The Best (and Worst) Online AP Courses, Reviewed

The Best (and Worst) Online AP Courses, Reviewed SAT / ACT Prep Online Guides and Tips There are hundreds, if not thousands, of online AP courses. So how are you supposed to find the best one for you? To help you sort through your options, I’ll quickly go over what makes a good online AP course. Then I’ll discuss the best-reviewed online AP courses, some popular online AP class providers, and wrap up with some classes that you should avoid. 7 FactorsThat Make a Good Online AP Course If you're searchingfor the best online AP courses, these are the qualities you should look for. #1: It's Accredited There’s no reason why you can’t self-study for an exam with non-accredited online resources- but if you are going to take an entire AP course online, it makes the most sense to take one that is accredited by the College Board. This means that they have looked over the syllabus and course requirements and approved it, and that it can be listed as an AP course if your high school agrees to list the online course on your transcript. #2: The Material Is Presented Well You want the material to be interesting, engaging, and presented clearly. The coursework may not be your first choice of activity, but if you’re bored out of your mind, you won’t want to study, and if you’re confused, you will be frustrated. #3: Teachers Are Accessible and Give Good Feedback Teachers should be easy to reach and give useful, timely feedback. If you are waiting for them to return assignments from months ago when you take the AP, that’s not particularly helpful. #4: The Workload Is Reasonable Many AP courses are demanding, which is to be expected. But you want to make sure that you have a good sense of how many hours per week you have available to spend on online coursework and how many hours a week the class will take. #5: There's an Easy-To-Use Interface and Tech Support A good course will be easy to navigate on your computer. You should also have easy access to tech support resources should something go wrong. #6: The Class Preps You for the AP Exam If you can get any information on how students tend to score on the exam after taking the course, that will be very useful in making a decision on a course. #7: It's Well-Reviewed A good online AP course is one other students have had good experiences in! Check forum sites like College Confidential for reviews of a given course. With those seven criteria in mind, we’re ready for a more in-depth look at some of the best-reviewed online AP courses out there! You can master the universe...of online AP courses! 8 GreatOnline AP Courses Below I’ve compiled a list of someof the bestonline AP courses. Ideally I would be able to provide an option for every AP, but unfortunately, some APs have very few online options (if any). That is why, as you may notice, there are some popular AP courses like Calculus and English Language that do not appear on the list below. AP US History AP US History From the UC System’s Scout Program Students like the material, the pace, and the focus on AP exam prep. Multimedia lessons are praised for being engaging, and assessments and assignments are full of variety, which keeps things interesting. Students appreciate the consistent pace of the assignments. A special bonus is that the end of the course involves an AP workshop with study strategies, practice AP exams, etc. This is also one of the cheaper online AP course providers, and it’s discounted for CA students. AP Art History AP Art History From the Florida Virtual School Students appreciate that the course spends so much time on non-European art. The interactive gallery format is engaging and helps you retain the material. Finally, the class content is not overly difficult, but students still feel prepared for the AP exam. AP Human Geography AP Human Geography From the Florida Virtual School Students recommend this class, finding it interesting without being frustrating. They also praise the teaching staff and like that teachers are accessible by text, e-mail, and phone. AP Psychology AP Psychology From the Florida Virtual School This course is interesting and fairly easy. Some assignments are fun, and the online textbook has helpful interactive video components and simulations. Overall, this course is straightforward and will prepare you well for the exam. With that said, students advise that some of the course material does require boring rote memorization. AP Biology AP Bio From Johns Hopkins CTY Students felt that this course overprepared them for the AP Bio exam, but in a good way. They also appreciated that the two lowest grades on tests were dropped, so you could dive into difficult material without fear that some struggling along the road would completely tank your grade. AP Biology From Apex Learning This class hasa combination virtual/in-person lab component,which ishelpful given that many online courses do not have labs at all. Students do mention that this course is reading-heavy. AP Chemistry AP Chemistry From ChemAdvantage The main selling point of this class is that students get mailed a small lab kit and do at-home labs; lab components are often missing from online science courses. The course is taught and managed by a husband and wife team. Students receive lots of instructor attention and feel that instructors are flexible when necessary. The course is demanding, as AP Chemistry usually is, but students feel well-prepared for the exam. Unfortunately, this class is primarily offered to homeschoolers, but their FAQ says that they may be able to accommodate students whose schools simply don’t offer AP Chem. AP Computer Science A AP CS A From the Florida Virtual School This is one of the most highly-praised online courses out there. According to students, the FLVS course imparts a strong coding foundation, good habits, and conceptual understanding. Students find that they easily retain the material for months and feel very prepared for the exam. They warn that you may spend 10 hours a week or more writing programs, but that you will enjoy yourself and it is time well-spent. There you have it- a selection of some of the most popular online AP classes available. Still at a loss? Keep reading for a brief list of three of the most well-regarded online AP providers. We briefly interrupt this broadcast to bring you this mesmerizing jellyfish. 