONGRUITY   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Of late there have been attempts by Indian producers and brand managers to come together and place the brand in a situation where the audience is captive and more prone to show high level of retention. Many consumers and researchers are of the view that this method is excessive commercialization of media and intrusion in life of viewer.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   The viewer does not necessarily go there to see the brands; rather he is going to the cinema hall to escape from the realities of life. Brand managers are using different type of placements to make the brand look obvious at the point of emergence. They are also integrating the brand presence with the plot of the cinema, so that the audience does not feel the brand to be out of context. The brand should also be reflective of the class of user of character in the film. If the plot connection is missing and the brand is not reflective of the characters class of usage, then probably the whole brand placement exercise will be futile. The success of Indian movies is not based on sound fundamentals which is evident from the number of feature films flopping every year. So if the vehicle in which the brand is placed does not have the required viewership, then the tariff charged to bring brand at some point of the story will also go in drain .   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Films are selected as context of research for various reasons as explained below.   Compared to television, movie viewing has higher involvement. While watching a television programme, the viewer can do multifarious work at home setting, which may affect the attention degree span of the audience and hence, reduce the overall effectiveness of the medium for enhancing brand retention. In opposition to this argument, is the movie going behavior where the viewer makes a voluntary choice for viewing (exposure) a specific film (product) at a cost (time, financial, opportunity cost) for the purpose of wholesome entertainment. So he is more receptive to brand communication provided to him in the movie hall while watching the movie of his choice.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   It has been observed from research that brand recall for commercials shown during the television programmes with higher level of TRPs are very poor due to the channel switching behavior. High level of media clutter, similarity of programming across channels, channel switching behavior are the factors responsible to generate sufficient level of research interest in researchers at the practice of brand placement in movies.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Brand placements are used to increase the level of brand knowledge among consumers as in every advertising medium. The uniqueness of the medium is found in the process of exposure and congruity of brand in the story. There is no competitive exposure in the same medium at the same time, unlike television of newspapers. This is significant as it may increase the level of brand knowledge. Brand knowledge is conceptualized as brand node in memory to which a variety of associations are linked. So it is important to identify the properties of the brand node and brand association.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   The factors important for product placement include the level of abstraction and qualitative nature of the brand memory effect and the congruity among brand associations affects the favorability, strength and uniqueness of the brand associations. The factors being: Brand awareness: It is the strength of brand node or trace in the memory as reflected by consumers ability to identify the brand under different conditions. Brand image: It is the set of perceptions, held in the consumers memory, as reflected by brand associations. Are the other informational nodes linked to the brand node in memory and contain the meaning of the brand for the consumers? Brand Attitudes: they are the overall evaluation of the brand by the consumers. They often form the basis of consumers choice. Other variables affecting Brand placement are- Favorability of Brand Associations: Associations differ according to how favorably they are evaluated. The success of a marketing program largely depends on the ability of the marketing program in creating the trust among consumers that the attributes and associations benefits are there in the brand talked about in communications. The Strength of Brand Association: It depends on how the information enters consumers memory (encoding) and how it is retained as part of brand image (storage). Strength is a function of both the amount or quality of processing information received at encoding (how much the person thinks about the information) and the nature or quality of the information at the encoding end (the manner in which the person thinks about the information). Congruence of a Brand: the congruence of the brand with the story of the film and presentation in the film is another measure. Congruence is defined as the extent to which the brand association shares the content and meaning with other brand associations. This explains how easily one existing brand association can be recalled and how additional associations can be linked to the brand node in memory. Brand Leverage: Compares the characteristics of the secondary associations with those of primary brand associations. The secondary associations are derived out of the usage of the brand by the character in the film. Example in the film Taal, the hero uses the bottle of Coke as a symbol of exchange of love and this contextual placement increases the strength of association of the brand. Earlier researches have shown the importance of a strong link between the brand and the film. The stronger the link, the greater is the impact between the brands image and the attitude towards the brand sponsor.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Increase in product placements and institutionalization of the industry indicate that advertisers are using the technique to sway consumers brand attitudes. The type of placements should look natural to the narration, as consumption symbols are often used to enrich the plot, theme and characters of popular culture texts. Some consumers may feel that the use of brand names in popular culture simply reflects the increased commercial content of a culture or the producers efforts to enhance the realism of their film. However, in case where the brand takes a major role in the story of the film as in the movie Friends, or where its presence in the movie might look suspect as in the movie Yaadein, the audience may realize that it was placed there to affect their judgments and they may counter argue them just as they do to the traditional advertising messages. Advertising gurus claim that in-film advertising is a very shaky business and most marketers have a tendency and temptation to go overboard with the result that the film would end up becoming a long advertising commercial. Others say that since marketers always tried to stretch their advertising rupee in order to obtain the maximum bang for their buck with the result that brand suffered. However, most advertising professionals vouch for the fact that films, by virtue of being quite engaging, are one of the cost-effective and effective mediums for advertising. If a consumer watches a particular scene and the advertisement is well embedded into that, it will remain, they say. This can be referred to the fact that the girls beating the boys fighting sequence in Chak De has been referred to as the McDonalds fight scene merely because it takes place in one of the outlets. Again, there is no mention of McDonalds in the entire film as it has been seamlessly embedded. Film content of any kind can be used to build brands. The last one year has been rather active in terms of in-film placements and branding through films. However, the placement of brands such as Ultra Tech poses a big challenge especially considering that there is no obvious benefit in sticking to stereo-types and force-fitting the Brand in films theme or storyline, he said Literature survey in the Indian context was more disheartening despite the fact that brand placement is used more and more in Indian films these days. There are hardly any evidences of work carried out on brand placement in Indian Movies.   