Pub Date : 2019-07-03DOI: 10.1080/14729342.2019.1671044
Simon Connell, T. Wilkinson
ABSTRACT In Nice Place Property Management Ltd v Paterson [2018] NZDC 20936, a New Zealand court recently ordered a tenant to pay their landlord the roughly NZ$7,500 profit that the tenant had made while subletting the premises via Airbnb in breach of their lease. The orthodox position is that an account of profit for breach of contract is available only in exceptional cases. We argue that Nice Place is not such an exceptional case. However, we suggest that a court could make an award of ‘negotiating damages’, which are compensatory in nature, to reflect the landlord’s loss of the right to control the use of their land. This approach could result in a sum less than, or possibly more than, the tenant’s actual profit.
{"title":"Remedies when a tenant profits from unlawful sublease on Airbnb: Nice Place Property Management Ltd v Paterson","authors":"Simon Connell, T. Wilkinson","doi":"10.1080/14729342.2019.1671044","DOIUrl":"https://doi.org/10.1080/14729342.2019.1671044","url":null,"abstract":"ABSTRACT In Nice Place Property Management Ltd v Paterson [2018] NZDC 20936, a New Zealand court recently ordered a tenant to pay their landlord the roughly NZ$7,500 profit that the tenant had made while subletting the premises via Airbnb in breach of their lease. The orthodox position is that an account of profit for breach of contract is available only in exceptional cases. We argue that Nice Place is not such an exceptional case. However, we suggest that a court could make an award of ‘negotiating damages’, which are compensatory in nature, to reflect the landlord’s loss of the right to control the use of their land. This approach could result in a sum less than, or possibly more than, the tenant’s actual profit.","PeriodicalId":35148,"journal":{"name":"Oxford University Commonwealth Law Journal","volume":"19 1","pages":"273 - 283"},"PeriodicalIF":0.0,"publicationDate":"2019-07-03","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"https://sci-hub-pdf.com/10.1080/14729342.2019.1671044","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"47525084","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2019-07-03DOI: 10.1080/14729342.2019.1665764
V. Ooi
ABSTRACT Section 10(1)(g) of the Singapore Income Tax Act is a ‘sweeping-up’ provision which catches all income not falling under sections 10(1)(a)–(f). More than 50 years after its introduction, the application of section 10(1)(g) is still unclear despite the test laid out in IB v CIT. This article notes that the current jurisprudence is limited to cases involving gains or profits from the disposal of assets. It argues that the reliance on the Australian Myer Emporium test in IB v CIT was misplaced and that the section 10(1)(g) test should not have a sole focus on intention. Rather, it proposes a set of indicia of income drawn from the Badges of Trade, which it argues to be consistent with the existing jurisprudence. The article highlights that the tax consequences of receipts being assessed under sections 10(1)(a) or (g) are different and notes the importance of the receipts being assessed under the correct subsection.
{"title":"Taxing ‘all other income’ in Singapore and Malaysia","authors":"V. Ooi","doi":"10.1080/14729342.2019.1665764","DOIUrl":"https://doi.org/10.1080/14729342.2019.1665764","url":null,"abstract":"ABSTRACT Section 10(1)(g) of the Singapore Income Tax Act is a ‘sweeping-up’ provision which catches all income not falling under sections 10(1)(a)–(f). More than 50 years after its introduction, the application of section 10(1)(g) is still unclear despite the test laid out in IB v CIT. This article notes that the current jurisprudence is limited to cases involving gains or profits from the disposal of assets. It argues that the reliance on the Australian Myer Emporium test in IB v CIT was misplaced and that the section 10(1)(g) test should not have a sole focus on intention. Rather, it proposes a set of indicia of income drawn from the Badges of Trade, which it argues to be consistent with the existing jurisprudence. The article highlights that the tax consequences of receipts being assessed under sections 10(1)(a) or (g) are different and notes the importance of the receipts being assessed under the correct subsection.","PeriodicalId":35148,"journal":{"name":"Oxford University Commonwealth Law Journal","volume":"19 1","pages":"204 - 226"},"PeriodicalIF":0.0,"publicationDate":"2019-07-03","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"https://sci-hub-pdf.com/10.1080/14729342.2019.1665764","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"47472428","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2019-07-03DOI: 10.1080/14729342.2019.1678105
Yevhenii Shevchuk
ABSTRACT Recent developments in the law of contract have led to a renewed interest in the concept of negotiating damages. The Supreme Court in Morris-Garner v One Step held that such damages may be awarded for breach of contract where the loss can be assessed appropriately by reference to the economic value of the right infringed. Such a right is considered a valuable asset of which the claimant is deprived by reason of the defendant’s breach. This paper examines negotiating damages in light of the recent decision in Morris-Garner v One Step.
