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Who Has "Possession, Custody, Or Control" Of The Employee's Personal Mobile Device? Time For Amendments To The Federal Rules, Xavier Rodriguez Jun 2026

Who Has "Possession, Custody, Or Control" Of The Employee's Personal Mobile Device? Time For Amendments To The Federal Rules, Xavier Rodriguez

Journal of Technology Law & Policy

As mobile devices have become indispensable tools for professional communication, the distinction between personal and business data has blurred—creating critical challenges for litigators and organizations navigating discovery obligations. This Article explores the evolving jurisprudence surrounding whether and when a corporate defendant has “possession, custody, or control” over data stored on an employee’s personal mobile device. Drawing from a recorded podcast conversation and expanding on the legal foundations, I scrutinize the two primary frameworks courts use to analyze control—the “legal right” test and the “practical ability” test—and question their fitness in the context of modern mobile usage patterns.

This Article evaluates …


Exploring Early Career Public General Education K–6 Teachers’ Experiences With Their Training For Teaching Special Education Students In Inclusive Classrooms, Alexandra E. Ray Jun 2026

Exploring Early Career Public General Education K–6 Teachers’ Experiences With Their Training For Teaching Special Education Students In Inclusive Classrooms, Alexandra E. Ray

Doctor of Education Program Dissertations

Although Canada is often regarded as a leader in inclusive education, reports note that many students’ needs remain unmet and inclusion is typically implemented by placing students in mainstream classrooms with individualized accommodations. This qualitative phenomenological study explored the lived experiences of seven early career K–6 public general education teachers in Ontario (1–4 years of practice) as they engaged in inclusive education and prepared to teach students with special needs. Participants reported that teacher preparation coursework presented inclusive models only superficially, professional development was fragmented and insufficient prompting self-directed learning and structural constraints in schools limited individualized support. Teachers described …


Teaching Evelina With Digital Humanities, Hilary Havens Jun 2026

Teaching Evelina With Digital Humanities, Hilary Havens

ABO: Interactive Journal for Women in the Arts, 1640–1830

Digital humanities, an interdisciplinary field that applies digital methodologies and technologies to the humanities, is an excellent lens through which to approach the eighteenth century.  I integrate digital humanities tools and workshops alongside primary source readings in all of my eighteenth-century British literature classes to help students better understand those texts and the world in which they were created.  In my upper-level undergraduate class on late eighteenth-century literature, I teach four digital humanities tools to students, two of them (StoryMapJS and Voyant) in connection with Frances Burney’s Evelina (1778). These tools train students how to uncover historical and geographic contexts …


Reading Burney’S Mastectomy Letter: Presentist Thinking And Personal Responses In The Classroom, Heather Meek Jun 2026

Reading Burney’S Mastectomy Letter: Presentist Thinking And Personal Responses In The Classroom, Heather Meek

ABO: Interactive Journal for Women in the Arts, 1640–1830

Frances Burney’s mastectomy letter, in its graphic and detailed depiction of the operation she underwent without anesthetic in 1811, does not always lend itself immediately to standard, scholarly classroom discussion. It tends, rather, to incite unusually intimate responses, as well as conversations about medicine and health today. In my teaching of the letter in literature courses at Université de Montréal over the course of the past 13 years, I have found that students are inclined to seize upon the subject of breast cancer as especially contemporary in its relevance and to share their own anecdotal knowledge of the disease. I …


Lifelong Learning: Approaches To Teaching Frances Burney’S The Wanderer To Adults, Miriam Al Jamil Jun 2026

Lifelong Learning: Approaches To Teaching Frances Burney’S The Wanderer To Adults, Miriam Al Jamil

ABO: Interactive Journal for Women in the Arts, 1640–1830

The construction of a course for adult learners who are not studying for a qualification or credits but rather for enjoyment and engagement with learning for its own sake, requires an approach centered on needs which may not be entirely academic. Drawing on students’ individual life experiences while avoiding assumptions based on familiarity with the material shapes the course and offers many benefits. The essay is based on teaching Workers Education Association (WEA) courses and proposes the structure of a literature course on Frances Burney’s 1814 novel The Wanderer. It selects thematic content which resonates with older learners, such …


The Wanderers: Teaching The Literature Of Migration And Exile, Linda Zionkowski Jun 2026

