Pub Date : 2024-04-05DOI: 10.36969/njel.v7i1.25812
Medy Dervovic, Stefan Kirchner, Angharad Downes
In recent years, it has increasingly been recognized that work at sea often raises questions concerning the protection of human rights. This is also the case in the context of fishing. While human rights issues on commercial fishing vessels are gaining attention, fishing activities of individuals and small crews are also connected to human rights—for example, regarding the implementation of fisheries policies. In December 2022, the European Court of Human Rights (ECtHR) ruled in the case of a fisherman from Bulgaria who had worked in Romania’s Exclusive Economic Zone (EEZ) in the Black Sea. Bulgaria and Romania are both members of the European Union (EU), and the EU’s Common Fisheries Policy (CFP) applied to the applicant’s work. He alleged that Romania implemented the CFP incorrectly and, in doing so, violated his human rights. This article analyzes the case of Spasov v Romania, which, as of late 2023, is available on the ECtHR’s website in French. The core issues of the case are placed in the context of the CFP and the relationship between the EU and the ECHR. It will be shown that the ECHR remains a potent tool for the protection of human rights at sea as well, including in the EEZ, where the coastal State exercises jurisdiction within the meaning of Article 1 ECHR.
{"title":"Fishing Rights Procedure at the European Court of Human Rights: Spasov v Romania","authors":"Medy Dervovic, Stefan Kirchner, Angharad Downes","doi":"10.36969/njel.v7i1.25812","DOIUrl":"https://doi.org/10.36969/njel.v7i1.25812","url":null,"abstract":"In recent years, it has increasingly been recognized that work at sea often raises questions concerning the protection of human rights. This is also the case in the context of fishing. While human rights issues on commercial fishing vessels are gaining attention, fishing activities of individuals and small crews are also connected to human rights—for example, regarding the implementation of fisheries policies. In December 2022, the European Court of Human Rights (ECtHR) ruled in the case of a fisherman from Bulgaria who had worked in Romania’s Exclusive Economic Zone (EEZ) in the Black Sea. Bulgaria and Romania are both members of the European Union (EU), and the EU’s Common Fisheries Policy (CFP) applied to the applicant’s work. He alleged that Romania implemented the CFP incorrectly and, in doing so, violated his human rights. This article analyzes the case of Spasov v Romania, which, as of late 2023, is available on the ECtHR’s website in French. The core issues of the case are placed in the context of the CFP and the relationship between the EU and the ECHR. It will be shown that the ECHR remains a potent tool for the protection of human rights at sea as well, including in the EEZ, where the coastal State exercises jurisdiction within the meaning of Article 1 ECHR.","PeriodicalId":489206,"journal":{"name":"Nordic journal of european law","volume":"35 3","pages":""},"PeriodicalIF":0.0,"publicationDate":"2024-04-05","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"140740985","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 : 2024-04-05DOI: 10.36969/njel.v7i1.25799
Ignacio Vásquez Torreblanca
The European Union has not only raised the need for strategic autonomy, but has also opened up to re-establishing new relationships. One of these relationships in the spotlight is Latin America, which has the highest concentration of critical minerals, key, among other things, for the energy transition of the Union and Latin America itself. However, the instruments of European law have become more flexible beyond Mercosur and the prevailing formalism, and a new cycle of relations is being generated. To a large extent, this adaptation may combine new ways of conceptualizing the role of "strategic for both parties", since European energy autonomy and the business diplomacy experienced by some Latin American countries such as Chile are not mutually exclusive. The Chilean case is paradigmatic of this crossroads, as the country is part of the new wave of natural resource sovereignty, but at the same time it is considering executing the development imaginary together with the geopolitical interests of the European Union.