最近合同法的发展重新引起了人们对协商损害赔偿概念的兴趣。最高法院在Morris-Garner v One Step一案中认为，如果损失可以参照被侵犯权利的经济价值进行适当评估，则可以判定此类损害赔偿为违约。这种权利被认为是一种宝贵的资产，由于被告的违约，索赔人被剥夺了这种资产。本文根据最近的莫里斯-加纳诉“一步”案的判决来考察谈判损害赔偿。
{"title":"Negotiating damages for breach of contract after Morris-Garner v One Step","authors":"Yevhenii Shevchuk","doi":"10.1080/14729342.2019.1678105","DOIUrl":"https://doi.org/10.1080/14729342.2019.1678105","url":null,"abstract":"ABSTRACT Recent developments in the law of contract have led to a renewed interest in the concept of negotiating damages. The Supreme Court in Morris-Garner v One Step held that such damages may be awarded for breach of contract where the loss can be assessed appropriately by reference to the economic value of the right infringed. Such a right is considered a valuable asset of which the claimant is deprived by reason of the defendant’s breach. This paper examines negotiating damages in light of the recent decision in Morris-Garner v One Step.","PeriodicalId":35148,"journal":{"name":"Oxford University Commonwealth Law Journal","volume":"19 1","pages":"284 - 297"},"PeriodicalIF":0.0,"publicationDate":"2019-07-03","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"https://sci-hub-pdf.com/10.1080/14729342.2019.1678105","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"42627193","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2019-07-03DOI: 10.1080/14729342.2019.1665779
M. Leeming
ABSTRACT Takhar v Gracefield Developments Ltd [2019] UKSC 13 holds that a litigant can apply to set aside a judgment procured by fraud even if the fraud was discoverable by reasonable diligence during the trial. The unanimous decision realigns United Kingdom law with the position in Australia and Canada. However, the four judgments delivered disclose four quite different approaches of judicial technique. This note considers those approaches as well as addressing three topics of more general significance: the way in which broadly expressed dicta may be read down, the role of an historical approach in developing the body of judge-made law, and the relationship between rules and principles in the legal system.
Takhar v Gracefield Developments Ltd [2019] UKSC 13认为，即使在审判期间通过合理的尽职调查发现了欺诈行为，当事人也可以申请撤销由欺诈引起的判决。这一一致决定将英国法律与澳大利亚和加拿大的立场重新统一起来。然而，这四份判决书揭示了四种截然不同的司法手法。本说明考虑了这些方法，并讨论了三个更具有普遍意义的主题:广泛表达的命令的解读方式，历史方法在发展法官制定的法律主体中的作用，以及法律制度中规则与原则之间的关系。
{"title":"Has the golden age of fraud passed?","authors":"M. Leeming","doi":"10.1080/14729342.2019.1665779","DOIUrl":"https://doi.org/10.1080/14729342.2019.1665779","url":null,"abstract":"ABSTRACT Takhar v Gracefield Developments Ltd [2019] UKSC 13 holds that a litigant can apply to set aside a judgment procured by fraud even if the fraud was discoverable by reasonable diligence during the trial. The unanimous decision realigns United Kingdom law with the position in Australia and Canada. However, the four judgments delivered disclose four quite different approaches of judicial technique. This note considers those approaches as well as addressing three topics of more general significance: the way in which broadly expressed dicta may be read down, the role of an historical approach in developing the body of judge-made law, and the relationship between rules and principles in the legal system.","PeriodicalId":35148,"journal":{"name":"Oxford University Commonwealth Law Journal","volume":"19 1","pages":"298 - 306"},"PeriodicalIF":0.0,"publicationDate":"2019-07-03","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"https://sci-hub-pdf.com/10.1080/14729342.2019.1665779","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"47178609","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2019-07-03DOI: 10.1080/14729342.2019.1678101
Neerav Srivastava, Aashish Srivastava, D. Srivastava
ABSTRACT Ragging has become a serious social evil. Millions of university students are ragged in India every year. While a perpetrator can be sued by the victim; it has not dented the escalation of ragging. Holding institutions responsible for preventing ragging is the only way to curb it. This can be by way of both public and private accountability of universities. The paper focuses on the latter. We submit a victim of ragging can sue the university for failure to prevent ragging for breach of the university–student contract, for negligence, under vicarious liability, breach of statutory duty, contravention of a non-delegable duty, and on the basis of misfeasance in public office by a rogue university officer. A private action will have a salutary effect on society, in particular universities.