The Indian Hindi film industry id the largest in the world in terms of number of movie produced. Yet the success rate of the movies in Indian film industry is very less. If a proper research on brand placement can be done, it can guide the producers, brand managers and academicians to develop and effective brand placement strategy in which the risk of the film making and failure will come down substantially in the Indian market. The producers can charge a price for the brand placement and cover a production cost; the brand managers will find a platform to communicate with the audience about their brands in more effective manner than conventional television advertising. PROMINNENT EXAMPLES OF SUCCESSFUL PRODUCT PLACEMENTS IN SOME MAINSTREAM FILMS (In Recent Times) SOME FAILURES TOO SUCCESSES Bollywood has finally discovered branding. In 2007, according to industry estimates, brand cameos earned around Rs 200 crore, and as a result, even small-and medium-budget movies as well as animated films are hoping to cash in on this new and lucrative revenue stream. Indeed, media analysts and industry watchers expect that figure to climb to Rs 800 crore by 2010. Some of the select successful instances of brand placement in recent times are cited below: Rang De Basanti: Rakyesh Omprakash Mehras Rang De Basanti was probably the most successful Bollywood branding in 2006 with its limited edition RDB Coca-Cola bottle, and cameos of Airtel, LG, Berger and Provogue in the film. Coke, in a first of its kind attempt, launched Coca-Cola bottles branded with the RDB title and Amirs picture and produced a movie trailer that was a montage of shots from the film and Cokes Piyo Sar Uthake campaign. Just the right kind of media partners, the films marketing ensured good and effective publicity and both the brands and the movie generated a lot of mileage from each other. Krrish: Rakesh Roshans Krrish, now a case study of Indian Institute of Management, Indore, prominently featured Singapore Tourism Board, Sony, John Players, Bournvita, Tide, Hero Honda, Boro Plus, Lifebuoy, HP Power, Acron Rangeela, Hansaplast and Lays chips, followed by merchandising of Krrish masks, lunch boxes, water bottles. Its merchandising sold like hot cakes among children. Krrish made 12 crores out of product placement. Don: Farhan Akhtars Don promoted Tag Heuer watches, Motorola, Garnier, Citibank and, of course, Oakley sunglasses as well as Louis Philippe outfits. The placement ensured that the viewer noticed dons phone, his laptop, his watch, hia sunglasses and the brand names were the focus of the camera work. But it was still done in a subtle way and did not come across as being imposed on viewer. Dhoom 2: Sanjay Gandavis Dhoom 2 promoted Coke, Pennzoil, Pepe, Sony, Disney channel, Sugar Free, McDonalds, Speed, and Suzuki Zeus. The movie was quite an opportunity for Coke, for both the brand ambassadors of Coke were starring in the movie together for the first time. The cool couple drinking the always coolest drink, perfect for Coke! The cola company had a special campaign for Dhoom 2 where Hrithik Roshan encouraged youngsters to take a swig and go dhoom. Main Hoon Naa: Farah Khans first movie Main Hoon Naa featured the following brands- Reebok, Cafà © coffee day, Frito Lays, Levis, LML. MHN was an example of optimum utilization of branding in a film. The story of the film revolved around youth hence it gave us the scope of using lifestyle and youth centric brands. The brands that were involved were the ones keeping the modern day college goers in mind, for which using brands is just a way of life. The brands were woven into the screenplay in a manner where it looked like a modern day college going youth was using the product natural yet conspicuous. Baghban: One of the clear cases of effective placement in recent times was BR films family drama Baghban. The movie creatively integrated five brands in it. The brands included were ICICI Bank, Tata Tea, Archies, Ford and Tide. Baghban truly depicted the craft of product placement. And these are not mere stating of the brands featured. These placements result in stupendous impact in consumers as delineated by the sales figures of the featured brands, before and after product placement. After Bournvita featured in Krrish, it reported a increase in sales by 15% and intention to use brand by 9%*. Domios registered greater footfall in its outlets after its placement in Phir Hera Pheri. Garnier recorded a product recall of 46% after it got featured in the movie Chup Chup Ke. Lays got an additional endorsement from Priyanka Chopra after she was shown munching on the snack in Krrish, thus re-establishing Lays as cool snack.   After Reebok featured in key scenes in Viruddh, the brand boasted of having got verbal endorsement of Amitabh Bacchan, and extensive reach through multiple showcasing of the film on multiple vehicles. Tanishq recorded a average minimum revenue of 1.45 crore from its Paheli collection. And as if that was not all, they recorded a increase in purchase intent by 13% and favorability of the brand by 10%!!! That says a lot about the success of brand placements. FAILURES There is always the other side of the coin! Academicians from Universities say that currently, embedded advertising still needs to grow in India. It is like a deranged marriage, the brand most often does not fit into the film the way in which it should. The reason is that most filmmakers still do not think of it as a revenue stream, they say. So apart from the huge successes, there were some bad failures as well. Few of them are: Ta Ra Rum Pum: After you see drivers and cars layered by brands of their sponsors, Ta Ra Rum Pum a film on racing cars would seem like the perfect avenue to showcase such similar branding. After all seeing these brands is what weve come to expect, but corporate honchos didnt seem happy just with being there. So they mustve insisted on special close-ups and zooms for their brands. As a result we get a good dose of Castrol, Goodyear and Chevrolet periodically through this film. Salaam E Ishq: Salaam E Ishq was another product-friendly movie. With such an extensive star cast and lavish set designs the director mustve felt the need for corporations to cover up costs. Of the many placements there was one that stood there screaming for attention. John Abraham and Vidya Balan play a couple in love so on the day of their anniversary John decides to gift his lady love with a diamond set. For those curious about the brand, it was Ira Jewellery and the makers give more than a glimmer to those who wonder. To make things worse, the camera decides to zoom more on the brand than the jewels. Victoria 203:   If youre one of the few people that watched the remake of Victoria 203, youd probably be gripped by the urge to buy diamonds, more specifically Gitanjali Diamonds. Thats because Gitanjali has been constantly mentioned throughout the first half an hour. The makers go to the extent of giving the viewers an unwanted history lesson about the Choksi family that owns the company and their legacy. VirruddhFamily Comes First: In terms of product placements, Viruddh went to the extent of shoving their branded products down audiences throats. What made this blatant promotion unbearable was that Virruddh was made as a serious film about a grieving family and their dead son. Obvious instances were where Sanjay Dutt posed with a can of Elf Oil in his garage and John Abraham praised how great the services of Western Union Brand Placement in the Indian Film Industry Brand Placement in the Indian Film Industry Churning out nearly 1,000 films a year, the Indian film industry is the largest in the world. Now, aided by technological advancements, the industry is set to take a further leap across production, exhibition and marketing. In such a scenario, product placement in mainstream films deserves a renewed focus because as a marketing communication tool, it is fast emerging as the medium with maximum potential to capture and covert audiences to potential consumers. This is especially relevant in a world where traditional media vehicles are increasingly failing to reach the consumers for various reasons.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Brand/product placement is a promotional tactic used by marketers in which a real commercial product is used in fictional media, and the presence of the product is the result of an economic exchange, it is an advertising technique in which the companies pay a fee or provide service in exchange for a prominent display of their product. Product placement occurs in plays, films, television series, music videos, video-games and books. The objective of such brand communication is to expose the audience to a brand, whereby the effect can be maximized in terms of increased awareness and higher recall, so that the customer will buy the brand which has maximum recall; and to satisfy the customer to optimum level.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   This research paper looks at the rationality of brand placement, the possible congruity that can be built in the story, as indicators of success of effective brand placement in films and if so, as variables in bringing desired change in consumers attitude. The paper highlights the basic reasons for placing products and brands in Mainstream Hindi films and the effectiveness of these placements as a tool for enhancing the recall value of brands in long run brands in the films. This paper also gives insight as to how audiences react to product placement, do they think it as an effective alternative media, if it has any impact on them and if they find it ethical.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   The research incorporated case studies of four mainstream Hindi films, selected on basis of their box office fate and the amount of brand placement. These films are then anaysed in terms of effectiveness of the variety of placements in bringing the desired recall and recognition values. The four films selected include Om Shanti Om, Goal, Chak De! India, and Lage Raho Munna Bhai. The research concludes with suggestions regarding areas for future research.