This chapter explores the relationship between private law and common law. Both private law and the common law fit awkwardly into the dominant theoretical models of law, which emphasize regulation and social control by the state. Thus, the common law has long been criticized for failing to comply with the model of clearly articulated rules that are announced ex ante and applied ex post. The private law, for its part, contains numerous features that make it a poor candidate for a well-designed regulatory regime. The chapter then argues that developments in private law theory suggest a convergence between private law and the common law that responds to these issues, rendering the law both intelligible and providing an answer to the common objection that the common law involves ex post facto lawmaking. In addition, a recovery of this classical common law theory is both conceptually feasible and offers solutions to problems left currently unanswered by neoformalism.
{"title":"Private Law and Local Custom","authors":"Nathan B. Oman","doi":"10.2139/ssrn.3468516","DOIUrl":"https://doi.org/10.2139/ssrn.3468516","url":null,"abstract":"This chapter explores the relationship between private law and common law. Both private law and the common law fit awkwardly into the dominant theoretical models of law, which emphasize regulation and social control by the state. Thus, the common law has long been criticized for failing to comply with the model of clearly articulated rules that are announced ex ante and applied ex post. The private law, for its part, contains numerous features that make it a poor candidate for a well-designed regulatory regime. The chapter then argues that developments in private law theory suggest a convergence between private law and the common law that responds to these issues, rendering the law both intelligible and providing an answer to the common objection that the common law involves ex post facto lawmaking. In addition, a recovery of this classical common law theory is both conceptually feasible and offers solutions to problems left currently unanswered by neoformalism.","PeriodicalId":433815,"journal":{"name":"English Law: Personal Obligations & Legal Theory (Topic)","volume":"9 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2019-10-11","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"130458946","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}
The author of this paper argues that judicial ratios can be classified into two different categories: 1) logical ratios, and 2) non-logical ratios. As an example, the author presents four different judicial ratios from four different UK case law. The paper also discusses the criteria which one must be looking at when classifying judicial ratios. The paper borrows ideas from the field of Set Theory and Analytic Philosophy, especially from the work of Bertrand Russell and Ludwig Wittgenstein.
{"title":"Judicial Reasoning: The Production of Legal Knowledge","authors":"Mustafa Tashkandi","doi":"10.2139/ssrn.3386200","DOIUrl":"https://doi.org/10.2139/ssrn.3386200","url":null,"abstract":"The author of this paper argues that judicial ratios can be classified into two different categories: 1) logical ratios, and 2) non-logical ratios. As an example, the author presents four different judicial ratios from four different UK case law. The paper also discusses the criteria which one must be looking at when classifying judicial ratios. The paper borrows ideas from the field of Set Theory and Analytic Philosophy, especially from the work of Bertrand Russell and Ludwig Wittgenstein.","PeriodicalId":433815,"journal":{"name":"English Law: Personal Obligations & Legal Theory (Topic)","volume":"168 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2019-05-07","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"121143269","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}
The fusion of law and equity in common law systems was a crucial moment in the development of modern Anglo-American law, with implications for the procedural, substantive and remedial aspects of law. This paper will introduce a volume of essays in which scholars undertake historical, comparative, doctrinal and theoretical analysis that aims to shed light on the ways in which law and equity have fused, and the ways in which they have remained distinct even in a ‘post-fusion’ world. The central concern of this paper lies in two facts. The first is that the presence of equity in common law systems poses fundamental questions. What is the place of equity in a modern common law system? Is the purpose of equity, as a distinct ingredient of common law systems, spent? Should equity be distributed through the law? If equity should be a distinct ingredient of common law systems, in what form? The second is that fusion (or merger or union) has become the means by which lawyers address those basic questions. Helpful answers to these basal questions have become more remote as theories of equity have become constrained by the terms in which fusion is discussed. How can the situation be improved? This chapter suggests that a newly widened perspective is needed. The constitutional place that has been assigned to equity in common law systems must be acknowledged and accommodated. And any modern theory of equity must be composite rather than simple or unitary. Also important to appreciate is the practical significance of how fusion is discussed, and how equity theories are formed, in the thinking of lawyers and the work of the courts. To illustrate that practical point, illustrations are given of the accidental fusion of law and equity through the unthinking assimilation of modern equitable claims to the common law forms of action finally abolished in England in 1875.