3High-Quality Online AP Course Providers In addition to some specific courses being like by students, there are also some online providers that are particularly well-regarded.It’s still a good idea to look for reviews and making sure a course has what you are looking for before you sign up, but these are some online schools that have a reputation for high-quality coursework. Pennsylvania Homeschoolers For homeschooled students in any state, PA Homeschoolers AP Courses are well-reviewed, with excellent teachers being the number one benefit. AP History and English classes are particularly well-liked, and they appear to have the only online AP Environmental Science course that is praised and not widely disliked. However, you must be a homeschooled student to register. Florida Virtual School Though there are a couple courses that aren’t highly reviewed (see below), most students found AP offerings from FLVS to be comprehensive, cost-effective, worthwhile, and adequate preparation for the AP exam. They also have a wide variety of AP courses available. It's one of the cheaper online providers, has no admissions requirements, and is free in Florida! Johns Hopkins Center for Talented Youth Johns Hopkins CTYis an online course provider for gifted students. To take courses, students need to get qualifying courses on the PSAT. In general, students found AP courses from this provider to be thorough and enjoyable. The material used is said to be top-notch. This is an expensive provider, though there is some financial aid available. Allow me to steer you away from AP online danger! 3BadOnline AP Classes Of course, not every online AP course is a great experience. There are some classes that are known throughout the world of high school distance learning as particularly terrible, and I’ll discuss why here. AP US History From Apex Learning There were two chief complaints here: logistical and technical issues with the course, and poor preparation for the AP. Students found that they lost points on quizzes due to technical errors when they had selected the correct answer. They were annoyed by all of the faxing they had to do, and that their faxed documents frequently got lost. Even more disconcertingly, students did not feel prepared to get 4-5 level scores on the exam, but only a 2-3. They found they learned more from prep books than the course! If you’re having better luck studying on your own, there’s no point in taking the class. AP Environmental Science From the Florida Virtual School This is probably the most widely disliked online course I saw. Students were frustrated by the workload, assessments, and lack of teacher accessibility. They found that lessons focused on information that was not relevant to the AP exam. They pointed to a high workload of busywork with low exam preparation payoff. Assessments were brutally long. Teachers took a long time to get back to students. The general consensus was that no one should take this course. AP Government From the Florida Virtual School This course, again, was disliked for its poor preparation value for the exam. Students found that assessments were frequently based on minor, unimportant details instead of major concepts. Even diligent students who carefully read the lessons and took notes felt that assessments were unfairly specific and did little to prepare them for the actual AP exam. As you can see, there are several running themes in what makes a course disliked: there are technical problems with the way the course is run, the material is presented in a way that is boring or overly specific, students do not feel prepared for the exam, and teaching staff is inaccessible or not helpful. If you see any of these issues cited in student reviews on College Confidential or elsewhere, these are major red flags. Keep this in mind to avoid any bad eggs! These eggs are good, so you don't need to avoid them. Choosing the Right Online AP Course: Final Thoughts There are high-quality AP online classes available out there, with excellent teaching, good exam prep, and engaging material. There are also less amazing online offerings, with frustrating technological meltdowns, vanishing instructors, and long assessments. I’ve listed some highly-praised options and some that aren't as well-liked, but this is by no means a comprehensive accounting of every course available. I’m sure you’ve noticed that some APs are easier to find online than others, and some have more options than others. This means a few well-known APs (World History, English Language) are conspicuously absent from this list of the best online AP courses. Keep in mind what’s available when you are planning your online AP coursework, and do research carefully! A smart investment in an online AP course can have a great payoff. What's Next? If you're not quite sure if online AP courses are for you, check out my pros and cons to online AP classes. Once you've selected your course of choice, you may need help registering for the AP exam. Want more information about the AP program before you decide? See our expert guide to AP classes and tests. Want to improve your SAT score by 160points or your ACT score by 4 points?We've written a guide for each test about the top 5 strategies you must be using to have a shot at improving your score. Download it for free now:

COLLEGE PAPER WRITING SERVICE for Students

COLLEGE PAPER WRITING SERVICE for Students Good written paper is no doubt a writing masterpiece. But if you ask yourself, what makes the academic essay so good? The answer to this question will be simple but the good essay writing does require much abilities and skills and college paper writing service is ready to help. Here are a few simple steps for you to follow while writing your perfect college paper. First is to study you the presented sources carefully. In addition to that make sure to sort well the reference sources. Second, communicate on paper your ideas and thoughts the most effective way you know. Third, generate the most impressive content you can come up with, aim to the unique piece of writing in the first place. Fourth is to put the facts into the logical and most sequential order while aiming to provide the continuous information flow. Fifth is to concentrate on using the simple language that speaks directly to the reader. And sixth is to apply your own personal writing style to show your understanding of the subject and to answer the central questions of the given essay.