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Product placement has come as a blessing in disguise for both, the brand and the filmmaker. Through it, the brand managers get the clutter breaking opportunity to look beyond the 30 sec TV commercial and the filmmaker gets to earn huge revenues by just showing the brand being used by protagonist or let it exist in the background. The deal is just perfect for both of them. But the most important person in the deal is the consumer who is vigilant and smart enough to notice whats served to him and has reservations against in your face placements. Surely he does not want more intrusion in his life. Hence, product placement has arrived and here to stay. But a word of caution is to be always kept in mind, by both the brand and the filmmaker- if as communication purveyors they are looking for better and innovative means of reaching the consumer, the consumer himself is already bombarded with marketing tactics from all over and in the three hours of movie, he would want to forget about all these intrusions, including advertising. Thus overdose of brand placement will only drive away the consumers from the cinema halls, resulting in a flop film and a failed marketing endeavor. INTRODUCTION BACKGROUND The Concept of Product Placement Product Placement in Movies Types of Product Placement Brand Placement is Different from Celebrity Endorsement The Opportunity of Brand placement, Consumer Information processing and Issue of Brand Congruity WHAT IS PRODUCT PLACEMENT? A product placement is the inclusion of a product, package, signage, a brand name or the name of the firm in a movie or in a television programme for increasing memorability of the brand and instant recognition at the point of purchase. Placements can be in form of verbal mentions in dialogue, actual use by character, visual displays such as corporate logo on a vehicle or billboard, brands used as set decorations, or even snatches of actual radio or television commercials. The objective of this communication strategy is to expose audience to a brand, whereby the effect can be maximized in terms of increased brand awareness and higher recall, so that the customer will buy the brand which has the highest recall; and to satisfy the customer to optimal level. Because of proliferation of advertisements and the consequent difficulty in getting commercial messages to reach and influence potential customers, product placement appears as an interesting alternative to traditional marketing communication tools. Basically, there are three ways product placement can occur: It simply happens. Its arranged, and a certain amount of the product serves as compensation. Its arranged, and there is financial compensation. Sometimes product placement just happens. A set dresser, producer, director, or even an actor might come across something he thinks will enhance the project. Usually this has to do with boosting the level of credibility or realism of the story being told. Example can be use of Tata Indigo car in movie Aaja Nachle. The car has been used to as mode of transport for the lead actress both when she arrives from abroad and when she goes back. Interestingly the vehicle is widely used as commercial luxury vehicle in many Indian towns. So use of this car added a touch of realism in the movie. However, when contacted, the representatives of the car company denied being approached about the use of their product. Arranged product placement deals fall into two categories: Trade-off of integration or placement for a supply of product Financial compensation for placement or integration The most common type of deal is a simple exchange of the product for the placement. Example, lets say the production team wants lead actor to display a quirky affinity for a particular type of beverage. This will come across rather strongly over the course of the program which means the chosen product could get a lot of air time. It turns out that someone on the crew knows someone who works for that beverage. The production people approach the beverage company folks with a proposal and a deal is made; in exchange for the airtime, the cast and crew are provided with an ample supply of the beverage at work. Example: the movie Krish where the lead actor drinks a lot of Bournvita. Sometimes, a gift of the product isnt an appropriate form of compensation, so money powers the deal. Imagine that the marketing team at Tag Heuer has heard about this project and feels that, given the star power of the actor playing lead, this project would be a great vehicle for showcasing its product. Someone from Tag Heuer approaches the set dresser with a financially lucrative proposal. Eventually, they come to an agreement and the wristwatch casually appears in several scenes. Before product placement really saw a surge in the mid 1990s, it was pretty much a do it yourself effort. Now there are specific corporate positions and entire agencies that can handle the job. Some larger corporations will dedicate personnel to scout out opportunities for product integration or placement within films, television shows and even games and music. Good example would be Madisons specialized division for in-film branding, MATES. PRODUCT PLACEMENT IN MOVIES Every frame in a movie has an opportunity for branding. With that intent, a number of marketers are now using movies to project the core values of their brands. In-film advertising, in its most effective form, is about a brand being a part of cinemas content. Many global brands are now turning to this medium for the sheer impact that a movie can make on its audiences. Product placement in movies has gained momentum all over the world. The practice of using branded products in Hollywood movies started as casual process since 1940s. The earliest example would be 1945 movie Mildred Pierce with film star Joan Crawford drinking Jack Daniels bourbon whiskey. The current Hollywood movies feature a plethora of products ranging from telecommunications (Motorola, Nokia), automobile (Audi, BMW, Chrysler, Jeep, Lada and Mercedes) to other products like FMCG goods, Tobacco etc. Good examples are James Bond movies. Indian mainstream Hindi films, popularly known as Bollywood the world over, caught up with the trend in 1970s with Rajkapoor using Rajdoot in his movie Bobby. Popularity of movies as medium for product placement grew because of the increasing difficulty of using television as an effective medium to target audiences. The film medium provides an excellent message reach and message life and an effective method of popularizing and immortalizing brands. One of the key drivers for movies becoming a popular medium for product placement has been the increasing difficulty of using television as an effective medium to target audiences. The advent of cable and satellite television has meant that audiences have become more fragmented and tend to demonstrate a greater level of ad avoidance. By contrast, the film medium provides an excellent message reach and message life and an effective method of popularizing and immortalizing brands. The movie-goers vicariously experience the brand as they make a connection between the film, the actor, the product and its consumption, and argue that product placement acts as a perceptual clue which directs behavior to purchase a product to satisfy a need or reinforce a social status. Movie product placement is viewed as a cheaper and more effective alternative to traditional marketing communications, despite its inflexibility, but as a result of the establishment of specialist placement agencies, and thro ugh increased brand exposure through cable, satellite, video and DVD, a typical movie with international distribution can reach over one hundred million consumers from box office to TV. There seem to be three reasons why marketers consider product placement in movies as interesting communication strategy. First watching a movie is high attention and involving activity. The particular exposure context associated with movies in theatres (lights off, minimal noise and distraction possibilities, large screen, difficulty in moving around, no zapping) is bound to lead to a high level of consumer attention as opposed to, say, listening to television. In addition, movie goers expend some significant effort (choosing a movie, driving to the theatre, finding a parking space, staying in line, finding a seat) and money (transportation, parking, tickets) in order to go to a movie and therefore quite involved during the show. Second, successful movie attract large audiences. A blockbuster movie like Om Shanti Om for instance has been seen by millions of people, and this does not include video purchases and rentals, and eventual television broadcast. Therefore from a strict cost per viewer point of view, a product placement in a movie is a real bargain. Finally product placement represents a natural, non aggressive, non persuasive way of promoting brand or a firm. Hence it may lead to less counter arguing and internal zapping from consumers. Such success stories firmly establish the importance of product placement. The use of feature films as a strategy for introducing new products has grown increasingly sophisticated. Savvy marketers now build elaborate marketing communication plans cross-promoting films and brands. For example, Audi used 2004s Babul, a film by Ravi Chopra, as an integrated element for introducing a new model, the Audi A6. It was judged the most successful promotion of 2004. Subhash Ghai was one of the early filmmakers to do product placement on a real large scale. Bollywood insiders say Ghai recovered production cost from Coke and other products even before the release of films like Yaadein and Taal. In future 40% of a films revenue will accrue from streams like TV, online rights, product placements and digital downloads. Video-on-demand, IPTV and DTH are already fetching handsome returns. Then, of course, there is the overseas market, which is expanding fast. In 2007 alone, at least a dozen Hindi Mainstream films have crossed a US $ 1 million mark in the UK an US. As successful marketing efforts incorporating motion pictures continue to mount, the casual use of brands as props will diminish. While current practice does not require filmmakers to identify brands placed in films, viewers can reasonably assume that prominently featured brands have offered some compensation or other consideration in exchange for the appearance. TYPES OF PRDUCT PLACEMENT In films, product placement can be divided into three broad categories: Implicit Mode: in this the star appears in a situation and is seen