The Wanderers: Teaching The Literature Of Migration And Exile, Linda Zionkowski

ABO: Interactive Journal for Women in the Arts, 1640–1830

In our current global landscape, exile—or forced, often permanent migration—appears a central rather than tangential experience, being driven by armed conflict, environmental destruction, economic collapse, and political repression. The climate on many university campuses reflects students’ awareness of and concern for the situation of displaced populations, and this awareness has influenced political discourse and political action inside and outside the classroom. My course titled “The Wanderers: Teaching the Literature of Migration and Exile” begins with  Frances Burney’s narration of exilic experiences in her life writings and The Wanderer. Burney’s texts offer a conceptual foundation for exploring instances of physical …


Introduction: Concise Collection On Teaching The Works Of Frances Burney, Dana Gliserman Kopans Jun 2026

Introduction: Concise Collection On Teaching The Works Of Frances Burney, Dana Gliserman Kopans

ABO: Interactive Journal for Women in the Arts, 1640–1830

This short essay introduces a Concise Collection special issue on teaching Frances Burney. The collection brings together a range of texts and approaches to them and demonstrates that Burney can be successfully taught to students outside of the graduate context.


The Secret(S) To Success: Genlis’S Guide To Raising A Foolproof Daughter, Jennifer Law-Sullivan Jun 2026

The Secret(S) To Success: Genlis’S Guide To Raising A Foolproof Daughter, Jennifer Law-Sullivan

ABO: Interactive Journal for Women in the Arts, 1640–1830

Abstract: “The Secret(s) to Success: Genlis’s Guide to Raising a Foolproof Daughter”

Stéphanie-Félicité de Genlis’s Adèle et Théodore ou lettres sur l’éducation, first published in 1782, is an epistolary conduct novel that examines the question of how best to educate girls. Attempts to answer the question were exceedingly in vogue in the late 18th century and can be traced back to Fénelon’s 1681 Traité de l’éducation des filles. Genlis’s novel offers a robust critique of previous education treatises, Rousseau, and a patriarchal society that did little to educate girls and mothers. She couches her critique in a …


Lutheran General Hospital - 40 Years Of Service Commemorative Calendar, 1959-1999, Advocate Health - Midwest Jun 2026

Lutheran General Hospital - 40 Years Of Service Commemorative Calendar, 1959-1999, Advocate Health - Midwest

Historical Documents - Combined

Advocate Lutheran General Hospital, Park Ridge, IL: Celebrating 40 years of service to the northwest Chicagoland area 1959-1999. This special commemorative calendar has been created to highlight a few of the milestones from the hospital's past four decades.


Turkish-American Ties: Analyzing Diplomatic & Population Ties During The Reign Of Mustafa Kemal Atatürk, Luke Schamber Jun 2026

Turkish-American Ties: Analyzing Diplomatic & Population Ties During The Reign Of Mustafa Kemal Atatürk, Luke Schamber

Voces Novae

No abstract provided.


Poking The Bear: American Involvement In The Afghan-Soviet War, Daniel Gunnarson Jun 2026

Poking The Bear: American Involvement In The Afghan-Soviet War, Daniel Gunnarson

Voces Novae

No abstract provided.


A Lineage Of Violence: Online Radicalization, The Great Replacement, And Far-Right Terrorism In The United States, 2011–2019, Kai Kawafuchi Jun 2026

A Lineage Of Violence: Online Radicalization, The Great Replacement, And Far-Right Terrorism In The United States, 2011–2019, Kai Kawafuchi

Voces Novae

No abstract provided.


War On Walls: The Role Of Political Murals In Northern Ireland, Julianne Martin Jun 2026

War On Walls: The Role Of Political Murals In Northern Ireland, Julianne Martin

Voces Novae

No abstract provided.


A Century Of Safer Skies: Statistical Insights Into Aviation Accidents And Death Rates, Abhijeet Regmi Jun 2026

A Century Of Safer Skies: Statistical Insights Into Aviation Accidents And Death Rates, Abhijeet Regmi

Journal of Aviation Technology and Engineering

The purpose of this study is to determine whether the recent advancements in the technology used for aircraft maintenance and repair have resulted in an increase or decrease in the accident and fatality rates of aviation incidents and accidents. The primary concerns are the extremely low survival rates in aviation accidents and the necessity to determine whether or not the accident and fatality rates are declining in light of recent technological advancements. If the rate is rising, we must prioritize passenger and crew safety more and adhere to tight regulations when performing repairs and maintenance. The data were compared for …


The Phd In Graduate Medical Education: Leveraging Doctoral Training For Educational Innovation, Rémy Roe Jun 2026

The Phd In Graduate Medical Education: Leveraging Doctoral Training For Educational Innovation, Rémy Roe