{"title":"EU-Chile Horizons: Climate Justice for a Shared Strategy on Critical Minerals","authors":"Ignacio Vásquez Torreblanca","doi":"10.36969/njel.v7i1.25799","DOIUrl":"https://doi.org/10.36969/njel.v7i1.25799","url":null,"abstract":"The European Union has not only raised the need for strategic autonomy, but has also opened up to re-establishing new relationships. One of these relationships in the spotlight is Latin America, which has the highest concentration of critical minerals, key, among other things, for the energy transition of the Union and Latin America itself. However, the instruments of European law have become more flexible beyond Mercosur and the prevailing formalism, and a new cycle of relations is being generated. To a large extent, this adaptation may combine new ways of conceptualizing the role of \"strategic for both parties\", since European energy autonomy and the business diplomacy experienced by some Latin American countries such as Chile are not mutually exclusive. The Chilean case is paradigmatic of this crossroads, as the country is part of the new wave of natural resource sovereignty, but at the same time it is considering executing the development imaginary together with the geopolitical interests of the European Union.","PeriodicalId":489206,"journal":{"name":"Nordic journal of european law","volume":"21 21","pages":""},"PeriodicalIF":0.0,"publicationDate":"2024-04-05","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"140738827","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 : 2024-04-05DOI: 10.36969/njel.v7i1.25323
Vetle Seierstad
This article explores the obligation of Member States, under Article 19(1) TEU, to uphold the judicial independence of all national courts who ‘may’ rule on Union law. The European Court of Justice (ECJ) first set out this obligation in their seminal ruling in Associação Sindical dos Juízes Portugueses and has since developed an extensive case-law. This article explores and discusses that case-law with the purpose of setting out, in a general manner, the key obligations Member States have under Article 19(1) TEU. Furthermore, where the ECJ has only set out general requirements without detailing their content, this article expands on the case-law by supplementing and contrasting solutions provided to similar issues in the case-law of the European Court of Human Rights (ECtHR), the recommendations of the Venice Commission and in wider International Human Rights Law. Finally, this article discusses whether judicial independence can be balanced against other aims, concerns and goals, and what room that leaves Member States to justify potential restrictions on judicial independence by the pursuit of (other) legitimate objectives.
{"title":"The Obligation to Establish and Uphold Judicial Independence under Article 19(1) TEU","authors":"Vetle Seierstad","doi":"10.36969/njel.v7i1.25323","DOIUrl":"https://doi.org/10.36969/njel.v7i1.25323","url":null,"abstract":"This article explores the obligation of Member States, under Article 19(1) TEU, to uphold the judicial independence of all national courts who ‘may’ rule on Union law. The European Court of Justice (ECJ) first set out this obligation in their seminal ruling in Associação Sindical dos Juízes Portugueses and has since developed an extensive case-law. This article explores and discusses that case-law with the purpose of setting out, in a general manner, the key obligations Member States have under Article 19(1) TEU. Furthermore, where the ECJ has only set out general requirements without detailing their content, this article expands on the case-law by supplementing and contrasting solutions provided to similar issues in the case-law of the European Court of Human Rights (ECtHR), the recommendations of the Venice Commission and in wider International Human Rights Law. Finally, this article discusses whether judicial independence can be balanced against other aims, concerns and goals, and what room that leaves Member States to justify potential restrictions on judicial independence by the pursuit of (other) legitimate objectives.","PeriodicalId":489206,"journal":{"name":"Nordic journal of european law","volume":"212 2","pages":""},"PeriodicalIF":0.0,"publicationDate":"2024-04-05","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"140740309","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 : 2024-04-05DOI: 10.36969/njel.v7i1.25734
Ludovica Sposini
This contribution aims at analysing the current European regulatory framework aimed at protecting online users against the risks of digital content profiling and personalisation practices by online platforms. Indeed, algorithms exploit human weaknesses and emotions to influence users' purchasing behaviour in a context where the line between mere persuasion (accepted within a certain limit by law) becomes manipulation. After analysing the current regulation on the subject and giving an account of its major criticalities, some final considerations will be provided in order to identify possible future developments in the EU consumer discipline to ensure greater protection against algorithm abuse.
