Wears Helen Now?

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2021 application form

Microsoft Office document icon2021 application form

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The Olivia Hodson Cancer Fund invites applications for funding of projects starting after July 2021. Project applications up to a maximum of £20,000 will be considered, however we do encourage pump-priming applications for smaller amounts of approximately £1,000 - £5,000.

Applications should be emailed to Anne Anton Friday 9th April 2021. Applications should be fully costed and registered with R&D. Please see the attachment for further information about the fund and the application form.

Your recommended peer reviewers will be contacted shortly after the deadline. It may speed up your application to let them know in advance that we will be getting in touch. The committee are unable to approve applications without a peer review.

The Committee will meet to review applications shortly after the deadline of 9th April 2021 and we will shortlist applications to be sent for review. All applicants will be notified about the shortlisting. Following the external review of shortlisted applications, the committee will meet to assess the peer reviews in mid June – date to be confirmed. Applicants may be required to attend an allocated slot and present (10mins presentation and 5mins for Q&A).

OHCF Committee

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Research Paper Highlight

29 September 2021

Alcohol-abuse drug disulfiram targets pediatric glioma via MLL degradation This paper addresses the challenging issue of novel therapies for brain tumours and is from a group, led by David Michod and Jaspar de Boer, including also Stefanie Meier, Sandra Cantilena, John Anderson and Darren Hargrave. Disulfiram is an old drug, used to help manage alcohol abuse, recently shown to be active against cancer cells.  The group showed that disulfiram killed paediatric glioma cells, both cell lines and patient derived cells.  They also unravelled the likely mechanism by showing that disulfiram induces degradation of an oncoprotein, which they propose as the novel key target of this old drug and opening up a potential new treatment for paediatric gliomas.  Link to paper in Cell Death and Disease

Make September Gold! 

1 September 2021

sept_gold_cancer_awareness_month

September is Childhood Cancer Awareness Month.  Every day in the UK, 12 children and young people will receive the devastating news that they have cancer. Of those 12, two will not survive.  Of those lucky enough to survive, many will have long-term side-effects that may significantly impact their lives forever.

Show your support this September by wearing a gold ribbon.  Limited edition gold ribbon pin badges can be purchased from Children with Cancer UK, please click here for more details.

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Interstate Horseracing Act

The Interstate Horseracing Act (IHA) was enacted in 1978:

to regulate interstate commerce with respect to wagering on horseracing, in order to further the horseracing and legal off-track betting industries in the United States.38

It provides that:

[n]o person may accept an interstate off-track wager except as provided in this [Act].39

The IHA was amended in 2000 to clarify that it permits remote wagering over the phone, internet or other electronic media.40 The statute now defines an 'interstate off-track wager' as a:

legal wager placed or accepted in one state with respect to the outcome of a horserace taking place in another state and includes pari-mutuel wagers, where lawful in each state involved, placed or transmitted by an individual in one state via telephone or other electronic media and accepted by an off-track betting system in the same or another state.41

Thus, an interstate pari-mutuel wager placed or transmitted by an individual customer is an 'interstate off-track wager' permitted under the IHA if it meets two requirements:

  1. it must be 'lawful in each state involved'; and
  2. it must be accepted by an 'off-track betting system'.

These systems must be 'conducted by the state or licensed and otherwise permitted by state law.'42

The IHA also sets forth a framework for the agreements that are required with host racetracks in order to permit simulcasts of the races and the acceptance of wagers on those races.43 The IHA requires the consent of five different parties for any off-track wagering agreement.44

There has been much discussion in the academic literature and among gaming lawyers as to the relationship between the IHA, which permits interstate off-track wagers, and the Wire Act, which prohibits them (as a species of sporting event). The US Department of Justice has taken the position – although only in public statements, never in an actual prosecution – that the Wire Act prohibition continues to apply, notwithstanding the IHA.

By contrast, the consensus of most scholars and practitioners in the space – and that of the authors – is that the IHA, as both the more specific and more recent statute, trumps the Wire Act ban, so long as the wager complies with the IHA's requirements. Indeed, for quite some time, the advance-deposit-wager industry has broadly accepted online horse race wagers pursuant to the statute on precisely that premise, and the federal government has taken no steps to stop that activity.

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By: obligatory - 8th April 2014 at 14:41 Permalink - Edited 1st January 1970 at 01:00

I think its the cheer number of fighters/engines, it adds up if quantity counts in thousands,plus, a general 'fed-up' sensation of ever increasing cost of the whole thing.I can in fact sympathize strongly with this emotion

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We are a team of crypto investors, engineers and visionaries on a mission to simplify crypto tracking & tax reporting. We make cryptocurrencies easy to own, manage and report.Koinly solves crypto tracking & tax reporting for investors. We do this by pairing intuitive software with expert guidance from renowned tax consultants. To us, it’s about giving investors more time to focus on what they care about.