HCA Healthcare Journal of Medicine

The field of Graduate Medical Education (GME) increasingly employs PhD-trained professionals in roles including simulation directors, education researchers, program coordinators, and assessment specialists. These professionals bring valuable expertise in educational theory, research methodology, and interdisciplinary perspectives that complement physician leadership. However, role ambiguity, hierarchical positioning, and underutilization of scholarly expertise remain common challenges. This article examines the growing population of PhD-trained professionals in GME, identifies their unique contributions, and proposes strategies for better integration. Recommendations include clarifying faculty appointments, recognizing doctoral credentials appropriately, leveraging interdisciplinary expertise in strategic planning, providing protected time for scholarship, and building professional community. As GME …


Assessment And Intervention For Health Behavior Change In Primary Care Across The Lifespan: A Guide For Residents In Primary Care Specialties, Stacy A. Ogbeide, Alexis Ramos, Bridget Murphy, Angel Ogbeide Jun 2026

Assessment And Intervention For Health Behavior Change In Primary Care Across The Lifespan: A Guide For Residents In Primary Care Specialties, Stacy A. Ogbeide, Alexis Ramos, Bridget Murphy, Angel Ogbeide

HCA Healthcare Journal of Medicine

More than 45% of Americans have at least 1 chronic disease, with chronic disease also being a leading cause of death in the United States. In primary care settings, about 75% of visits are for management of multiple chronic diseases. Due to the increasing medical complexity of patients who present to primary care, these numbers make it more challenging for Primary Care Clinicians (PCCs) to manage these conditions alone and point to the need for innovative solutions to chronic disease care. One evidence-based innovation is team-based care to improve the treatment of these conditions. Clinicians such as clinical pharmacists, registered …


Does Staff Education Increase Sequential Compression Device Utilization: A Retrospective Study, Devin Q. John, Vincent Lee, Akshay V. Daji, Hans Lapica, Connor Donley, Matthew J. Mccrosson, Nino Coutelle, Carlos Fernandez, Diego Lima Jun 2026

Does Staff Education Increase Sequential Compression Device Utilization: A Retrospective Study, Devin Q. John, Vincent Lee, Akshay V. Daji, Hans Lapica, Connor Donley, Matthew J. Mccrosson, Nino Coutelle, Carlos Fernandez, Diego Lima

HCA Healthcare Journal of Medicine

Background

Venous thromboembolism (VTE) is a significant perioperative safety concern among orthopedic patients, with an incidence of 0.4%-1.0% and a substantial risk of chronic complications. Sequential compression devices (SCDs) are recommended for VTE prophylaxis, yet compliance remains suboptimal due to staff misconceptions. This study evaluates the impact of a resident-led educational intervention on SCD utilization among nursing staff in orthopedic postoperative care.

Methods

This retrospective study was conducted at 2 hospitals (HCA Florida JFK Hospital and HCA Florida Palms West Hospital). Nursing staff participated in a single educational session addressing SCD benefits, application techniques, and operational protocols. Data on SCD …


Organizational Psychology Theories In Graduate Medical Education: A Narrative Review, Mohamad S. Saad, Naim El-Aswad, Zeina Ghossoub, Relly Nadler, Serena Wasilewski Jun 2026

Organizational Psychology Theories In Graduate Medical Education: A Narrative Review, Mohamad S. Saad, Naim El-Aswad, Zeina Ghossoub, Relly Nadler, Serena Wasilewski

HCA Healthcare Journal of Medicine

Physicians and educators tend to be more versed in recognizing disease patterns and medical problems than in identifying malfunctioning patterns in the psychological aspects of their mentees and work environments. Just as hypertension and diabetes are the common soil for many acute medical problems, agency problems and organizational silos can lead to many acute managerial problems in graduate medical education (GME) settings.

Data show that most workers are lonely at work, which leads to negative emotions and undermines performance. Organizational problems seem to stem from an individual’s inability to align one’s motivation with the organization’s shared value. This can cause …


Aspirational Mirrors: A Conceptual Model Of Alumni-Led Near-Peer Outreach For Precollege Engagement In Ocean Engineering, Habibi Palippui, Juswan Sade Jun 2026

Aspirational Mirrors: A Conceptual Model Of Alumni-Led Near-Peer Outreach For Precollege Engagement In Ocean Engineering, Habibi Palippui, Juswan Sade

Journal of Pre-College Engineering Education Research (J-PEER)