openly stating that he is using the product/brand. For example, in the movie Chalte Chalte, Shahrukh Khan is seen asking his worker to fill Castrol in his truck. Imperative Mode: In this the star would ask his friend/co-worker/peer to use the product. For example, in the movie Koi Mil Gaya, Hritik Roshan is seen recommending Bournvita to Priety Zinta and her mother in the film. Co-present Mode: in this, the star appears in some kind of setting with the product or he or she could be seen consuming or using the product. In the movie Diljale, love is the ulterior theme, and Sonali Bendre, the lead actress is shown expressing her love through Archies cards, thus revolving around the social expression feel of the Card makers. BRAND PLACEMENT IS DIFFERENT FROM CELEBRITY ENDORSEMENT The celebrities endorse product and brands with commercial reasons, which normally come in the breaks in television programmes or in cinema halls. The phenomenon of zipping and change in television usage behavior due to surfing during the commercial breaks has reduced effectiveness of television commercials. Similarly commercials of cinema hall are found to be of low involvement as audience takes them as blocks between the reasons of visiting the cinema hall and the time available to them for entertainment. So the brand communication and the entertainment product are viewed differently from the audience of both media. Brand placement provides an opportunity where the involved audience gets exposure to the brands and products during the natural process of narration of movie or television commercial. THE OPPORTUNITY OF BRAND PLACEMENT, CONSUMER INFORMATION PROCESSING AND ISSUE OF BRAND CONGRUITY   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Of late there have been attempts by Indian producers and brand managers to come together and place the brand in a situation where the audience is captive and more prone to show high level of retention. Many consumers and researchers are of the view that this method is excessive commercialization of media and intrusion in life of viewer.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   The viewer does not necessarily go there to see the brands; rather he is going to the cinema hall to escape from the realities of life. Brand managers are using different type of placements to make the brand look obvious at the point of emergence. They are also integrating the brand presence with the plot of the cinema, so that the audience does not feel the brand to be out of context. The brand should also be reflective of the class of user of character in the film. If the plot connection is missing and the brand is not reflective of the characters class of usage, then probably the whole brand placement exercise will be futile. The success of Indian movies is not based on sound fundamentals which is evident from the number of feature films flopping every year. So if the vehicle in which the brand is placed does not have the required viewership, then the tariff charged to bring brand at some point of the story will also go in drain .   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Films are selected as context of research for various reasons as explained below.   Compared to television, movie viewing has higher involvement. While watching a television programme, the viewer can do multifarious work at home setting, which may affect the attention degree span of the audience and hence, reduce the overall effectiveness of the medium for enhancing brand retention. In opposition to this argument, is the movie going behavior where the viewer makes a voluntary choice for viewing (exposure) a specific film (product) at a cost (time, financial, opportunity cost) for the purpose of wholesome entertainment. So he is more receptive to brand communication provided to him in the movie hall while watching the movie of his choice.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   It has been observed from research that brand recall for commercials shown during the television programmes with higher level of TRPs are very poor due to the channel switching behavior. High level of media clutter, similarity of programming across channels, channel switching behavior are the factors responsible to generate sufficient level of research interest in researchers at the practice of brand placement in movies.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Brand placements are used to increase the level of brand knowledge among consumers as in every advertising medium. The uniqueness of the medium is found in the process of exposure and congruity of brand in the story. There is no competitive exposure in the same medium at the same time, unlike television of newspapers. This is significant as it may increase the level of brand knowledge. Brand knowledge is conceptualized as brand node in memory to which a variety of associations are linked. So it is important to identify the properties of the brand node and brand association.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   The factors important for product placement include the level of abstraction and qualitative nature of the brand memory effect and the congruity among brand associations affects the favorability, strength and uniqueness of the brand associations. The factors being: Brand awareness: It is the strength of brand node or trace in the memory as reflected by consumers ability to identify the brand under different conditions. Brand image: It is the set of perceptions, held in the consumers memory, as reflected by brand associations. Are the other informational nodes linked to the brand node in memory and contain the meaning of the brand for the consumers? Brand Attitudes: they are the overall evaluation of the brand by the consumers. They often form the basis of consumers choice. Other variables affecting Brand placement are- Favorability of Brand Associations: Associations differ according to how favorably they are evaluated. The success of a marketing program largely depends on the ability of the marketing program in creating the trust among consumers that the attributes and associations benefits are there in the brand talked about in communications. The Strength of Brand Association: It depends on how the information enters consumers memory (encoding) and how it is retained as part of brand image (storage). Strength is a function of both the amount or quality of processing information received at encoding (how much the person thinks about the information) and the nature or quality of the information at the encoding end (the manner in which the person thinks about the information). Congruence of a Brand: the congruence of the brand with the story of the film and presentation in the film is another measure. Congruence is defined as the extent to which the brand association shares the content and meaning with other brand associations. This explains how easily one existing brand association can be recalled and how additional associations can be linked to the brand node in memory. Brand Leverage: Compares the characteristics of the secondary associations with those of primary brand associations. The secondary associations are derived out of the usage of the brand by the character in the film. Example in the film Taal, the hero uses the bottle of Coke as a symbol of exchange of love and this contextual placement increases the strength of association of the brand. Earlier researches have shown the importance of a strong link between the brand and the film. The stronger the link, the greater is the impact between the brands image and the attitude towards the brand sponsor.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Increase in product placements and institutionalization of the industry indicate that advertisers are using the technique to sway consumers brand attitudes. The type of placements should look natural to the narration, as consumption symbols are often used to enrich the plot, theme and characters of popular culture texts. Some consumers may feel that the use of brand names in popular culture simply reflects the increased commercial content of a culture or the producers efforts to enhance the realism of their film. However, in case where the brand takes a major role in the story of the film as in the movie Friends, or where its presence in the movie might look suspect as in the movie Yaadein, the audience may realize that it was placed there to affect their judgments and they may counter argue them just as they do to the traditional advertising messages. Advertising gurus claim that in-film advertising is a very shaky business and most marketers have a tendency and temptation to go overboard with the result that the film would end up becoming a long advertising commercial. Others say that since marketers always tried to stretch their advertising rupee in order to obtain the maximum bang for their buck with the result that brand suffered. However, most advertising professionals vouch for the fact that films, by virtue of being quite engaging, are one of the cost-effective and effective mediums for advertising. If a consumer watches a particular scene and the advertisement is well embedded into that, it will remain, they say. This can be referred to the fact that the girls beating the boys fighting sequence in Chak De has been referred to as the McDonalds fight scene merely because it takes place in one of the outlets. Again, there is no mention of McDonalds in the entire film as it has been seamlessly embedded. Film content of any kind can be used to build brands. The last one year has been rather active in terms of in-film placements and branding through films. However, the placement of brands such as Ultra Tech poses a big challenge especially considering that there is no obvious benefit in sticking to stereo-types and force-fitting the Brand in films theme or storyline, he said Literature survey in the Indian context was more disheartening despite the fact that brand placement is used more and more in Indian films these days. There are hardly any evidences of work carried out on brand placement in Indian Movies.   