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By: obligatory - 9th April 2014 at 03:30 Permalink - Edited 1st January 1970 at 01:00

but isn't thin air also reduce drag alot ?
Yes, but thrust also go down with alt, sweet spot for F-22 is 36-37k

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IV Outlook

The driving force behind online expansion has been the steady growth of sports betting. When measured from the date of the Supreme Court's May 2018 decision in Murphy v. NCAA, the growth in the number of jurisdictions that have now legalised the activity (most, but not all, to include online) is significant. 2021 saw some important state launches, perhaps most notably in New York, which, despite its extraordinarily high tax, attracted fierce competition for limited 'skin' (licence) opportunities and generated substantial revenue from the start. New York legislators are already discussing expanding the market to include additional participants.

The sports betting sector was not without its setbacks, however. Texas failed to pass sports betting legislation despite intense effort and, due to the nature of that state's legislative calendar, will not be able to revisit the issue until 2023. Florida's effort to grant the Seminoles monopoly position through a tribal-state compact foundered on the shoals of the federal judiciary, leaving the state in limbo as an appeal of the court's decision invalidating the compact progresses – a process likely to consume the lion's share of 2022. And California faces the prospect of multiple, competing referenda on the ballot facing the voters in November 2022. What type of sports betting regime emerges will depend on which, if any, is enacted.

At the same time, the business of sports betting is in flux. The rush to grab 'skins' and market share in each state has led to a likely oversaturation of the sector with enormous promotional and marketing expenditures. We see a significant consolidation in the years ahead, but, for the short term, at least, companies seem intent on continuing to expand, hoping to outlast their competitors.

On the other side of the ledger, legal uncertainties surrounding the lucrative social casino sector remain. Potentially massive litigations against the platforms that process payments, distribute or promote social casino games – Google, Apple and Meta Platforms (formerly known as Facebook) remain pending. How those cases are ultimately resolved will have a dramatic impact on the sector. A more active Federal Trade Commission may portend greater scrutiny as well. A year after the Commission solicited comments from stakeholders on the potential regulation of 'loot boxes' in digital games (which raise legal issues similar to those presented by social casino), it has not taken any visible action, but that could change at any time. States are also considering legislative action, principally to limit those types of games or activities to adults or to require more fulsome disclosure of odds and related factors.

ii Ancillary criminal laws

Several other criminal statutes can be invoked in the gambling context:

  1. Money laundering statutes, 18 USC Sections 1956 and 1957, prohibit knowingly engaging in certain financial or monetary transactions, or international transportation or transmission of funds, with the 'proceeds' of a wide range of predicate crimes or 'specified unlawful activities', including gambling in violation of the Wire Act or state law.53 Penalties for violation of either statute include civil and criminal penalties, forfeitures of bank assets or debtor collateral used to facilitate the offence, imprisonment and, in the case of a financial institution, possible collateral civil sanctions.
  2. The Racketeering and Corrupt Organizations Act (RICO) imposes substantial criminal penalties where there is a 'pattern of racketeering activity'.54 'Racketeering activity' is defined to include any 'act or threat involving . . . gambling . . . which is chargeable under state law and punishable by imprisonment for more than one year' or any act or threat involving a litany of federal offences, including violations of the Wire Act, Wagering Paraphernalia Act, Travel Act, Illegal Gambling Business Act or money laundering.55

Other potentially relevant statutes include conspiracy and bank or wire fraud.56 In all of these cases, liability arises only if the defendant is violating some other federal or state statute.

iv Fantasy sports

The legality of fantasy sports has been hotly contested in the past few years. Although the UIGEA provides a safe harbour for fantasy sports, the safe harbour provides sanctuary only from the proscriptions of the UIGEA itself; it cannot absolve from liability those competitions that run afoul of state or other federal laws. Moreover, today's DFS models, with their head-to-head competitions and variation in game play and rules, at times face difficulty in fitting within the contours of the statute's safe harbour.

Beginning with New York in late 2015, 2016 saw a number of state attorneys general issue written opinions asserting DFS to be illegal gambling under state laws, and that DFS operators were in violation of state law.77 New York's attorney general went so far as to initiate civil suits alleging false advertising and unlawful gambling, and seeking to enjoin the operation of the two most prominent DFS operators – FanDuel and DraftKings – in that state. (FanDuel and DraftKings later settled the gambling aspects of those suits in March 2016,78 and the false advertising aspects in October 2016 for US$6 million each.79) These negative opinions usually claim that DFS are not contests of skill within the meaning of their respective state laws, since outcomes are ultimately determined by the athletic performance of others, over whom the participants exert no control. By contrast, only a handful of attorneys general took the position that DFS is legal under state gambling laws.80