{"title":"A Million Winslows: private liability of universities for ragging in India","authors":"Neerav Srivastava, Aashish Srivastava, D. Srivastava","doi":"10.1080/14729342.2019.1678101","DOIUrl":"https://doi.org/10.1080/14729342.2019.1678101","url":null,"abstract":"ABSTRACT Ragging has become a serious social evil. Millions of university students are ragged in India every year. While a perpetrator can be sued by the victim; it has not dented the escalation of ragging. Holding institutions responsible for preventing ragging is the only way to curb it. This can be by way of both public and private accountability of universities. The paper focuses on the latter. We submit a victim of ragging can sue the university for failure to prevent ragging for breach of the university–student contract, for negligence, under vicarious liability, breach of statutory duty, contravention of a non-delegable duty, and on the basis of misfeasance in public office by a rogue university officer. A private action will have a salutary effect on society, in particular universities.","PeriodicalId":35148,"journal":{"name":"Oxford University Commonwealth Law Journal","volume":"19 1","pages":"227 - 262"},"PeriodicalIF":0.0,"publicationDate":"2019-07-03","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"https://sci-hub-pdf.com/10.1080/14729342.2019.1678101","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"44387191","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2019-07-03DOI: 10.1080/14729342.2019.1655924
Caitlin Moustaka, Kanaga Dharmananda SC
ABSTRACT In UKI (Kingsway) Limited v Westminster City Council, the Supreme Court of the United Kingdom considered the fundamental question of what constitutes effective service in the context of service of notice under a statutory regime. Two questions of general importance arose. First, is a notice validly served where it reaches the intended recipient indirectly through the actions of a third party not authorised for that purpose? Second, is a notice validly served where it is received in electronic form? On each question, the Court held that service was valid, expounding an approach that significantly expands the valid means and modes of service. This case note considers the difficulties in principle and practice of this decision, as well as its future implications.
{"title":"Indirect and electronic service: serving the interests of justice?","authors":"Caitlin Moustaka, Kanaga Dharmananda SC","doi":"10.1080/14729342.2019.1655924","DOIUrl":"https://doi.org/10.1080/14729342.2019.1655924","url":null,"abstract":"ABSTRACT In UKI (Kingsway) Limited v Westminster City Council, the Supreme Court of the United Kingdom considered the fundamental question of what constitutes effective service in the context of service of notice under a statutory regime. Two questions of general importance arose. First, is a notice validly served where it reaches the intended recipient indirectly through the actions of a third party not authorised for that purpose? Second, is a notice validly served where it is received in electronic form? On each question, the Court held that service was valid, expounding an approach that significantly expands the valid means and modes of service. This case note considers the difficulties in principle and practice of this decision, as well as its future implications.","PeriodicalId":35148,"journal":{"name":"Oxford University Commonwealth Law Journal","volume":"19 1","pages":"263 - 272"},"PeriodicalIF":0.0,"publicationDate":"2019-07-03","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"https://sci-hub-pdf.com/10.1080/14729342.2019.1655924","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"44507679","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2019-01-02DOI: 10.1080/14729342.2019.1616942
V. Chen
ABSTRACT In recent years, the misappropriation of corporate assets by 1MDB, a high-profile Malaysian company, has precipitated international investigations by regulatory authorities. Although the scandal resulted in the imprisonment of Singaporean bankers, for many years no enforcement proceedings were taken against the directors of 1MDB in Malaysia despite the existence of corporate law modelled substantially on Anglo-Australian law. The article investigates the enforcement of directors’ duties in Malaysia and seeks to explain the manner and extent to which regulatory safeguards against the expropriation of corporate property are enforced. The analysis draws from the Australian experience to illuminate the differences across jurisdictions. Features of the Malaysian context are examined to explain differences in the enforcement of directors’ duties across countries. The findings reveal the significance of the politics-business nexus, corporate ownership structures and cultural norms for the enforcement of corporate law. The implications of the Malaysian experience are considered within a broader regional context.