{"title":"Fusion and Theories of Equity in Common Law Systems","authors":"P. G. Turner","doi":"10.2139/SSRN.3253606","DOIUrl":"https://doi.org/10.2139/SSRN.3253606","url":null,"abstract":"The fusion of law and equity in common law systems was a crucial moment in the development of modern Anglo-American law, with implications for the procedural, substantive and remedial aspects of law. This paper will introduce a volume of essays in which scholars undertake historical, comparative, doctrinal and theoretical analysis that aims to shed light on the ways in which law and equity have fused, and the ways in which they have remained distinct even in a ‘post-fusion’ world. \u0000The central concern of this paper lies in two facts. The first is that the presence of equity in common law systems poses fundamental questions. What is the place of equity in a modern common law system? Is the purpose of equity, as a distinct ingredient of common law systems, spent? Should equity be distributed through the law? If equity should be a distinct ingredient of common law systems, in what form? The second is that fusion (or merger or union) has become the means by which lawyers address those basic questions. \u0000Helpful answers to these basal questions have become more remote as theories of equity have become constrained by the terms in which fusion is discussed. How can the situation be improved? This chapter suggests that a newly widened perspective is needed. The constitutional place that has been assigned to equity in common law systems must be acknowledged and accommodated. And any modern theory of equity must be composite rather than simple or unitary. Also important to appreciate is the practical significance of how fusion is discussed, and how equity theories are formed, in the thinking of lawyers and the work of the courts. To illustrate that practical point, illustrations are given of the accidental fusion of law and equity through the unthinking assimilation of modern equitable claims to the common law forms of action finally abolished in England in 1875.","PeriodicalId":433815,"journal":{"name":"English Law: Personal Obligations & Legal Theory (Topic)","volume":"120 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2018-09-22","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"120959883","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}
The Bills of Sale Acts were enacted in Victorian times as a form of secured credit whereby ‘goods’ owned by a borrower could be assigned under the bill of sale to a lender who would have title to the goods transferred to him. The lender would then allow the borrower to retain possession of the goods in exchange for instalment payments with interest. In the twenty‐first century these bills are most commonly used as ‘logbook loans’ for vehicles with extortionate interest rates and very little protection for individual consumers. This article examines the operational background to the Bill of Sale Acts. It focuses upon particular concerns for consumers and businesses and provides critique of the registration process before examining the proposals and consultations for reform currently before the Law Commission.
{"title":"Bill of Sale Lending: Reforming a ‘Toxic’ Form of Credit","authors":"G. Swaby, Rebecca J. Kelly, P. Richards","doi":"10.1111/1468-2230.12330","DOIUrl":"https://doi.org/10.1111/1468-2230.12330","url":null,"abstract":"The Bills of Sale Acts were enacted in Victorian times as a form of secured credit whereby ‘goods’ owned by a borrower could be assigned under the bill of sale to a lender who would have title to the goods transferred to him. The lender would then allow the borrower to retain possession of the goods in exchange for instalment payments with interest. In the twenty‐first century these bills are most commonly used as ‘logbook loans’ for vehicles with extortionate interest rates and very little protection for individual consumers. This article examines the operational background to the Bill of Sale Acts. It focuses upon particular concerns for consumers and businesses and provides critique of the registration process before examining the proposals and consultations for reform currently before the Law Commission.","PeriodicalId":433815,"journal":{"name":"English Law: Personal Obligations & Legal Theory (Topic)","volume":"10 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2018-03-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"114148430","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 : 2015-12-06DOI: 10.4337/9781789902518.00009
Victor P. Goldberg
In The Golden Victory the House of Lords held that when determining damages for a repudiatory breach, in a conflict between the compensatory principle and finality, the former trumped. The decision was recently ratified by the Supreme Court in Bunge SA v. Nidera BV. The claim in this paper is that this was a mistake; properly conceived, there is no conflict. The contract should be viewed as an asset and compensation would entail determining the decline in value of that asset at the time of the breach. The value of the contract at that moment would reflect the possible effects of future events (e.g., the occurrence of the Gulf War in The Golden Victory and the lifting of the Russian wheat embargo in Bunge). This does not mean rejection of the compensatory principle; it simply entails defining more precisely what is being compensated — the value of the contract at the moment it had been repudiated.