{"title":"The Governance of Algorithms: Profiling and Personalisation of Online Content in the Context of European Consumer Law","authors":"Ludovica Sposini","doi":"10.36969/njel.v7i1.25734","DOIUrl":"https://doi.org/10.36969/njel.v7i1.25734","url":null,"abstract":"This contribution aims at analysing the current European regulatory framework aimed at protecting online users against the risks of digital content profiling and personalisation practices by online platforms. \u0000Indeed, algorithms exploit human weaknesses and emotions to influence users' purchasing behaviour in a context where the line between mere persuasion (accepted within a certain limit by law) becomes manipulation. After analysing the current regulation on the subject and giving an account of its major criticalities, some final considerations will be provided in order to identify possible future developments in the EU consumer discipline to ensure greater protection against algorithm abuse.","PeriodicalId":489206,"journal":{"name":"Nordic journal of european law","volume":"182 4","pages":""},"PeriodicalIF":0.0,"publicationDate":"2024-04-05","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"140740510","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 : 2023-10-31DOI: 10.36969/njel.v6i3.25716
Pablo Martín Rodríguez
{"title":"The Respect of The Rule of Law by the European Union in Times of Economic Emergency","authors":"Pablo Martín Rodríguez","doi":"10.36969/njel.v6i3.25716","DOIUrl":"https://doi.org/10.36969/njel.v6i3.25716","url":null,"abstract":"","PeriodicalId":489206,"journal":{"name":"Nordic journal of european law","volume":"4 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2023-10-31","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"135869792","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 : 2023-10-31DOI: 10.36969/njel.v6i3.25090
Martin Westlund
Many asylum cases present an opportunity for the European Court of Justice to promote and protect EU values such as human rights and the rule of law. Yet, in central issues on the EU asylum system, the Court has opted for careful and formal readings of law rather than exploring such perspectives. The Court’s legal reasoning in asylum is examined by case analyses in NF v Council on the EU-Turkey Statement, X and X on humanitarian visas, and A.S. and Jafari on the EU asylum system. In free movement, the Court is considered a key driver of integration, whereas, in asylum law, it is seen as more restrictive. Rather than promoting EU integration and ensuring human rights protections, the Court grants discretion to the legislator or the executive. There are legitimate reasons why a different path has been taken in asylum. However, as a more extensive and dynamic method of interpretation could increase human rights protections, it is relevant to reassess the position of the Court in asylum law.
{"title":"The Road Not Taken","authors":"Martin Westlund","doi":"10.36969/njel.v6i3.25090","DOIUrl":"https://doi.org/10.36969/njel.v6i3.25090","url":null,"abstract":"Many asylum cases present an opportunity for the European Court of Justice to promote and protect EU values such as human rights and the rule of law. Yet, in central issues on the EU asylum system, the Court has opted for careful and formal readings of law rather than exploring such perspectives. The Court’s legal reasoning in asylum is examined by case analyses in NF v Council on the EU-Turkey Statement, X and X on humanitarian visas, and A.S. and Jafari on the EU asylum system. In free movement, the Court is considered a key driver of integration, whereas, in asylum law, it is seen as more restrictive. Rather than promoting EU integration and ensuring human rights protections, the Court grants discretion to the legislator or the executive. There are legitimate reasons why a different path has been taken in asylum. However, as a more extensive and dynamic method of interpretation could increase human rights protections, it is relevant to reassess the position of the Court in asylum law.","PeriodicalId":489206,"journal":{"name":"Nordic journal of european law","volume":"86 11","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2023-10-31","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"135813823","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 : 2023-10-31DOI: 10.36969/njel.v6i3.25717
Radu Mares
In response to the climate emergency, the European Union seeks to establish a new model of inclusive growth and depicts this shift as a ‘green, fair and competitive transition’. The article examines the EU sustainable corporate governance initiative commenced in 2018 that has crystalized after four years in a Commission’s proposal for a Directive on corporate due diligence, which is expected to be adopted by early 2024. The focus herein is on why and how directors’ duties under company law are being discussed and potentially reformed in the EU through this new Directive. At stake are current corporate governance arrangements that have enshrined powerful norms regarding profit-maximization and shareholder primacy that can hinder the green transition. This inquiry aims to map, simplify and explain the vast and rapidly evolving EU regulatory landscape. Drawing on EU materials from 2018 to 2023, the article documents the ‘misunderstanding problem’ and the ‘incentives problem’ that create a dissonance between the legal norm advanced by company law and the business norm practiced by the corporate governance system. Currently mired by profound disagreements between the Commission and the Council, the EU has a rare opportunity to deliver an innovative and noteworthy reform of directors’ duties in company law by creating new legal and market incentives while remaining faithful to the core tenets of this body of law.