Advanced Research Methods Dissertation Example | Topics and Well Written Essays - 2750 words

Advanced Research Methods - Dissertation Example Companies are expanding operations in other nations and the increasing incidence of mergers, acquisitions and joint ventures have increased the challenges before organizations in terms of managing a diversified and cross cultural work force. For example, an American company shifting its manufacturing and marketing facilities in China will have to integrate organizational HR practices in keeping with the lifestyle and culture of the local population. Such situations can result in cross cultural conflicts that can adversely impact organizational culture and productivity. It is very difficult for American executives to adapt to Chinese culture and systems of working. Such circumstances create responsibility for the HR department to ensure that cross cultural relationships within the organization are cordial and positive so that the company functions smoothly. This proposal is about a quantitative research that will be carried out in the area of human resource management in an organizati on that is shifting its manufacturing facilities from the US to China in order to benefit from the accruing economies of scale, low costs of production and cheap availability of raw material. The proposal will outline the research strategy on how to deal effectively with the emerging issues of training a culturally diversified workforce. Introduction The study will address some major issues in terms of the extent to which a cross cultural training strategy can work positively in improving the company’s performance in China. In order to achieve this objective, exhaustive research will have to be carried out on how expatriates and local employees have to be dealt with. Initially the company will have to ask Americans or nationals from other countries to work in China because key positions in the company cannot be performed by Chinese nationals. The research will ascertain the merits and demerits if cross-cultural training modules and also ascertain the approaches that will work best in the given environment. Another objective will be to develop theories of efficient cross-cultural modules for global human resource personnel. HRM is widely acknowledged as a management resource that imbibes the maximum possible management actions and decisions that impact relationships amongst the organization and workers (Beer et al, 1986). It is the process that coordinates the organization’s human resources in meeting organizational objectives. Therefore, the job of HR professionals becomes quite complicated because all aspects of the firm and workers have to be encompassed. It is believed that the most significant asset of the organization is its people that assist in achieving its goals, and this comprises the core of the HRM philosophy. Human resources are the most important asset and are the major force that drives human resource management in any organization. Human resource personnel have to take care of areas such as professional development, compensation, benefits, performance evaluation, recruitment, health and safety, job design, job analysis, labor relations and management of a diverse work force (Lipiec, 2002). According to Schermerhorn (2002), there is global inter-dependence in the global economy in terms of resources and markets whereby every business thrives because of competition. Internationalization has led businesses to act and think globally in order to succeed in a competitive environment. Some theorists have viewed globalization as providing massive growth potential for both developed and developing

Managing People and Organisations Case Study Example | Topics and Well Written Essays - 3250 words

Managing People and Organisations - Case Study Example PEST analysis shows that ALSTOM political situation was feeble in 1999 and continued to remain till 2003 until they change their HRM policies to unite the new and old employees. Among the major concerns were lack of funds, updated technology and unskilled labour which they overcome in 2005 by revising their policies and considering social factors on a cultural basis which gained customers' trust and trained their unskilled managers and employees so that they could move with the 'new' labour department. ALSTOM currently should consider economic conditions to be updated on a weekly basis as this would provide the managers with the latest updates to take financial decisions regarding investment and budgeting control. ALSTOM should also sought new ways to lower its' costs and increase