Since then, however, a number of states have moved to regulate fantasy sports, including through licensing, taxation and consumer-protection-focused disclosures; even New York, whose attorney general was one of the earliest opponents of DFS, legalised and now regulates DFS.81

Notwithstanding 2015's flurry of attorney-general activity, there is little case law addressing the legality of fantasy sports. In February 2016, the Judicial Panel on Multidistrict Litigation consolidated nearly 80 individual putative class actions against FanDuel and DraftKings. The complaints alleged, in part, that DFS constitute unlawful gambling. FanDuel and DraftKings were later separated in November 2019, following a decision by the court to compel arbitration of a large portion of the claims at issue. On 4 March 2021, DraftKings settled the lawsuit, agreeing to provide US$7.28 million in site credit for open accounts and to allocate US$720,000 for closed player accounts.82 As part of the agreement, DraftKings will implement measures to prevent players from excessive play for two years, and publish statistics on the percentage of players winning or losing money over the preceding 30 days.83 In July 2021, FanDuel settled the remaining claims not sent to arbitration by agreeing to donate US$375,000 to national responsible gaming organisations and change its policies for spousal requests for account closure.84

A court challenge to DFS in New York had cast a cloud over its legality in that state.85 Individuals opposed to gambling filed suit in October 2018, arguing that the state's authorisation of interactive fantasy sports contests violated the state constitution's prohibition on gambling. The state supreme court – which is, confusingly, the state's trial, not highest, court – sided with the plaintiffs. It reasoned: '[Interactive fantasy sports contests] involve[], to a material degree, an element of chance, as the participants win or lose based on the actual statistical performance of groups of selected athletes in future events not under the contestants [players] control or influence.'86 As a result, the court concluded, it cannot be authorised absent a voter referendum approving an amendment to the state constitution. In February 2020, a New York appellate court affirmed the lower court's ruling.87 In March 2022, the New York Court of Appeals reversed, holding that internet-based DFS contests are legal under the state constitution. In a four–three decision, the court reasoned that 'gambling' in the state constitution does not include lawful skill-based competitions and that the legislature's determination that internet-based DFS contests are lawful skill-based competitions was supported by sufficient factual evidence.88 That decision clears the way for New York to implement its regulatory structure for DFS in that state.

In 2020, the Illinois Supreme Court similarly held that the state's safe harbour for bona fide contests of skill did, in fact, apply to an internet-based DFS contest. In Dew-Becker v. Wu, the court ruled that the plaintiff could not recover money he lost to the defendant in an internet-based DFS contest under Illinois' Gambling Loss Recovery Act because the contest was one of skill under Illinois law and therefore did not meet Illinois' definition of illegal gambling.89

Aside from that recent activity, only two pre-existing federal district court decisions address fantasy sports in any detail – Humphrey v. Viacom Inc et al, No. 06-2768, slip opinion, 2007 WL 1797648 (DNJ 20 June 2007), and Langone v. Kaiser, No. 1:12-cv-02073, slip opinion, 2013 WL 5567587 (ND Ill 9 October 2013).

Humphrey is the more significant of the two, as it reinforced the centrality of 'risk' in evaluating whether consideration for purposes of gambling is present. The plaintiff in Humphrey sought civil recovery under the qui tam laws of several states, which required him to show that money had been lost by a wager, bet or stake upon a game of chance.90 He pointed to the entry fees and prizes as evidence of money lost in a wager upon a game of chance. Without deciding whether fantasy sports are games of skill or chance, the New Jersey court noted three central elements common to the fantasy leagues at issue:

  1. the entry fee was paid unconditionally;
  2. prizes (of predetermined amounts, not dependent on the fees received) were guaranteed to be awarded; and
  3. the operators of the leagues did not compete and could not win the prizes themselves.91

Together, those factors led the court to conclude that the entry fees were not bets or wagers that would violate the gambling laws of the identified states.92 The fact that the operator did not participate in the contest – and, in fact, was indifferent to the outcome – was central to the Humphrey court's analysis.

The Langone court principally involved a claim under Illinois's gambling loss recovery statute to recover 'losses' suffered by participants on an online fantasy sports site operated by a major fantasy sports provider, FanDuel. The court ruled for FanDuel after finding that the plaintiff was unable to identify purported losers and amounts of loss with sufficient particularity, and because FanDuel's role in hosting contests and collecting entry fees did not make it a 'winner' in any particular wager. The court did not reach the question of whether FanDuel's contests would be considered 'gambling' or otherwise in violation of state laws.

Whether the Humphrey analysis would apply squarely to today's DFS variants may yet be determined in the context of the New York litigation or other potential, future cases. At the same time, state moves to clarify fantasy sports' legal status will likely result in a very different landscape for fantasy sports over the coming years.

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