Precollege students in Indonesia, especially in rural and coastal regions, often lack exposure to engineering disciplines due to social, geographic, and informational barriers. This essay proposes a conceptual model of alumni-led near-peer outreach as an affective and culturally grounded mechanism to engage high school students in ocean engineering. Drawing from theories of social similarity, possible selves, and engineering identity, the model conceptualizes alumni as “aspirational mirrors” who influence students not merely through information but also through identification. The model outlines four primary mechanisms—social connection, narrative engagement, aspirational mirroring, and early identity activation—and also accounts for contextual variables such as school …


On- And Off-Field Impacts Of Foreign Players On Peruvian Liga 1 Football Teams, Juan Victor Aranibar, Claudio Rocha Jun 2026

On- And Off-Field Impacts Of Foreign Players On Peruvian Liga 1 Football Teams, Juan Victor Aranibar, Claudio Rocha

Global Sport Business Journal

Despite the growing globalisation of football, little research has examined how foreign players create competitive advantage in non-traditional leagues. Using the Resource-Based View (RBV), this study explores the on- and off-field impact of foreign players in Peruvian Liga 1 clubs. Semi-structured interviews with 12 sporting directors, commercial managers, scouts, and coaches were analysed thematically, revealing five themes: physical characteristics, leadership and mental strength, cultural barriers, competitive salaries, and commercial blindness. Findings suggest that although foreign players provide valuable physical and psychological attributes, these are rarely sufficient to create sustained competitive advantage. More notably, clubs fail to capitalize on foreign players' …


Electronic Surveillance: National Security And The Preservation Of The Rights Guaranteed By The Fourth Amendment, Valentín I. Arenas Jun 2026

Electronic Surveillance: National Security And The Preservation Of The Rights Guaranteed By The Fourth Amendment, Valentín I. Arenas

Journal of Technology Law & Policy

No abstract provided.


Internet Ethics, American Law, And Jewish Law: A Comparative Overview, Gertrude N. Levine, Samuel J. Levine Jun 2026

Internet Ethics, American Law, And Jewish Law: A Comparative Overview, Gertrude N. Levine, Samuel J. Levine

Journal of Technology Law & Policy

Societies are governed by codes of ethics. In developed societies, parts of these codes form a set of laws, enforceable by legal authorities, with or without assistance from the populace. At times, laws are crafted for the benefit of the powerful members of the society, ensuring preservation of their positions and property, while other constituents may ignore, actively disobey, or challenge laws they believe do not support their ethics. Developing and maintaining appropriate social norms is thus particularly critical for sustaining rapidly changing heterogeneous populaces.

The Internet, devised for the purpose of interconnecting diverse computer networks of research and educational …


Fintech And Disruptive Business Models In Financial Products, Intermediation And Markets-Policy Implications For Financial Regulators, Iris H-Y Chiu Jun 2026

Fintech And Disruptive Business Models In Financial Products, Intermediation And Markets-Policy Implications For Financial Regulators, Iris H-Y Chiu

Journal of Technology Law & Policy

A recent Financial Times survey indicates that the financial services sector (in mainstream terms) is concerned about the disruptive potential of several digital-based technologies as applied to financial services, such as blockchain, big data and robo-advisers. Not to mention that we have already of late witnessed the emergence of high frequency algorithmic trading, novel consumer payment devices, online crowdfunding and peer-to-peer lending. Financial technology, which seems to be ushering in an order for upheaval, is defined by Price Waterhouse Coopers as "a dynamic segment at the intersection of the financial services and technology sectors where technology-focused start-ups and new market …


You Can't Hack This: The Regulatory Future Of Cybersecurity In Automobiles, Liz Allison Jun 2026

You Can't Hack This: The Regulatory Future Of Cybersecurity In Automobiles, Liz Allison

Journal of Technology Law & Policy

This Note argues that any new legislation imposing new safety regulations on car manufacturers is unnecessary, and will ultimately create more problems than it solves. First, there are numerous established laws that either already require what some of these propose, or address the issues involved in car hacking. Secondly, as vehicular technology becomes more advanced, so too will the methods available to fix the vulnerabilities within their systems. Finally, the government's inefficiencies and inability to stave off its own cyberattacks makes any type of federal regulations requiring minimum safety protocols a cumbersome option. For these reasons, this Note argues private …


The Metaphorical Narrative Vision In Al-Tahir Jean Walis Padovani, Zahra Ibrahim Jun 2026

The Metaphorical Narrative Vision In Al-Tahir Jean Walis Padovani, Zahra Ibrahim

SOROUD: The journal of Literacy Criticism

Jean-Wallis PADOVANI did not write under a pseudonym or assume the part of any of his characters, but rather published the story of TAHER under his real name. Unlike his contemporaries, who, driven by hidden motives, had changed their names or otherwise disguised themselves in their writings in order to appropriate the identity of the indigenous people, members of their environment, or symbols of their culture, PADOVANI took a different alternative by choosing a narrative form that he cleverly exploited for equally camouflaged purposes. From his luxurious Parisian neighborhood, he dedicated to Jean THARAUD and his brother Jérôme a short …