{"title":"Enforcement of directors’ duties in Malaysia and Australia: the implications of context","authors":"V. Chen","doi":"10.1080/14729342.2019.1616942","DOIUrl":"https://doi.org/10.1080/14729342.2019.1616942","url":null,"abstract":"ABSTRACT In recent years, the misappropriation of corporate assets by 1MDB, a high-profile Malaysian company, has precipitated international investigations by regulatory authorities. Although the scandal resulted in the imprisonment of Singaporean bankers, for many years no enforcement proceedings were taken against the directors of 1MDB in Malaysia despite the existence of corporate law modelled substantially on Anglo-Australian law. The article investigates the enforcement of directors’ duties in Malaysia and seeks to explain the manner and extent to which regulatory safeguards against the expropriation of corporate property are enforced. The analysis draws from the Australian experience to illuminate the differences across jurisdictions. Features of the Malaysian context are examined to explain differences in the enforcement of directors’ duties across countries. The findings reveal the significance of the politics-business nexus, corporate ownership structures and cultural norms for the enforcement of corporate law. The implications of the Malaysian experience are considered within a broader regional context.","PeriodicalId":35148,"journal":{"name":"Oxford University Commonwealth Law Journal","volume":"19 1","pages":"117 - 91"},"PeriodicalIF":0.0,"publicationDate":"2019-01-02","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"https://sci-hub-pdf.com/10.1080/14729342.2019.1616942","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"45767072","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2019-01-02DOI: 10.1080/14729342.2019.1588479
I. Murray
ABSTRACT In addition to their service delivery role, charities enable a range of process benefits, such as acting as sites of collective and political action. Indeed, political activities frequently arise from and are informed by service delivery. Developments around the world suggest some reticence about charities engaging in political advocacy, yet Australia and New Zealand no longer have a political purpose doctrine in their charity laws. This paper focuses on two contentious forms of political advocacy—election campaigning and illegal protest activities—and argues that in only some circumstances do those activities affect an entity’s charitable purpose or charitable status in Australia and New Zealand.
{"title":"Looking at the charitable purposes/activities distinction through a political advocacy lens: a trans-Tasman perspective","authors":"I. Murray","doi":"10.1080/14729342.2019.1588479","DOIUrl":"https://doi.org/10.1080/14729342.2019.1588479","url":null,"abstract":"ABSTRACT In addition to their service delivery role, charities enable a range of process benefits, such as acting as sites of collective and political action. Indeed, political activities frequently arise from and are informed by service delivery. Developments around the world suggest some reticence about charities engaging in political advocacy, yet Australia and New Zealand no longer have a political purpose doctrine in their charity laws. This paper focuses on two contentious forms of political advocacy—election campaigning and illegal protest activities—and argues that in only some circumstances do those activities affect an entity’s charitable purpose or charitable status in Australia and New Zealand.","PeriodicalId":35148,"journal":{"name":"Oxford University Commonwealth Law Journal","volume":"19 1","pages":"30 - 54"},"PeriodicalIF":0.0,"publicationDate":"2019-01-02","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"https://sci-hub-pdf.com/10.1080/14729342.2019.1588479","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"41633512","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2019-01-02DOI: 10.1080/14729342.2019.1580518
Tyrone Kirchengast, Thomas Crofts
ABSTRACT The criminalisation of ‘revenge porn’ offending responds to the non-consensual distribution of intimate images. By smart device or computer, the ability to distribute images assumed to be private across public networks including social media has emerged as a serious twenty-first-century concern. Individual victims present as particularly vulnerable against the ability to disseminate images quickly. It can be a particularly heinous and harmful act, and removal of the offending images may not be guaranteed. Victims have previously been limited to older criminal offences of general application, in addition to civil law remedies ordering the removal of such images. Complexity and expense has often resulted in inaction. This article assesses the Australian context of ‘revenge porn’ criminalisation, arguing for a range of graduated and complementary responses from self-help to public education to the availability of a range of civil legal remedies and criminalisation.