The Indian Hindi film industry id the largest in the world in terms of number of movie produced. Yet the success rate of the movies in Indian film industry is very less. If a proper research on brand placement can be done, it can guide the producers, brand managers and academicians to develop and effective brand placement strategy in which the risk of the film making and failure will come down substantially in the Indian market. The producers can charge a price for the brand placement and cover a production cost; the brand managers will find a platform to communicate with the audience about their brands in more effective manner than conventional television advertising. PROMINNENT EXAMPLES OF SUCCESSFUL PRODUCT PLACEMENTS IN SOME MAINSTREAM FILMS (In Recent Times) SOME FAILURES TOO SUCCESSES Bollywood has finally discovered branding. In 2007, according to industry estimates, brand cameos earned around Rs 200 crore, and as a result, even small-and medium-budget movies as well as animated films are hoping to cash in on this new and lucrative revenue stream. Indeed, media analysts and industry watchers expect that figure to climb to Rs 800 crore by 2010. Some of the select successful instances of brand placement in recent times are cited below: Rang De Basanti: Rakyesh Omprakash Mehras Rang De Basanti was probably the most successful Bollywood branding in 2006 with its limited edition RDB Coca-Cola bottle, and cameos of Airtel, LG, Berger and Provogue in the film. Coke, in a first of its kind attempt, launched Coca-Cola bottles branded with the RDB title and Amirs picture and produced a movie trailer that was a montage of shots from the film and Cokes Piyo Sar Uthake campaign. Just the right kind of media partners, the films marketing ensured good and effective publicity and both the brands and the movie generated a lot of mileage from each other. Krrish: Rakesh Roshans Krrish, now a case study of Indian Institute of Management, Indore, prominently featured Singapore Tourism Board, Sony, John Players, Bournvita, Tide, Hero Honda, Boro Plus, Lifebuoy, HP Power, Acron Rangeela, Hansaplast and Lays chips, followed by merchandising of Krrish masks, lunch boxes, water bottles. Its merchandising sold like hot cakes among children. Krrish made 12 crores out of product placement. Don: Farhan Akhtars Don promoted Tag Heuer watches, Motorola, Garnier, Citibank and, of course, Oakley sunglasses as well as Louis Philippe outfits. The placement ensured that the viewer noticed dons phone, his laptop, his watch, hia sunglasses and the brand names were the focus of the camera work. But it was still done in a subtle way and did not come across as being imposed on viewer. Dhoom 2: Sanjay Gandavis Dhoom 2 promoted Coke, Pennzoil, Pepe, Sony, Disney channel, Sugar Free, McDonalds, Speed, and Suzuki Zeus. The movie was quite an opportunity for Coke, for both the brand ambassadors of Coke were starring in the movie together for the first time. The cool couple drinking the always coolest drink, perfect for Coke! The cola company had a special campaign for Dhoom 2 where Hrithik Roshan encouraged youngsters to take a swig and go dhoom. Main Hoon Naa: Farah Khans first movie Main Hoon Naa featured the following brands- Reebok, Cafà © coffee day, Frito Lays, Levis, LML. MHN was an example of optimum utilization of branding in a film. The story of the film revolved around youth hence it gave us the scope of using lifestyle and youth centric brands. The brands that were involved were the ones keeping the modern day college goers in mind, for which using brands is just a way of life. The brands were woven into the screenplay in a manner where it looked like a modern day college going youth was using the product natural yet conspicuous. Baghban: One of the clear cases of effective placement in recent times was BR films family drama Baghban. The movie creatively integrated five brands in it. The brands included were ICICI Bank, Tata Tea, Archies, Ford and Tide. Baghban truly depicted the craft of product placement. And these are not mere stating of the brands featured. These placements result in stupendous impact in consumers as delineated by the sales figures of the featured brands, before and after product placement. After Bournvita featured in Krrish, it reported a increase in sales by 15% and intention to use brand by 9%*. Domios registered greater footfall in its outlets after its placement in Phir Hera Pheri. Garnier recorded a product recall of 46% after it got featured in the movie Chup Chup Ke. Lays got an additional endorsement from Priyanka Chopra after she was shown munching on the snack in Krrish, thus re-establishing Lays as cool snack.   After Reebok featured in key scenes in Viruddh, the brand boasted of having got verbal endorsement of Amitabh Bacchan, and extensive reach through multiple showcasing of the film on multiple vehicles. Tanishq recorded a average minimum revenue of 1.45 crore from its Paheli collection. And as if that was not all, they recorded a increase in purchase intent by 13% and favorability of the brand by 10%!!! That says a lot about the success of brand placements. FAILURES There is always the other side of the coin! Academicians from Universities say that currently, embedded advertising still needs to grow in India. It is like a deranged marriage, the brand most often does not fit into the film the way in which it should. The reason is that most filmmakers still do not think of it as a revenue stream, they say. So apart from the huge successes, there were some bad failures as well. Few of them are: Ta Ra Rum Pum: After you see drivers and cars layered by brands of their sponsors, Ta Ra Rum Pum a film on racing cars would seem like the perfect avenue to showcase such similar branding. After all seeing these brands is what weve come to expect, but corporate honchos didnt seem happy just with being there. So they mustve insisted on special close-ups and zooms for their brands. As a result we get a good dose of Castrol, Goodyear and Chevrolet periodically through this film. Salaam E Ishq: Salaam E Ishq was another product-friendly movie. With such an extensive star cast and lavish set designs the director mustve felt the need for corporations to cover up costs. Of the many placements there was one that stood there screaming for attention. John Abraham and Vidya Balan play a couple in love so on the day of their anniversary John decides to gift his lady love with a diamond set. For those curious about the brand, it was Ira Jewellery and the makers give more than a glimmer to those who wonder. To make things worse, the camera decides to zoom more on the brand than the jewels. Victoria 203:   If youre one of the few people that watched the remake of Victoria 203, youd probably be gripped by the urge to buy diamonds, more specifically Gitanjali Diamonds. Thats because Gitanjali has been constantly mentioned throughout the first half an hour. The makers go to the extent of giving the viewers an unwanted history lesson about the Choksi family that owns the company and their legacy. VirruddhFamily Comes First: In terms of product placements, Viruddh went to the extent of shoving their branded products down audiences throats. What made this blatant promotion unbearable was that Virruddh was made as a serious film about a grieving family and their dead son. Obvious instances were where Sanjay Dutt posed with a can of Elf Oil in his garage and John Abraham praised how great the services of Western Union

Steel drums :: essays research papers

The recording I listened to is called Carnival Favorites. It is Caribbean steel drum music. It is the majority of what people listen to and play in the Caribbean. It can be related to the genre of music known as techno. Usually a basic beat is repeated while a featured instrument such as steel drums plays a melody or song. Caribbean bands are mostly comprised of a drum set player, steel drum player, and a guitar and bass player. Other bands will add in other instruments such as a keyboard, bongos, or African drums. It is played so that people will be entertained, is played to keep people’s spirits high. Steel drum music is also about dancing. Any song that is played you will most likely be able to dance to it. The music makes you want to get into groove. Unless a band is playing a cover song, the band might not have a singer. Steel drum bands, in particularly, use the steel drums to â€Å"sing† to the audience. Steel drum players are fascinating to watch because of how difficult it is to play, and players can play every note perfect in the steel pan with ease.   Ã‚  Ã‚  Ã‚  Ã‚  It differs from any American music because there are usually not any words, and is different from techno because the steel drum is used as a voice instead of a sound machine. Most music that I listen to is based on the guitar and the vocalists. Being a drummer makes me focus more on the drum parts, which is why I like steel drum bands because they are percussion featured. The steel drums, and other percussion instruments are the main attractions. The tempos of what I listen to, and Caribbean music, differ greatly. The genre of music I listen to can be up to twice as fast as Caribbean music. Caribbean music is at a mild tempo so it is relaxing and so nobody is over worked, either dancing or playing. Most steel drum players could not play at a fast speed.