{"title":"Directors’ Duties During the Green Transition under EU Law","authors":"Radu Mares","doi":"10.36969/njel.v6i3.25717","DOIUrl":"https://doi.org/10.36969/njel.v6i3.25717","url":null,"abstract":"In response to the climate emergency, the European Union seeks to establish a new model of inclusive growth and depicts this shift as a ‘green, fair and competitive transition’. The article examines the EU sustainable corporate governance initiative commenced in 2018 that has crystalized after four years in a Commission’s proposal for a Directive on corporate due diligence, which is expected to be adopted by early 2024. The focus herein is on why and how directors’ duties under company law are being discussed and potentially reformed in the EU through this new Directive. At stake are current corporate governance arrangements that have enshrined powerful norms regarding profit-maximization and shareholder primacy that can hinder the green transition. This inquiry aims to map, simplify and explain the vast and rapidly evolving EU regulatory landscape. Drawing on EU materials from 2018 to 2023, the article documents the ‘misunderstanding problem’ and the ‘incentives problem’ that create a dissonance between the legal norm advanced by company law and the business norm practiced by the corporate governance system. Currently mired by profound disagreements between the Commission and the Council, the EU has a rare opportunity to deliver an innovative and noteworthy reform of directors’ duties in company law by creating new legal and market incentives while remaining faithful to the core tenets of this body of law.","PeriodicalId":489206,"journal":{"name":"Nordic journal of european law","volume":"63 5","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2023-10-31","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"135813557","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 : 2023-10-31DOI: 10.36969/njel.v6i3.25718
Snjólaug Árnadóttir
The international recognition of a universal right to a healthy environment is reaching its pinnacle. At least 156 States have recognised this right through the adoption of international treaties and 161 States have recognised it through their endorsement of UN General Assembly Resolution 76/300. While codified in several regional agreements, the right is not binding on all States through treaty law. The European Convention on Human Rights makes no explicit reference to the environment which might lead to the conclusion that States Parties are under no obligation to implement a right to a healthy environment into their domestic legal systems. However, the jurisprudence of the European Court of Human Rights indicates that this right may be a precondition to the enjoyment of other rights safeguarded by the Convention. Furthermore, it may be becoming universally binding as a standalone right under customary international law. This article concludes that various international obligations require States to ensure an explicit or implicit right to a healthy environment and that such a right should enjoy constitutional status. It explains that elements of the right may be implicitly embedded in constitutions even if they have no environmental provisions, as is the case of the Icelandic constitution. However, that is not an appropriate implementation of the standalone right to a healthy environment.
{"title":"International Obligations Calling for Constitutional Protection of the Right to a Healthy Environment","authors":"Snjólaug Árnadóttir","doi":"10.36969/njel.v6i3.25718","DOIUrl":"https://doi.org/10.36969/njel.v6i3.25718","url":null,"abstract":"The international recognition of a universal right to a healthy environment is reaching its pinnacle. At least 156 States have recognised this right through the adoption of international treaties and 161 States have recognised it through their endorsement of UN General Assembly Resolution 76/300. While codified in several regional agreements, the right is not binding on all States through treaty law. The European Convention on Human Rights makes no explicit reference to the environment which might lead to the conclusion that States Parties are under no obligation to implement a right to a healthy environment into their domestic legal systems. However, the jurisprudence of the European Court of Human Rights indicates that this right may be a precondition to the enjoyment of other rights safeguarded by the Convention. Furthermore, it may be becoming universally binding as a standalone right under customary international law. This article concludes that various international obligations require States to ensure an explicit or implicit right to a healthy environment and that such a right should enjoy constitutional status. It explains that elements of the right may be implicitly embedded in constitutions even if they have no environmental provisions, as is the case of the Icelandic constitution. However, that is not an appropriate implementation of the standalone right to a healthy environment.","PeriodicalId":489206,"journal":{"name":"Nordic journal of european law","volume":"57 4","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2023-10-31","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"135813972","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 : 2023-10-31DOI: 10.36969/njel.v6i3.25183
Jarne De Geyter
The Lisbon Treaty broadened and relaxed the standing requirements before the EU Court of Justice by adding a third class of acts amenable to judicial review. In the meantime, the EU has moreover been found in breach of the Aarhus Convention twice for shortcomings in access to justice for environmental organisations. Hence, the Aarhus Regulation, which implements the Aarhus Convention at Union level, was revised in 2021, and possible further amendments with regard to state aid decisions are being examined at the moment. The current standing requirements before the EFTA Court by contrast still reflect the situation prevailing in the European Union before those EU pillar evolutions. This article revisits four judgments of the EFTA Court in light of these developments and analyses how the EFTA Court has dealt with the existing discrepancies before, and might or might not be able to deal with them in the future.