its plant's efficiency. ALSTOM unintentionally became dual service business which consisted of a two-fold unit, the existing sector and the newly formed sector. This was the main reason why the industry started engaging in various conflicts. The service sector that was considered 'useless' in ALSTOM was promoted on 'managerial' post while the 'production' unit that consisted of the people who were considered as the real pioneers of the Industry, were merged with the newly formed staff. Any proposal suggested by the new comers and qualified staff was immediately opposed by the existing sector. ... This was the main reason why the industry started engaging in various conflicts. The service sector that was considered 'useless' in ALSTOM was promoted on 'managerial' post while the 'production' unit that consisted of the people who were considered as the real pioneers of the Industry, were merged with the newly formed staff. Any proposal suggested by the new comers and qualified staff was immediately opposed by the existing sector. The conflicts were not limited to the people alone, managers were also involved. Industrial unity began to fragile in the face of multiple pressures; some of them were even brutal which gave rise to the political involvement of managers which widened the potential scope of internal conflict and therefore threatened the basic industrial unity. As a result there started a cold war in two sectors which resisted unity simply as a means of self-protection. (Minkin, 1991, p. 8) The emergence of Uncertainty The existence of 'uncertainty' tended to further reinforce the sense of there being a political sphere distinct from the industrial world which is evident from the development of two distinct centres, the OEM and the newly emerged sector the one growing out of the other seemed to imply the acceptance of two orders and two sets of functions. All of this enhanced the possibility of political and employees' union role-playing in a way that accounts for much of the subtlety and flexibility of the organisational relationship. Walter's management was aware of the fact that ALSTOM was lacking experienced employees; therefore with the formation of OEM, ALSTOM hired capable employees. Inflexibility The more united the organisation, the better is its' structure in terms of flexibility. Walter perceived the two

The Battle :: essays research papers

The Battle   Ã‚  Ã‚  Ã‚  Ã‚  The sun was touching the tree tops as it slowly descended in the horizon. Shadows were cast on the ground. The air was still hot and humid from the midday. A bit of a breeze was beginning to blow from the east sending a slight chill through our spines. We stepped unto the grounds and surveyed our surroundings. The playing field was perfect just like we had all imagined it would be. In the far distance there was woods along with a wide shallow stream. In front there was a field scattered with shields and barricades. We divided into units and went to gather up our gear. With our equipment in hand the whistle blows and friends become foes. Our mission was to survive, be the last team standing, we were to annihilate our opponents. With the signal given the war was under way.   Ã‚  Ã‚  Ã‚  Ã‚  My teammates and I gathered together at our base. There we came up with a battle plan. We were to separate and head in different directions eventually meeting up at an undisclosed location where we would ambush the enemy’s base . After everyone was clear on the objective we split up and went out to battle.   Ã‚  Ã‚  Ã‚  Ã‚  I ran across the field to the nearest shield and collected my thoughts. I could hear the orders being shouted from my fellow comrades in the distance as they engaged in a brawl with the enemy, â€Å"duck, cover, fire, fire†. Soon the brawl ended with a small victory as they scattered out into the sunset. My heart was pounding in my stomach. The sounds of the earth were magnified in my ears. Then it came to me, this was a war, this was life or death. Shoot or be shot, the setting had changed. With the new thoughts in mind I held tightly onto my gun gathered all my strength and courage and charged into battle.   Ã‚  Ã‚  Ã‚  Ã‚  I made my way slowly and quietly into the deep woods, like a recon soldier. My mind and senses were focused on the enemy. As I made my way down the beaten path I spotted movement in a far bush. I dropped to the ground and pushed my body flat against the cold earth. After a few seconds of silence I knew that I had not been seen. I crawled around the bush so I could see my pray. She sat there so still she blended in with the green color of the leaves.