Breach of Employment Contract Essay

The case involves a claim that Baril, the appellant, was dismissed by Aiken Regional Medical Centers, the Hospital where she previously worked, and such dismissal constitutes a breach of the employment contract between Baril and the Hospital. The contract the parties were referring to was the â€Å"Associate Handbook† she received from the Hospital, which contained the personnel polices of the Hospital that governed her employment. Baril was terminated for making a call through the Hospital’s toll-free number, as a result of which he was deemed to have committed a violation of the Hospital’s rules and policies, which merited her immediate termination. Baril argues that the Hospital itself breached the employment contract by unjustly terminating her employment. The Court of Appeals of South Carolina began its discussion by stating that the general rule on employment contracts is that contracts of employment are â€Å"at-will† contracts. This means that the contract is terminable at the pleasure of either party, at any time, regardless of the existence or non-existence of a justifiable ground for the termination. However, the existence of an employee handbook is recognized as an exemption to the general rule. Such a handbook may create an employment contract, depending on the terms stated therein. Where the handbook contains ambiguous clauses such as disclaimers, the issue of whether it could constitute an employment contract has to be determined by a jury, and not by summary judgment. The court noted that while the handbook explicitly states that it does not change the nature of the employment contract as an at-will contract, it does provide strict procedures to be followed in disciplinary cases such as the one where Baril is concerned. Thus, the Hospital’s procedures and practices give rise to more than one reasonable inference concerning the creation of an employment contract. Concomitantly, we find the trial court erred in granting summary judgment on the issue of whether Hospital’s policies found in its employee handbook, amendments, and actual practices created an employment contract between Baril and Hospital. The court also determined that the employment contract established by the Hospital’s practices and procedures requires that there be an existing just cause for termination. The criterion for determining justness in the termination of Baril’s employment rests on the existence of a â€Å"reasonable good faith belief that sufficient cause existed for termination. † Weighing the arguments of both Baril and the Hospital, the court concluded that reasonable minds could differ as to the whether there was good or bad faith in the Hospital’s termination of Baril’s employment. Therefore, the case could not have been settled using the rules on summary judgment. Attached: Case: http://www. sccourts. org/opinions/HTMLfiles/COA/3561. htm THE STATE OF SOUTH CAROLINA In The Court of Appeals Marolyn L. Baril, Appellant, v. Aiken Regional Medical Centers, Respondent. Appeal From Aiken County Rodney A. Peeples, Circuit Court Judge Opinion No. 3561 Heard October 8, 2002 – Filed October 28, 2002 REVERSED and REMANDED Herbert W. Louthian, Sr. , and Deborah R. J. Shupe, both of Columbia, for Appellant. Richard J. Morgan and Reginald W. Belcher, both of Columbia, for Respondent. ANDERSON, J. : Marolyn L. Baril appeals the Circuit Court’s order granting summary judgment to Aiken Regional Medical Centers (Hospital) on Baril’s action for breach of employment contract. We reverse and remand. FACTS/PROCEDURAL BACKGROUND Baril joined Hospital’s nursing staff in 1986. She earned a master’s degree in nursing administration from the University of South Carolina in 1990. The following year, Baril was named director of Hospital’s emergency department. Baril resigned from that position for personal reasons in 1992, but continued as a staff nurse in the emergency department. Holly Martinez de Andino eventually succeeded Baril as director of Hospital’s emergency department. John Arnold [1] and Martinez de Andino indirectly supervised Baril. In early 1993, Baril began teaching nursing classes on a part-time basis at the University of South Carolina’s Aiken campus (USC-Aiken). She joined the faculty on a full-time basis later that year. Baril received an â€Å"Associate Handbook† from Hospital in May of 1997. She signed an acknowledgment form provided by Hospital, indicating she would familiarize herself with the handbook and that she understood the handbook â€Å"constitute[d] the personnel policies of [Hospital] and that [she was] governed by them. † The handbook and acknowledgment form contained disclaimer language: Please Read! Important Employment Information The information contained in this booklet is designed to serve only as a reference to Aiken Regional Medical Centers policies and procedures. Aiken Regional Medical Centers reserves the right to amend this guide as necessary at any time, with or without prior notice. Current hospital policies and procedures will apply in all cases. Please remember that this booklet does not constitute a contract between you and Aiken Regional Medical Centers. Employment at Aiken Regional Medical Centers is on a voluntary basis and either you or the Facility may terminate this employment relationship at any time with or without reason or prior notice. No associate of Aiken Regional Medical Centers has the right to make verbal promises or commitments which may create a contract and thereby alter the â€Å"employment at will† relationship. (Emphasis added). Additionally, the handbook’s â€Å"Recruiting and Hiring† section included similar language: In no event shall a hiring of an associate be considered as creating a contractual [re]lationship between the associate and the Facility; and, unless otherwise provided in writing, such relationship shall be defined as â€Å"employment at will,† where either party may dissolve the relationship. (Emphasis added). However, the acknowledgment form states that â€Å"the information in [the] handbook is subject to change/revision† and â€Å"any change will be communicated through the usual channels. † The handbook incorporated a detailed, progressive disciplinary procedure. Two categories of offenses were specifically identified. The categories were bifurcated: (1) actions meriting immediate termination; and (2) actions warranting termination for continuous violations. In July of 1998, Martinez de Andino disciplined Baril for allegedly slamming a door in Arnold’s face and disagreeing with Hospital’s management regarding a management issue. [2] Baril was first suspended and later given a â€Å"final† written warning. Yet, the handbook’s procedure mandated use of a â€Å"final† written warning only after two previous warnings. Baril had not previously been warned or disciplined. Baril asked Hospital to change her work status from full-time to part-time in November 1998. She continued to teach full-time at USC-Aiken. Baril initiated a grievance pursuant to Hospital policy. Hospital’s chief executive officer, Richard H. Satcher, investigated Baril’s complaint and found sufficient cause to purge the disciplinary action from Baril’s employment file. As a condition to purging her employment file, Satcher required Baril and Martinez de Andino to meet with Hospital’s director of human resources, Richard Lowe, and director of nursing, Mary Ann Angle. The purpose of the meeting was to â€Å"clarify understandings and expectations† regarding Baril and Martinez de Andino’s working relationship. In January of 1999, Baril met with Martinez de Andino, Lowe, and Angle to discuss problems between Baril and Martinez de Andino. During the meeting, Baril expressed concern that Martinez de Andino had targeted Baril for termination which Martinez de Andino intended to accomplish using the disciplinary procedure. Lowe responded that Hospital had updated pertinent portions of its employee handbook to prevent the disciplinary procedure from being abused to eliminate employees and to ensure that it would only be used to positively impact its employees. Lowe delivered a copy of the new policy to Baril. Regarding its purpose, the policy stated: To set standard operating procedures in order to ensure that all associates are fully aware of the conduct expected of them. This policy will also ensure fair and consistent treatment to associates if violations of these standards of conduct occur. This policy is based on the concept of increased severity in disciplining associates who repeatedly violate hospital rules while performing work for the hospital or while on hospital premises. Written counselings are given for initial, minor infractions of rules; if the infractions continue harsher discipline is enforced. However, situations which are so serious that they require immediate stern disciplinary action will not follow a progressive concept. [Hospital] reserves the right to administer disciplinary action as it deems appropriate for the circumstances involved. (Emphasis added). The new policy provided: â€Å"Discipline is an instrument for changing unacceptable performance or behavior, and for providing motivation and encouragement for disciplined associates. † The new policy described four general categories of disciplinary offenses, ranging in degree of seriousness from greatest (critical offenses) to least (minor offenses). The category of â€Å"critical offenses† included actions that constituted â€Å"serious violations of rules or associate misconduct which justify immediate termination without regard to the associate’s length of service or prior conduct. † The new policy contained various examples of critical offenses. It specified in section 2. 