Current Splitting Research Articles

Induced Current Pharmacological Split Stimulation System for Neuronal Networks

Magnetic stimulation noninvasively modulates neuronal activity through a magnetically induced current. However, despite the usefulness and popularity of this method, the effects of neuronal activity in the nonstimulated regions on the stimulus responses are unknown. Here, we report that the induced current-evoked responses were affected by neuronal activities in the nonstimulated regions. Our experiment used a Mu-metal-based localized induced current stimulation (LICS) system combined with the microfabricated cell culture chamber system and a microelectrode array (MEA). The cell culture chamber system has radiating microtunnels connecting one central and eight outer chambers, which were fabricated using soft lithography and a replica modeling technique with SU-8 photoresist and polydimethylsiloxane (PDMS). Rat cortical neurons were separately cultured in the chambers and formed functional synaptic connections through the microtunnels. By applying a biphasic alternating pulsed magnetic field to the Mu-metal located in the central chamber, induced currents were mainly generated near the cultured neurons and modified the neuronal activities, which were recorded through MEA. Furthermore, we confirmed that the evoked responses were modified by localized pharmacological stimulation (LPS) in the outer chambers. These results suggest that our system would be promising tool for analyzing the effect of magnetic stimulation on interacting neuronal activity.

Experimental observations of the splitting of a gravity current at a density step in a stratified water body

AbstractWhen a gravity current reaches the level of neutral buoyancy in a stratified water body it can separate from the sloping boundary as an intrusion. If there is a density gradient within the gravity current, then multiple intrusions can form in the stratified water body. Using a series of laboratory experiments in a two‐layered ambient stratification, we document how a gravity current splits in two upon reaching the sharp density step. Our laboratory observations stress the significance of the densimetric Froude number of the gravity current (Fr), as well as a measure of the ambient stratification (density Richardson number, Riρ), on determining how a gravity current intrudes into a two‐layered stratified ambient water. Gravity currents are more likely to detrain into two parts at a density step when they have a diffuse density interface (Fr > 1). However, gravity currents tend to intrude as a single intrusion when they have a sharp, more step‐like density profile (Fr < 1). Using details of the internal structure of the gravity current, we develop a theory to predict the partition of the buoyancy flux into the interflow and underflow when the gravity current splits at the density step. Our predictions of buoyancy portions are in agreement with our experimental observations. We discuss when the application of our equations will be relevant for river intrusions into reservoirs, and for gravity currents in the stratified ocean.

Predicting the use of public transportation: a case study from Putrajaya, Malaysia.

Putrajaya is a new federal administrative capital of Malaysia which has been set to achieve a 70% share of all travels by public transport in the city area. However, the current modal split between the public transport and private transport is 15 : 85. In order to understand travelers' willingness to use the public transport, a conceptual model has been developed to determine the factors that affect them to use the public transport instead of travelling in their own cars. Various variables such as service quality, environmental impact, attitude, and behavior intention were analyzed and tested using structural equation model (SEM). Results indicate that the service quality and attitude are found to have positive effects on the behavioral intention of taking the public transport. Other than this, this study also shows that the service quality and environmental impact have some positive influences on the attitude to using the public transport. However, environmental impact has no significant, positive, and direct effect on behavioral intention. The results of this study demonstrate that the model that was developed is useful in predicting the public transport and it could provide a more complete understanding of behavioral intention towards public transport use.

The NHS Information Revolution: ‘Choice of Control’ to ‘Choice’ and ‘Control’

This paper provides a novel and critical analysis of the necessary and important balance between ‘individual privacy’ and ‘collective transparency’. We suggest that the onset of the Information Revolution has created a dilemma for the National Health Service (NHS) in terms of how it addresses its obligation to use information to improve best practice in healthcare for society (‘collective transparency’) whilst also keeping sensitive personal information confidential (‘individual privacy’). There is clearly a need to consider both whether the NHS is balancing this critically important informational relationship and whether its approach is fit for purpose. We argue that the NHS's ‘proxy-individual’ information guardian role could inadvertently mask individuals' intended roles, effectively circumventing autonomy-based laws by limiting the power of individuals to be autonomous. In this article we have identified three issues – first the prevailing ‘Mindset’ (the ‘M’) of ‘privacy’, which is viewed as individualistic, resulting in an overpowering concept of confidentiality; second, the quality and control of Information (the first ‘I’); and third, the concept of innovation (the second ‘i’), which is being used as a ‘solution’ rather than a vehicle for transparency. Indeed, transparency is our target of ‘best practice,’ and we suggest that individual privacy and collective transparency are best embedded within a complementary privacy framework that offers a better fit than the current split of control between the roles of the NHS and the roles of the individual. It is suggested that when facilitated by transparency, ‘control’ and ‘privacy’ form a continuum, aligning through the desire for choice. Therefore, the choice of control could facilitate control and choice. Together, they could replace the concept of privacy by empowering ‘informed patients’ to support the NHS's ‘No decision about me, without me’ pledge.