{"title":"After the Golden Victory: Still Lost at Sea","authors":"Victor P. Goldberg","doi":"10.4337/9781789902518.00009","DOIUrl":"https://doi.org/10.4337/9781789902518.00009","url":null,"abstract":"In The Golden Victory the House of Lords held that when determining damages for a repudiatory breach, in a conflict between the compensatory principle and finality, the former trumped. The decision was recently ratified by the Supreme Court in Bunge SA v. Nidera BV. The claim in this paper is that this was a mistake; properly conceived, there is no conflict. The contract should be viewed as an asset and compensation would entail determining the decline in value of that asset at the time of the breach. The value of the contract at that moment would reflect the possible effects of future events (e.g., the occurrence of the Gulf War in The Golden Victory and the lifting of the Russian wheat embargo in Bunge). This does not mean rejection of the compensatory principle; it simply entails defining more precisely what is being compensated — the value of the contract at the moment it had been repudiated.","PeriodicalId":433815,"journal":{"name":"English Law: Personal Obligations & Legal Theory (Topic)","volume":"28 1 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2015-12-06","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"128738698","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}
Is the loss of the opportunity of fatherhood a form of damage recognised by the law of delict? Much academic commentary has already been generated by the English case of Yearworth v North Bristol NHS Trust [2009] EWCA Civ 37, [2010] QB 1, in which the Court of Appeal ruled that the negligent destruction of sperm samples entrusted for storage to the defendant by cancer patients constituted an actionable breach of bailment. In reaching that decision it took the view that the damage to the sperm samples could not be regarded as personal injury, and other potential grounds for liability in tort were not explored in depth. These issues have now come to the fore in Scotland in Holdich v Lothian Health Board [2013] CSOH 197, 2014 SLT 495, which arose out of similar circumstances. Following citation of Yearworth, Lord Stewart held the pursuer relevantly to have argued that sperm samples deposited by him with the defender were capable of being owned by him, and that, consequently, failure properly to conserve them could be regarded as a breach of the contract of deposit. However, his Lordship further allowed that the case in negligence for damages for mental injury, and for loss of “autonomy”, was relevant for proof, observing in addition that a claim based upon personal injury might not have been “far fetched”. Others have commented in detail upon the property law implications of Holdich (see See K. Reid “Body Parts and Property”, Edinburgh Law School Working Paper Series, 2015/25 (SSRN, 2015). This paper focuses instead upon the important questions of delictual liability raised thereby.