2. 2 of HR116 that actions of â€Å"[d]ishonesty, fraud, theft (regardless of the amount), [or] unauthorized removal of hospital property† were examples of critical offenses. At the end of the meeting, Baril and Martinez de Andino signed a document identifying â€Å"expectations† concerning Baril’s and Hospital’s obligations to each other. The details of the document consisted of expectations related to performance and communications. On July 6, 1999, Baril suffered injuries when a cabinet fell on her while at work. She immediately sought treatment for injuries involving muscle strain, subperiosteal hematoma, and an impinged nerve. Baril filed an accident report and claim for Workers’ Compensation benefits at the time of the accident. Four days after her accident, on July 10, 1999, Baril traveled to Tacoma, Washington, for a vacation. When Baril arrived, she received a telephone message indicating Hospital called her sister in an effort to contact Baril. In response, Baril called Hospital on its toll-free number and asked to speak to someone in her department. After a brief conversation with a coworker, Baril asked the coworker to transfer her call to her sister’s home in Aiken. Baril informed her sister that she had arrived in Washington safely, and asked why Hospital wanted to talk to her. Baril’s sister offered to call Hospital to ask why it had contacted her to try to reach Baril. However, Baril declined her sister’s offer. According to telephone company records, the call lasted thirty-two seconds. No evidence exists in the record concerning the cost of the call or whether Hospital sustained any economic loss as a result of the call. Baril returned from vacation on July 17, 1999. When she reported to work the following day, Baril was told to meet with Arnold and Martinez de Andino. At the meeting, Baril learned that by using Hospital’s toll-free number for personal use, she violated section 2. 2. 2 of Hospital Policy HR116, which cites â€Å"[d]ishonesty, fraud, theft (regardless of amount), unauthorized removal of hospital property,† as â€Å"critical offenses† justifying immediate termination. Baril offered to pay for the telephone call, but Arnold refused to accept payment and informed her she was being terminated. Baril exited the premises a short time thereafter. Baril filed this cause of action averring (1) Hospital created a contract of employment between Baril and itself through its written employee handbook, its amendments to the handbook, and its conduct regarding the handbook’s policies, particularly the mandatory language of the disciplinary procedure in HR116 and verbal assurances provided by Lowe during the January 1999 meeting; (2) Hospital breached the contract between Baril and itself by wrongfully terminating her; and (3) Hospital violated S. C. Code Ann.  § 41-1-80 (Supp. 2001) by terminating Baril in retaliation for filing a Workers’ Compensation claim. Baril sought $403,508 in actual damages, plus costs and other just and proper relief. Hospital answered, generally denying Baril’s allegations and claiming it â€Å"acted in good faith† when dealing with Baril’s discipline and termination. Hospital specifically asserted that Baril was an at-will employee throughout her employment with Hospital, and denied the existence of an employment contract. Hospital further claimed that, even if any employment contract existed, Hospital never breached it and that Baril’s discharge was not wrongful. Hospital cited Baril’s own conduct as the source of â€Å"any and all of the employment actions that [Hospital] took against [Baril]. † Additionally, Hospital maintained that Baril â€Å"failed to meet [Hospital’s] established work standards, stole [Hospital’s] time and possibly money when making an impermissible telephone call, and violated at least one of [Hospital’s] specific written Company policies for which [Hospital’s] action was a stated remedy of the violation. † Finally, Hospital contended Baril failed to mitigate any damages she might have sustained. Hospital moved for summary judgment, arguing no material issues of fact existed and Hospital was entitled to judgment as a matter of law. The Circuit Court conducted a hearing on the motion and issued an order finding: (1) Hospital’s policies did not constitute an implied employment contract as a matter of law, even when viewed in the light most favorable to Baril; (2) even if Hospital’s policies constituted an implied employment contract, Hospital’s actions did not breach the contract because it acted pursuant to the express terms of the alleged contract and because Baril’s interpretation of the alleged contract was â€Å"strained and unreasonable and would have led to absurd consequences†; (3) Hospital did not breach any alleged contract because on the date Hospital terminated Baril it had a â€Å"reasonable, good faith belief that, pursuant to the language of HR 116, it had sufficient and just cause to terminate [Baril’s] employment†; (4) Baril failed to establish a retaliation claim because she â€Å"based this cause of action merely upon her own self-serving, unsup ported opinions and the temporal proximity between the filing of her workers’ compensation claim and her termination of employment†; and (5) Baril failed to mitigate her damages because she â€Å"did nothing to seek employment or mitigate damages in any way. † The Circuit Court dismissed all of Baril’s claims with prejudice. STANDARD OF REVIEW When reviewing the grant of a summary judgment motion, the appellate court applies the same standard which governs the trial court under Rule 56(c), SCRCP: summary judgment is proper when there is no genuine issue as to any material fact and the moving party is entitled to judgment as a matter of law. Fleming v. Rose, 350 S. C. 488, 567 S. E. 2d 857 (2002); Ferguson v. Charleston Lincoln Mercury, Inc. , 349 S. C. 558, 564 S. E. 2d 94 (2002). In determining whether any triable issue of fact exists, the evidence and all inferences which can reasonably be drawn therefrom must be viewed in the light most favorable to the nonmoving party. Faile v. South Carolina Dep’t of Juvenile Justice, 350 S. C. 315, 566 S. E. 2d 536 (2002); McNair v. Rainsford, 330 S. C. 332, 499 S. E. 2d 488 (Ct. App. 1998). If triable issues exist, those issues must go to the jury. Young v. South Carolina Dep’t of Corrections, 333 S. C. 714, 511 S. E. 2d 413 (Ct. App. 1999). Summary judgment is not appropriate where further inquiry into the facts of the case is desirable to clarify the application of the law. Vermeer Carolina’s, Inc. v. Wood/Chuck Chipper Corp. , 336 S. C. 53, 518 S. E. 2d 301 (Ct. App. 1999). All ambiguities, conclusions, and inferences arising from the evidence must be construed most strongly against the moving party. Bayle v. South Carolina Dep’t of Transp. , 344 S. C. 115, 542 S. E. 2d 736 (Ct. App. 2001). Even when there is no dispute as to evidentiary facts, but only as to the conclusions or inferences to be drawn from them, summary judgment should be denied. Hall v. Fedor, 349 S. C. 169, 561 S. E. 2d 654 (Ct. App. 2002). Moreover, summary judgment is a drastic remedy which should be cautiously invoked so no person will be improperly deprived of a trial of the disputed factual issues. Lanham v. Blue Cross and Blue Shield, 349 S. C. 356, 563 S. E. 2d 331 (2002); Trivelas v. South Carolina Dep’t of Transp. , 348 S. C. 125, 558 S. E. 2d 271 (Ct. App. 2001). ISSUES I. Did the Circuit Court err in granting summary judgment on the issue of whether Hospital’s written policies and actual practices created an employment contract between the parties? II. Did the Circuit Court err in granting summary judgment on the issue of whether Hospital’s actions in terminating Baril’s employment breached a contract between the parties? III. Did the Circuit Court err in granting summary judgment on the issue of whether Baril acted reasonably in attempting to mitigate her damages? LAW/ANALYSIS I. Existence of Employment Contract Baril maintains the Circuit Court erred in granting summary judgment because, viewing the evidence in the light most favorable to Baril as the nonmoving party, material issues of fact exist concerning whether Hospital’s written policies and actual practices created an employment contract between Baril and Hospital. We agree. South Carolina recognizes the doctrine of employment at-will. Prescott v. Farmers Tel. Coop. , Inc. , 335 S. C. 330, 516 S. E. 2d 923 (1999). This doctrine provides that a contract for permanent employment is terminable at the pleasure of either party when unsupported by any consideration other than the employer’s duty to provide compensation in exchange for the employee’s duty to perform a service or obligation. Id. â€Å"At-will employment is generally terminable by either party at any time, for any reason or no reason at all. † Prescott, 335 S. C. at 334, 516 S. E. 2d at 925. However, an employer and employee may contractually alter the general rule of employment at-will, thereby restricting the freedom of either party to terminate the employment relationship without incurring liability. See Small v. Springs Indus. , Inc. , 292 S. C. 481, 357 S. E. 2d 452 (1987). For example, an employee handbook may create a contract altering an at-will arrangement. Id. Because an employee handbook may create an employment contract, the question of