Constitutional Law of the European Union Essay

The European Court of Justice is the driving force behind European integration. The ECJ had elaborately defined the doctrines of supremacy and direct effect of the EC Law and provided remedies for damages caused by breach of EC Law by a Member State . Despite the initiatives of the ECJ, there have been conflicts between Community law and national law. Moreover, the ECJ made it clear that the EC law had supremacy over national law in the event of conflict as evidenced in the case of Costa v ENEL, wherein it held that a preliminary ruling by the Italian courts based on their national law would be of no significance. In Simmenthal, the ECJ clarified that the Community law was to take precedence over national law and that any provision of the national law that contravened the Community Law would be rescinded by it. Moreover, the ECJ prohibited the implementation of any national law that was in conflict with the Community law. The ECJ further ruled that no fundamental provision of any national law could challenge the supremacy of a directly applicable Community rule . This supremacy of Community law is one of the constitutive principles of the integration of the European Community legal order and it has been well embedded in the Treaty that established a Constitution for the European Union. The doctrine of supremacy of Community law, the principles of direct effect and uniform applicability are the primary ingredients of the Community. They are fundamental to the promotion of an effective Community legal order and form the unseen pillars of the European Constitution. Further, the doctrine of supremacy is the actual concrete personification of this constitutional power . The national constitutional courts of Member States found it very difficult to adopt the doctrine of supremacy and in the initial stages the Italian and German constitutional courts almost refused to adopt this doctrine into their respective national legislations, because they felt that they would be surrendering their power of constitutional review of secondary community law. Subsequently, the enlargement of the European Union provided a new paradigm to this doctrine of supremacy. This doctrine of supremacy was enforced by the ECJ in Costa v ENEL . This doctrine is a jurisprudential creation of the ECJ. Further, the Court clarified that the EEC Treaty had adopted a new legal system, which the Member States had integrated into their national legislation. Accordingly, the national courts were required to apply the Community law without any deviation and this generated a number of debates in the Member States. Ultimately, it was accepted by the Member States. However, total supremacy over the national constitutional provisions has not been achieved . In Frontini the Italian Constitutional Court had opined that the 1957 Act, which had accepted the provisions of the EEC Treaty, did not breach the Constitution. Moreover, the Italian court reserved to itself the right to review the continuing compatibility of the Treaty with the Constitution . In another case the Italian Constitutional Court, while accepting the precedence of Community law, maintained that the court had competence over any aspect of the relationship between Community law and municipal law . These decisions clearly established that the national constitutional courts had not completely accepted the supremacy of Community law. The German Constitutional Courts voiced their concern over the protection of fundamental rights in the decisions given in Solange I and II and introduced the concept of Kompetenz – Kompetenze. Even in the Banana case the German constitutional Court declined to give up its power to review secondary community legislation in order to protect fundamental rights . In the United Kingdom this doctrine created several problems, because the UK constitution bestows absolute power on Parliament. Further, the UK ratified a dualist policy concerning the relationship between international treaties and national law. Although such treaties were signed by the UK, they were not incorporated into the domestic law of the UK. In order to incorporate the treaties into national laws, the Parliament had to ratify them and this resulted in a problem in respect of accepting the doctrine of supremacy of Community law over national law. In the famous Factortame case the concept of the supremacy of Community law was subjected to a vast amount of discussion. In that case Spanish fishermen had argued that the norms for registering vessels under the Merchant Shipping Act 1988 were discriminatory and in conflict with the provisions of the EC Treaty. The House of Lords refused to grant any interim injunction against the Crown. The applicants in this case claimed that this would violate the Community law and the result was that a reference was made to the ECJ, which ruled in favour of these applicants. The ECJ further held that any piece of legislation in the national law that prevented a court from issuing interim relief would be tantamount to the violation of the Community law . The EOC case dealt with the suitability of the UK statute regarding unfair dismissal and redundancy pay in the broader context of the EC law . The UK law provided different benefits to employees working in full –time and part – time jobs. The appellant in the case, the Equal Opportunities Commission, opined that the statute was discriminating against female employees, which was in contravention of Article 141 of the EC Treaty and to other Community directives. The House of Lords held that the national legislation had violated the EC law and upheld the contention of the EOC. The approach of the European Court of Justice is at variance with the customary doctrine of precedent that is entrenched in domestic law. The objective of the ECJ is to bring about a European Union that follows the same law throughout its Member States and to this end it constantly endeavours to promote the EC Treaty. This could result in a change in the interpretation of legal principle over a period of time. Moreover, the ECJ bases its decisions on the extant circumstances and not on precedent. National courts of Member States in the European Union can obtain a preliminary ruling regarding the interpretation of European Union