{"title":"Delictual Liability and the Loss of Opportunity of Fatherhood: Holdich v Lothian Health Board","authors":"E. Reid","doi":"10.2139/ssrn.2663063","DOIUrl":"https://doi.org/10.2139/ssrn.2663063","url":null,"abstract":"Is the loss of the opportunity of fatherhood a form of damage recognised by the law of delict? Much academic commentary has already been generated by the English case of Yearworth v North Bristol NHS Trust [2009] EWCA Civ 37, [2010] QB 1, in which the Court of Appeal ruled that the negligent destruction of sperm samples entrusted for storage to the defendant by cancer patients constituted an actionable breach of bailment. In reaching that decision it took the view that the damage to the sperm samples could not be regarded as personal injury, and other potential grounds for liability in tort were not explored in depth. These issues have now come to the fore in Scotland in Holdich v Lothian Health Board [2013] CSOH 197, 2014 SLT 495, which arose out of similar circumstances. Following citation of Yearworth, Lord Stewart held the pursuer relevantly to have argued that sperm samples deposited by him with the defender were capable of being owned by him, and that, consequently, failure properly to conserve them could be regarded as a breach of the contract of deposit. However, his Lordship further allowed that the case in negligence for damages for mental injury, and for loss of “autonomy”, was relevant for proof, observing in addition that a claim based upon personal injury might not have been “far fetched”. Others have commented in detail upon the property law implications of Holdich (see See K. Reid “Body Parts and Property”, Edinburgh Law School Working Paper Series, 2015/25 (SSRN, 2015). This paper focuses instead upon the important questions of delictual liability raised thereby.","PeriodicalId":433815,"journal":{"name":"English Law: Personal Obligations & Legal Theory (Topic)","volume":"10 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2015-09-20","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"127817161","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 : 2015-04-13DOI: 10.1017/9781316442906.003
Neil Walker
The jurist comprehends law as something more than technical expertise. The jurist is concerned not only with serving the needs of her professional clients, whatever these needs may be, but also with the wider purpose of enhancing the well-being of law as a practical idea. What implications does this longstanding if highly open-ended conception of the jurist have for legal research and education today? The paper begins to address this question by exploring some of the general and enduring tensions and divisions within our understanding of law as an academic discipline; between a humanities-based approach and a social scientific approach, and also between service, detached and critical orientations towards the law. It then proceeds to re-examine these divisions in the context of the intense development of transnational and global law in the contemporary age. The paper argues that the challenge to state-centred legal authority accompanying that development has enhanced the role of jurists as co-producers of legal norms and authority frameworks. It has also required jurists to become more invested both in the kind of reflective historical inquiry into and evaluation of our common cultural productions associated with the humanities, and in the analysis of emergent trends associated with certain of the social sciences. And in its focus on the new fluidity of legal authority, the globalisation of law also increasingly questions the force of the opposition between a conservatively-inflected service or detached orientation and a (potentially transformative) critical orientation. The role of the jurist in a global age, in sum, is significantly altered, and requires us to revise some of the distinctions that have traditionally attended our thinking about legal teaching and learning.
{"title":"The Jurist in a Global Age","authors":"Neil Walker","doi":"10.1017/9781316442906.003","DOIUrl":"https://doi.org/10.1017/9781316442906.003","url":null,"abstract":"The jurist comprehends law as something more than technical expertise. The jurist is concerned not only with serving the needs of her professional clients, whatever these needs may be, but also with the wider purpose of enhancing the well-being of law as a practical idea. What implications does this longstanding if highly open-ended conception of the jurist have for legal research and education today? The paper begins to address this question by exploring some of the general and enduring tensions and divisions within our understanding of law as an academic discipline; between a humanities-based approach and a social scientific approach, and also between service, detached and critical orientations towards the law. It then proceeds to re-examine these divisions in the context of the intense development of transnational and global law in the contemporary age. The paper argues that the challenge to state-centred legal authority accompanying that development has enhanced the role of jurists as co-producers of legal norms and authority frameworks. It has also required jurists to become more invested both in the kind of reflective historical inquiry into and evaluation of our common cultural productions associated with the humanities, and in the analysis of emergent trends associated with certain of the social sciences. And in its focus on the new fluidity of legal authority, the globalisation of law also increasingly questions the force of the opposition between a conservatively-inflected service or detached orientation and a (potentially transformative) critical orientation. The role of the jurist in a global age, in sum, is significantly altered, and requires us to revise some of the distinctions that have traditionally attended our thinking about legal teaching and learning.","PeriodicalId":433815,"journal":{"name":"English Law: Personal Obligations & Legal Theory (Topic)","volume":"118 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2015-04-13","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"131660413","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}
Why are the civil remedies at common law which delivery up specific moveable property to another with greater right to possess so narrow in English law? Historically the equitable remedy of specific restoration returned property more easily than even the rule today; the common law remedy remains discretionary, with the claimant having to show the value to the property that cannot be found equally easily in the market. There may be a number of reasons behind this. The purpose of this chapter is to show the role played by the widely available proprietary remedies in the criminal law, as well as the role of the conceptual structure of property law in England focussing on relative title to possess. The argument being tested is that there was less pressure to develop a civil law restoration remedy because significant practical results were being achieved by the criminal mechanisms. It is all the more interesting that specific restoration has been more significant than compensation in the criminal law (when the reverse has been true in the civil law).