{"title":"Revisiting the standing debate before the EFTA Court through the lens of post-Lisbon EU devlopments regarding locus standi","authors":"Jarne De Geyter","doi":"10.36969/njel.v6i3.25183","DOIUrl":"https://doi.org/10.36969/njel.v6i3.25183","url":null,"abstract":"The Lisbon Treaty broadened and relaxed the standing requirements before the EU Court of Justice by adding a third class of acts amenable to judicial review. In the meantime, the EU has moreover been found in breach of the Aarhus Convention twice for shortcomings in access to justice for environmental organisations. Hence, the Aarhus Regulation, which implements the Aarhus Convention at Union level, was revised in 2021, and possible further amendments with regard to state aid decisions are being examined at the moment. The current standing requirements before the EFTA Court by contrast still reflect the situation prevailing in the European Union before those EU pillar evolutions. This article revisits four judgments of the EFTA Court in light of these developments and analyses how the EFTA Court has dealt with the existing discrepancies before, and might or might not be able to deal with them in the future.","PeriodicalId":489206,"journal":{"name":"Nordic journal of european law","volume":"197 ","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2023-10-31","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"135870762","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 : 2023-10-31DOI: 10.36969/njel.v6i3.25719
Arnljotur Astvaldsson
Since the beginning of the new millennium, the landscape of cross-border commerce has been altered significantly, with more and more individuals having the possibility to engage in commercial activities online, for example through so-called online platforms. This has led to the EU legislator undertaking legislative activities in the field, aimed at creating a safer environment for online commerce and enhancing the internal market. This article discusses the legislation in question in relation to a certain group of economic actors, namely those that operate in the grey area between acting for purely private, non-professional, purposes and those engaging in commerce as a part of a business for professional purposes. The article discusses the way in which EU legislation, applicable to online commerce, draws the line between non-professional and professional actors, in particular with regard to ascertaining the legal position of actors that find themselves on the borderline between professional and non-professional actors, referred to as participants in the gig economy.
{"title":"The Lost Traders?","authors":"Arnljotur Astvaldsson","doi":"10.36969/njel.v6i3.25719","DOIUrl":"https://doi.org/10.36969/njel.v6i3.25719","url":null,"abstract":"Since the beginning of the new millennium, the landscape of cross-border commerce has been altered significantly, with more and more individuals having the possibility to engage in commercial activities online, for example through so-called online platforms. This has led to the EU legislator undertaking legislative activities in the field, aimed at creating a safer environment for online commerce and enhancing the internal market. This article discusses the legislation in question in relation to a certain group of economic actors, namely those that operate in the grey area between acting for purely private, non-professional, purposes and those engaging in commerce as a part of a business for professional purposes. The article discusses the way in which EU legislation, applicable to online commerce, draws the line between non-professional and professional actors, in particular with regard to ascertaining the legal position of actors that find themselves on the borderline between professional and non-professional actors, referred to as participants in the gig economy.","PeriodicalId":489206,"journal":{"name":"Nordic journal of european law","volume":"59 11","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2023-10-31","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"135813435","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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