Law from the ECJ on the basis of the provisions inherent in Article 234 of the EC Treaty. However, it is not the primary objective of the ECJ to take decisions regarding the compatibility between the domestic and European laws. Further, it is also not the primary aim of the ECJ to apply the European Union Law to some specific facts of a case . The ECJ indicates the principle to be applied in a particular case and the case will have to be decided in the originating court, however, the ECJ ruling will have to be implemented by such a court. In the absence of an appeal from a national court, a reference will have to be made by the originating court, in case it is of the opinion that a clarification in respect of European Union Law is required. Nevertheless, there are instances where an ET, EAT or Appellate Court has to make a reference to the ECJ in order to pronounce judgement that is in accordance with the EU law. The function of the advocates general is to aid the judges in their judicial work. They do this by submitting analyses and recommendations regarding the issues raised in a particular case . In addition to the rights conferred on the nationals of the EU Member States by their respective national constitutions, the EU law comprises of another source that grants rights to them. As such the European Union law constitutes a legal system that in addition to being independent also, perhaps more importantly, takes precedence over the national laws of the Member States of the European Union. This European Union law comprises of treaties, which constitute primary legislation and regulations and directives that constitute secondary legislation. The importance of regulations is that they directly require compliance from the Member States without having to be codified into the national laws. However, in respect of the Directives, which are also legally binding, the onus of implementing them rests squarely with the Member States and these Member States have to do so by resorting to the relevant national law legislation on or before the final date set by the EU for such implementation. Accordingly, Article 189 of the European Economic Treaty states that â€Å"A Directive shall be binding, as to the result to be achieved, upon each Member State to which it is addressed, but shall leave to the national authorities the choice of form and methods. † The European Court of Justice, subsequent to taking cognizance of the fact that Directives have to be implemented by the Member States, declared that individuals were well within their rights to ensure the implementation of Directives even in the event of failure by the Member States to meet the deadline set by the EU. In addition, individuals were permitted to enforce such rights in the national courts. The Van Gend en Loos decision unequivocally established the fact that in addition to creating obligations for the Member States to implement the Directives it also creates rights for the individual citizens of these Member States . The right of the Member States and the European Commission to proceed against other Member States before the European Court of Justice does not prohibit the lodging of complaints by individuals against the Member State to which they belong in their national courts. In this context, the European Court of Justice ruled that Article 12 of the EEC results in direct effect, which in turn result in the creation of rights for individuals and that these rights had to perforce protected by the national courts. Consequently, individuals have been empowered to ensure that rights granted by the Directives are enforced in the national courts . The offshoot of this is that individuals can ensure the implementation of human rights by resorting to legal action. In the Becker case it was clarified that if there is unconditionality and adequate precision in the provisions of a Directive that bestows individual rights, then individuals can resort to such provisions to contest the relevant national law . Furthermore, in the Francovich case the European Court of Justice established a test in three parts, which was to be utilized in order to ascertain whether the provisions that were inherent in a Directive, were sufficiently precise and unconditional in creating a right that was applicable to individuals. The ECJ has to consider the identity of the persons who are supported by the guarantee and the content of the guarantee. The identity of the person in breach and who is liable to pay the guarantee has also to be ascertained. Private persons and institutes cannot be subjected to the provisions of the Directives, because it is only the state that is subject to the Directives. The decision in the case of Francovich served to establish that damages could be claimed by an individual in a national court, in the event of a Member State’s failure to implement a Directive properly. The ECJ clarified that the spirit of the European law and the protection of rights would become ineffective if an individual failed to secure compensation. Moreover, the States are required to implement Directives wholly and properly. The ECJ decided in Brasserie du Pecheur v. Germany that there must be a sufficiently serious breach by the State in order to determine its liability. This dictum applies to situations where national legislation is implemented improperly and inconsistently with a Directive. In order to determine whether Community law was breached with sufficient seriousness, it is sufficient to demonstrate that the Member State or Community institution had seriously and knowingly ignored the limits to its discretionary power. Some of the factors that the court has to consider are the exactitude and clarity of the rule that was breached, the amount of discretion allowed to the national or Community authorities, whether the damage caused was intentional or not and whether there had been any adoption or rejection of measures that were in violation of the Community law . Member States for whom the Directives are specifically issued should be bound by them. Sometimes Directives can be addressed to one Member State or a group of them, but in general Directives are addressed to all the Member States. The exception to this practice is in respect of Directives that pertain to Common Agricultural Policy. The