Negotiation-Mediated Recommendation Platform For Autonomous Agent Commerce, Anonymous Jun 2026

Negotiation-Mediated Recommendation Platform For Autonomous Agent Commerce, Anonymous

Defensive Publications Series

A platform mediates commerce between autonomous buyer and seller agents by treating recommendation as structured negotiation. The platform receives structured buyer requirements including hard constraints and preference information, and structured seller offers including multi-attribute flexibility ranges for terms such as price, delivery, warranty, and bundling. Compatibility scores are computed to select feasible matches and initiate a multi-round proposal and counter-proposal protocol. When negotiations stall, the platform computes or approximates Pareto-efficient candidate agreements and may select a bargaining-based compromise point. The platform may apply surplus-based fees and incentive-compatible transfer logic and may maintain credibility scores from observed negotiation behavior. Negotiation outcomes …


Multi-Modal Ai Platform For Integrated Manufacturing Build Monitoring And Automated Defect Analysis, Anonymous Jun 2026

Multi-Modal Ai Platform For Integrated Manufacturing Build Monitoring And Automated Defect Analysis, Anonymous

Defensive Publications Series

A multi-modal manufacturing build monitoring platform ingests time-stamped functional test station results and inspection imagery from multiple factory stations. The platform stores the data in a unified store linked by unit identifiers and provides build-level, station-level, and device-level monitoring views. Statistical drift detection flags shifts in test result distributions, including capability metric changes and distribution shape changes. Computer vision models analyze AOI/SMT and other inspection images to detect visual defects such as solder anomalies, component placement issues, and chip/package damage. A correlation engine links visual defect patterns with numerical test trends across stations and units and generates ranked failure modes …


Consumer-Oriented Marketplace Intelligence And Auction Optimization Systems For Digital Advertising Platforms, Anonymous Jun 2026

Consumer-Oriented Marketplace Intelligence And Auction Optimization Systems For Digital Advertising Platforms, Anonymous

Defensive Publications Series

Systems and methods are disclosed for consumer-centric marketplace intelligence in a digital advertising platform. Event data and social graph data are used to maintain a continuously updated consumer state vector per user including RFM scoring, lifecycle stage, predicted 13-month lifetime value tier, purchase propensity, and shopping rhythm. A per-user, per-category lifecycle model maintains probabilistic stage membership across stages including Unaware, Discovery, Research, Intent, Active, Champion, and Lapsed, and may represent cross-category migration sequences. A global product catalog knowledge graph normalizes products across multiple advertisers and stores cross-merchant relationships including complements, substitutes, and upgrade paths. An auction service computes auction scores …


Hybrid Serving Architecture With Cost-Benefit Routing For Llm-Based Recommendation Systems, Anonymous Jun 2026

Hybrid Serving Architecture With Cost-Benefit Routing For Llm-Based Recommendation Systems, Anonymous

Defensive Publications Series

A hybrid online serving architecture for recommendation systems selectively applies large language model (LLM) reasoning at a late ranking stage. A request is processed through retrieval and early-stage ranking to reduce candidates and produce confidence statistics. A cost-benefit routing orchestrator computes a routing score using traditional-model confidence, user value tier, budget utilization, latency constraints, and surface priority, and compares the routing score to a dynamically adapted threshold responsive to budget pressure, quality gap, and tail-latency pressure. Prior to LLM invocation, an ROI estimate is computed from expected quality lift and token cost, and the LLM is invoked only when ROI …


Token-Aware Capacity Management With Multi-Level Budget Hierarchy For Llm-Based Recommendation Systems, Anonymous Jun 2026

Token-Aware Capacity Management With Multi-Level Budget Hierarchy For Llm-Based Recommendation Systems, Anonymous

Defensive Publications Series

Token-aware capacity management is described for LLM-based recommendation serving. A request token cost is estimated as a sum of token components including profile, candidate, context, and output tokens. Admission control evaluates the estimated cost against a four-level hierarchical token budget comprising a global budget, per-surface budgets, per-user budgets derived from user tiers, and a per-request cap. For sub-100 ms serving paths, serving instances perform budget checks and deductions using local leased counters obtained asynchronously from a central token pool, enabling constant-time decisions without network round-trips and non-blocking lease renewal. When budgets are insufficient, a graceful degradation orchestrator selects among full …