{"title":"The legal and policy contexts of ‘revenge porn’ criminalisation: the need for multiple approaches","authors":"Tyrone Kirchengast, Thomas Crofts","doi":"10.1080/14729342.2019.1580518","DOIUrl":"https://doi.org/10.1080/14729342.2019.1580518","url":null,"abstract":"ABSTRACT The criminalisation of ‘revenge porn’ offending responds to the non-consensual distribution of intimate images. By smart device or computer, the ability to distribute images assumed to be private across public networks including social media has emerged as a serious twenty-first-century concern. Individual victims present as particularly vulnerable against the ability to disseminate images quickly. It can be a particularly heinous and harmful act, and removal of the offending images may not be guaranteed. Victims have previously been limited to older criminal offences of general application, in addition to civil law remedies ordering the removal of such images. Complexity and expense has often resulted in inaction. This article assesses the Australian context of ‘revenge porn’ criminalisation, arguing for a range of graduated and complementary responses from self-help to public education to the availability of a range of civil legal remedies and criminalisation.","PeriodicalId":35148,"journal":{"name":"Oxford University Commonwealth Law Journal","volume":"19 1","pages":"1 - 29"},"PeriodicalIF":0.0,"publicationDate":"2019-01-02","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"https://sci-hub-pdf.com/10.1080/14729342.2019.1580518","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"44168238","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2019-01-02DOI: 10.1080/14729342.2019.1619238
A. Keay
ABSTRACT Section 172(1) of the Companies Act 2006 introduced the principle of enlightened shareholder value (ESV) to UK law. The provision imposes a duty on directors to act in good faith, in a manner that they consider will promote the success of the company for the benefit of shareholders. The subsection also requires directors to have regard to certain factors when doing this. This is the enlightened aspect of ESV, as these factors encompass interests of different stakeholders, such as employees and customers. Uncertainty prevails over several elements of s 172(1), and this paper addresses this uncertainty over the directors’ obligation to have regard to these factors. It examines the factors in the provision and what it means for directors to have regard to them. It also explores what directors are to do when their actions will lead to a conflict between different factors.
{"title":"Having regard for stakeholders in practising enlightened shareholder value","authors":"A. Keay","doi":"10.1080/14729342.2019.1619238","DOIUrl":"https://doi.org/10.1080/14729342.2019.1619238","url":null,"abstract":"ABSTRACT Section 172(1) of the Companies Act 2006 introduced the principle of enlightened shareholder value (ESV) to UK law. The provision imposes a duty on directors to act in good faith, in a manner that they consider will promote the success of the company for the benefit of shareholders. The subsection also requires directors to have regard to certain factors when doing this. This is the enlightened aspect of ESV, as these factors encompass interests of different stakeholders, such as employees and customers. Uncertainty prevails over several elements of s 172(1), and this paper addresses this uncertainty over the directors’ obligation to have regard to these factors. It examines the factors in the provision and what it means for directors to have regard to them. It also explores what directors are to do when their actions will lead to a conflict between different factors.","PeriodicalId":35148,"journal":{"name":"Oxford University Commonwealth Law Journal","volume":"19 1","pages":"118 - 138"},"PeriodicalIF":0.0,"publicationDate":"2019-01-02","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"https://sci-hub-pdf.com/10.1080/14729342.2019.1619238","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"45101341","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
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