European Commission initiates a binding legal action in situations where a Member State fails to incorporate the provisions of a Directive into their national legislation or if the national legislation fails to properly fulfill the requirements of the Directive. Previously, the Directives were not adequately binding upon the Member States in their implementation. To address this problem, the ECJ promoted the doctrine of direct effect. Thus even if a Member States fails implement the Directives there is legal initiation under the principle of direct effect. This was clearly established in the case of Francovich v Italy. In that case, the ECJ attributed liability to Italy for its failure to implement a Directive. The Easytalk was a private limited company that had been formed with help from the UK government. It was established in order to encourage students in the EU to come to the UK in order to learn English. This company advertised all over the EU universities by means of pamphlets, in which it was stated that the course instructors would be highly qualified scholars in English with a great deal of teaching experience. A Directive was issued by the EU that prohibited the issuance of advertisements that misled and imparted false information. This Directive was to be implemented by January 2007. However, the UK government failed to implement this Directive by this deadline and in effect this Directive had been ignored by the UK government, because the latter was of the opinion that this Directive was unlawful. Subsequently, a French student, Antoine came to the UK and registered for a course that taught English. However, once the classes commenced, Antoine realized that the faculty comprised of students who were not qualified teachers of English as a foreign language. On being approached, the institute where he had enrolled refused to refund the fees paid by him. The direct effect of directives has been restrained by the concepts of vertical and horizontal effect. Van Duyn and Ratti affirmed that directives only have vertical effect so that an individual who is affected by the states’ failure to implement a directive properly or not at all only has rights against the state and not against a non-state entity or other individuals, as the directive imposes the obligation of implementation upon the state. Therefore a horizontal limitation was placed upon the scope of the direct effect of directives. This principle was addressed in Marshall v Southampton and South West Hampshire Health Authority , in which the applicant who was employed by the Health authority, was required to retire at the age of sixty – two years, while men doing the same work did not have to retire until the age of sixty – five years. Although under national law, by virtue of the Sex Discrimination Act, this was not discriminatory, she succeeded in her claim for unfair dismissal by relying on the Equal Treatment directive, which had not been implemented in the UK. This directive was sufficiently clear to have direct effect but the courts took the opportunity to confirm that a directive may not of itself impose obligations on an individual and that a provision may not be relied upon as such against such a person. Therefore since the health authority was an organ of the state, the directive had vertical direct effect. Since the respondent in this problem is a private limited company, the claimant cannot approach the Commission under the vertical direct effect. However, he can seek justice under the EU law by resorting to the procedure of indirect effect. Since, the UK government had not implemented the Directive; the claimant can approach the national courts of the UK to compel the government to apply the Directive. In respect of damages, the ECJ further held in R v H. M. Treasury, ex parte British Telecommunications plc that parties who had sustained loss as a result of incorrect implementation of a directive by a state, could claim damages for the loss sustained on such an account. In contrast to this, if a state has failed to fulfill its obligations regarding Directives, whether by non-implementation or incorrect implementation, an individual cannot request invocation of the horizontal direct effect of a directive against another individual. Similarly the effectiveness of non-implemented or incorrectly-implemented directives that do not have direct effect through the horizontal limitation has been enhanced through the doctrine of indirect effect, which emerged from Von Colson . In this case the ECJ held that national courts are required to interpret their national law in light of the wording and the purpose of the directive so that the directive is given some effect despite the absence of proper domestic implementation. This principle may be used under two circumstances; first, where the defendant is a state entity but a directive is not vertically directly effective as its provisions are insufficiently precise, conditional and require further state action for their implementation. Second, the provisions of a directive could be indirectly enforced against a non-state entity i. e. it could be applied horizontally as between individuals. The court was confronted with a ‘horizontal’ situation in Marleasing , in which this position was confirmed. Therefore, if national law was in existence that could be read in conformity with a non-implemented directive, then an individual could enforce a legal remedy against another individual through the interpretative route without seeking to enforce the directive directly and encountering the barrier to horizontal effect. In respect of the Easytalk institute the claimant can file a case for breach of contract and false representation in the UK courts in order to obtain redressal for the loss, damage and frustration caused to him. The question arises as to whether the aggrieved individuals can claim damages against the state in the national courts. The ECJ clarified that the state had to pay compensation for the damages caused due to non – implementation of a Directive and that the conditions laid down for such claim of damages must not be less reasonable than what was specified for a domestic claim. Furthermore, the Member State should not unduly complicate the claim process.

The Parapet and Battlement - Using Castle Architecture