whether a contract exists is for a jury when its existence is questioned and the evidence is either conflicting or admits of more than one inference. Conner v. City of Forest Acres, 348 S. C. 454, 560 S. E. 2d 606 (2002) (stating summary judgment is inappropriate in most instances when handbook contains both a disclaimer and promises). The presence of promissory language and a disclaimer in the handbook make it ambiguous and subject to more than one interpretation. [3] See Fleming v. Borden, 316 S. C. 452, 450 S. E. 2d 589 (1994) (stating that a handbook containing both a disclaimer and promissory language should be viewed as inherently ambiguous). Here, the handbook states that it does not operate to change the at-will nature of employment to a contractual relationship. However, the handbook’s procedures concerning progressive discipline, discharge, and grievance are couched in mandatory terms, including assurances that the procedures will be followed. As to Lowe’s statements regarding the new disciplinary policy, Baril testified: Richard Lowe told me, guaranteed me that the new disciplinary policy was put into effect for exactly that reason because I told Richard, I said, you know, I have been a manager, and you can use a disciplinary procedure to try to eliminate people or try to help people grow and have positive behaviors and goals and grow. And Richard Lowe said that is what that policy is for, is to help you, and that is what is going to be happening from this point forward, and I felt that that was a guarantee, was a contract, a verbal contract that I would be treated equitably, that I would be—that I would not be targeted any further, that the grievance was over, and we were to go forward. And so I felt at that time that that was a contract that was made . . . . Thus, the court concluded that the procedures and practices established by the Hospital was more than sufficient for it to arrive at the conclusion that an employment contract was created between the parties. II. Hospital’s Actions in Terminating Baril’s Employment Baril claims the Circuit Court erred in granting summary judgment because, viewing the evidence in the light most favorable to Baril as the nonmoving party, material issues of fact exist regarding whether Hospital’s actions in terminating her employment breached an employment contract between Hospital and Baril. We agree. When an employment contract only permits termination for cause, the appropriate test on the issue of breach focuses on whether the employer had a â€Å"reasonable good faith belief that sufficient cause existed for termination. † Conner v. City of Forest Acres, 348 S. C. 454, 464, 560 S. E. 2d 606, 611 (2002) (emphasis added). â€Å"[T]he fact finder must not focus on whether the employee actually committed misconduct; instead, the focus must be on whether the employer reasonably determined it had cause to terminate. † Id. at 464-65, 560 S. E. 2d at 611. a. Reasonable Good Faith In the January 1999 meeting, Baril expressed concern that Martinez de Andino disliked her and would use Hospital’s disciplinary process to terminate her. Lowe responded that Hospital had updated pertinent portions of its employee handbook to prevent the disciplinary procedure from being abused to eliminate employees and to ensure that it would only be used to positively impact its employees. Nevertheless, reasonable minds could disagree as to whether Hospital proceeded to act in reasonable good faith by using the disciplinary policy to immediately terminate Baril for using the toll-free line to transfer one possibly business-related telephone call to Baril’s sister for thirty-two seconds. Additionally, our Supreme Court has held that summary judgment should not ordinarily be used to resolve the question of whether an employer acted under a reasonable good faith belief that sufficient cause existed for termination. Conner, 348 S. C. at 465, 560 S. E. 2d at 611-612. Viewing the evidence in the light most favorable to Baril, we find that reasonable minds could differ as to whether Hospital acted with good faith in terminating Baril. b. Sufficient Cause Hospital alleges it followed its disciplinary policies in terminating Baril. Hospital contends Baril’s request that her call on Hospital’s toll-free line be transferred to her sister’s private residence constituted an act of â€Å"dishonesty, fraud, theft (regardless of amount), unauthorized removal of hospital property. † Thus, Hospital avers Baril demonstrated violation of a â€Å"critical offense† meriting immediate termination. However, Hospital never announced a policy against use of its toll-free telephone line by employees for personal or private business, although the written materials of Hospital purported to communicate policies and changes to Hospital employees. Furthermore, Baril declared that other Hospital employees had engaged in similar behavior without Hospital’s objection, thereby raising the possibility that Hospital tacitly condoned the practice. Assuming, arguendo, that Hospital rightfully concluded such employee use of its toll-free telephone lines for private purposes constituted dishonesty, fraud, or theft sufficient to merit immediate termination under its policy, evidence exists that Baril’s telephone call to her sister originated in matters related to her employment at Hospital. Moreover, Hospital failed to produce any evidence that it suffered a loss related to the telephone call. In addition, Hospital rejected Baril’s good-faith efforts to compensate Hospital for any loss it may have sustained for the thirty-two second call, although Hospital’s undisputed practice was to permit employees to reimburse it for private long-distance telephone calls. The Circuit Court determined â€Å"no evidence showed or even suggested that [Baril] ever reimbursed or attempted to reimburse Hospital for any of these calls. † A cursory reading of the record contradicts this finding. First, the phrase â€Å"any of these calls† wrongly implies that Baril made more than one call, contrary to undisputed evidence that she only made one call at issue. Next, the record is replete with testimony from Baril and Lowe that Baril immediately offered to reimburse Hospital for any expenses related to the telephone call. Hospital maintains Baril abused her authority by ordering a subordinate to transfer the telephone call outside the Hospital. Yet, the record contains no evidence that Baril had any subordinates at the Hospital at the time she placed the call. In fact, the employee whom Baril asked to transfer the call was only considered a subordinate by the trial court because she had previously been one of Baril’s nursing students. Viewing the evidence in the light most favorable to Baril, we conclude her actions constituted a mere peccadillo at worst and that reasonable minds could differ concerning whether Hospital terminated Baril with just cause. III. Mitigation of Damages Baril claims the Circuit Court erred in granting summary judgment because, viewing the evidence in the light most favorable to Baril as the nonmoving party, material issues of fact exist concerning whether she made reasonable efforts to mitigate her damages. We agree. A party injured by the acts of another is required to do those things a person of ordinary prudence would do under the circumstances, but the law does not require him to exert himself unreasonably or incur substantial expense to avoid damages. McClary v. Massey Ferguson, Inc. , 291 S. C. 506, 354 S. E. 2d 405 (Ct. App. 1987). Whether the party acted reasonably to mitigate damages is ordinarily a question for the jury. Id. Baril did not seek other employment throughout this litigation. However, she attempted to justify her behavior. First, she testified she did not want to reveal to potential employers that she had been fired. Second, she testified that there were no other hospitals with emergency rooms in or near Aiken, where she resided. Thus, she would have been forced to either commute or relocate in order to perform similar work. Baril did not want to relocate because she had a home and family in Aiken, where she taught college classes on a full-time basis. Baril speculated that a lengthy commute would interfere with her teaching career. Considering the evidence in the light most favorable to Baril, reasonable minds could disagree over whether she made reasonable efforts to mitigate her damages. The trial court should have allowed this question to be resolved by a jury. CONCLUSION Accordingly, the trial court’s decision is REVERSED and REMANDED. CONNOR and STILWELL, JJ. , concur. [1] John Arnold’s specific job title is unclear in the record, which indicates he operated in a supervisory capacity similar to that of Martinez de Andino. [2] Shortly before Martinez de Andino initiated the July 1998 disciplinary action against Baril, a dispute arose between them concerning Martinez de Andino’s decision to hire paramedics to perform nursing functions in the emergency room. Baril learned from the South Carolina Department of Health and Environmental Control that South Carolina law prohibited paramedics from performing some of the functions that Martinez de Andino intended for them to perform. Baril conveyed this information to Martinez de Andino, who told Baril to â€Å"deal with it. † Baril contends Martinez de Andino resented Baril’s input, leading to a souring of their relationship that motivated her to seek Baril’s termination. [3] Baril and Hospital clearly disagree about the existence of a contract.