{"title":"The Properties of the Law: Restoring Personal Property Through Crime and Tort","authors":"M. Dyson, Sarah Green","doi":"10.2139/SSRN.2377311","DOIUrl":"https://doi.org/10.2139/SSRN.2377311","url":null,"abstract":"Why are the civil remedies at common law which delivery up specific moveable property to another with greater right to possess so narrow in English law? Historically the equitable remedy of specific restoration returned property more easily than even the rule today; the common law remedy remains discretionary, with the claimant having to show the value to the property that cannot be found equally easily in the market. There may be a number of reasons behind this. The purpose of this chapter is to show the role played by the widely available proprietary remedies in the criminal law, as well as the role of the conceptual structure of property law in England focussing on relative title to possess. The argument being tested is that there was less pressure to develop a civil law restoration remedy because significant practical results were being achieved by the criminal mechanisms. It is all the more interesting that specific restoration has been more significant than compensation in the criminal law (when the reverse has been true in the civil law).","PeriodicalId":433815,"journal":{"name":"English Law: Personal Obligations & Legal Theory (Topic)","volume":"23 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2014-01-03","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"129537896","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}
This article examines the gist, vitality and practical utility of the tort of intimidation and identifies what count as unlawful threats and as actionable harm. While two versions of the tort have been identified in the past – one involving two parties, one involving three – only the former has survived the decision of the House of Lords in OBG v Allan. In the context considering the tort's practical usefulness, the article exposes as bogus the suggestion that two‐party intimidation offers nothing that is not already supplied under the law of contract via the doctrines of anticipatory breach, duress and economic duress. The article concludes with two radical suggestions. First, that two‐party intimidation is not a specifically economic tort and secondly, in view of this fact, it was a most inappropriate tool for the House of Lords to have used in their resurrection of the tort of unlawful means conspiracy in Total Network SL v Revenue and Customs Commissioners.
{"title":"Understanding Intimidation","authors":"John Murphy","doi":"10.1111/1468-2230.12055","DOIUrl":"https://doi.org/10.1111/1468-2230.12055","url":null,"abstract":"This article examines the gist, vitality and practical utility of the tort of intimidation and identifies what count as unlawful threats and as actionable harm. While two versions of the tort have been identified in the past – one involving two parties, one involving three – only the former has survived the decision of the House of Lords in OBG v Allan. In the context considering the tort's practical usefulness, the article exposes as bogus the suggestion that two‐party intimidation offers nothing that is not already supplied under the law of contract via the doctrines of anticipatory breach, duress and economic duress. The article concludes with two radical suggestions. First, that two‐party intimidation is not a specifically economic tort and secondly, in view of this fact, it was a most inappropriate tool for the House of Lords to have used in their resurrection of the tort of unlawful means conspiracy in Total Network SL v Revenue and Customs Commissioners.","PeriodicalId":433815,"journal":{"name":"English Law: Personal Obligations & Legal Theory (Topic)","volume":"28 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2014-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"129938558","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}
A brief overview of the current provisions of Part 36 CPR as amended, and a brief evaluation of whether its introduction through the CPR has been a success.
简要概述经修订的《CPR》第36部分的现行规定，并简要评价其通过《CPR》的引入是否成功。
{"title":"Part 36: Success or Failure?","authors":"Christos S. Konstantinou","doi":"10.2139/SSRN.2162833","DOIUrl":"https://doi.org/10.2139/SSRN.2162833","url":null,"abstract":"A brief overview of the current provisions of Part 36 CPR as amended, and a brief evaluation of whether its introduction through the CPR has been a success.","PeriodicalId":433815,"journal":{"name":"English Law: Personal Obligations & Legal Theory (Topic)","volume":"24 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2012-10-14","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"116677630","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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