Kesan Masa Perjalanan Bas dan Bayaran Tempat Letak Kereta Terhadap Penggunaan Pengangkutan Awam di Putrajaya

Putrajaya is a unique Malaysian city from a transport policy perspective because of its explicit goal to achieve a 70% share of public transport to its core areas. However, the current modal split between public transport and private transport is 15:85. One possible way to reduce the use of cars is to promote people to use public transport as a primary mode of transport. In order to evaluate the effects of this measure, data were collected from the workers who travel by car to work place in Putrajaya. A total of 290 respondents completed a questionnaire with a response rate of 58% (out of 500 distributed questionnaires). Logistic regression method has been used to analyze the factors that influence users to switch their trips mode to shift to public transport. It is concluded that with reducing the bus travel time and implementing parking fee will directly affect the use of the public transport facility.

The Impact of Racial and Sexual Politics on Women's History

Cornelia H. Dayton and Lisa Levenstein have done a brilliant job corralling recent publications in U.S. women’s and gender history under a big tent. Focusing on scholarship published in the last ten years that “reconceives gender” and/or rewrites mainstream historical narratives, Dayton and Levenstein point to new directions and challenge readers to consider the future of U.S. women’s and gender history. They open their essay by contrasting the current generational splits among feminist activists with the relative unity among scholars of women’s and gender history and remind us of the field’s long and deep connections to feminist politics. Noting the dynamic relationship between women’s and gender history and feminist politics, they convincingly argue that the simultaneous explication of race and gender has produced radical questions about intersectionality, relational differences among and between women, overlapping constructions of sexuality and gender, and the unfixed relationship between gender identity and sex. Yet Dayton and Levenstein say very little about the racial and sexual politics of the late twentieth century that provoked radical changes in the field of women’s and gender history. Understanding the emergence of the new scholarship that Dayton and Levenstein highlight is difficult without serious consideration of the political crisis that provoked women’s and gender historians to rethink issues of “intersectionality”: the idea that “emphasiz[es] that race and gender were not experienced separately and thus could not be analyzed independently of each other.” Acknowledging the political origins of this new literature provides a fuller picture of how the field has evolved over the last five decades. Moreover, the scholarship of the last ten years reflects not only an engagement with the sexual and racial politics of the late twentieth century but also a radical shift in the field of women’s and gender history that began in the 1990s. For decades, women of color in various disciplines and women’s historians working in the fields of African American, southern, and labor history had been quietly insisting on the significance of examining race and gender together. The racialized gender politics of the Ronald Reagan–George H. W. Bush era finally forced feminist scholars to insist that

United States V. Liddell: 8th Circuit Precedent at the Forefront of the Circuit Split Over the Quarles Public Safety Exception

The Eighth Circuit case of United States v. Liddell established a broader perspective of the 'public safety exception' to the Miranda requirement, which should be adopted universally. In Liddell, the court decided the Miranda requirement did not apply and allowed statements made by a suspect prior to his Miranda warning into evidence. The Liddell court held a sufficient public safety basis existed when there was a risk of police officers being injured from the mishandling of unknown firearms or drug paraphernalia. Specifically, the Liddell court allowed the police to ask a suspect, who had been arrested and secured, whether there were weapons or contraband in the car or apartment the police were about to search. In determining the outcome, the court broadened the existing exception to Miranda as established by the United States Supreme Court 28 years ago in the case of New York v. Quarles.One controversial aspect of the Liddell case is whether broadening the exception created by the plurality opinion of Quarles violates Miranda’s constitutional requirements. Recently noted by the District of New Jersey case of United States v. Fautz, the 8th Circuit is the only federal circuit to expressly hold such an exception exists. An additional aspect of this case is whether the circuit split developing among the federal circuits makes this issue likely to be addressed by the Supreme Court. The current split involves the 8th, 9th, and 1st Circuits taking a broad approach to the public safety exception, while the 3d, 4th and 5th Circuits take a narrow approach.This Article provides an analysis of the issues in Liddell and concludes the 8th Circuit arrived at a constitutionally permissible holding. The Supreme Court should follow the 8th Circuit broad approach to the public safety exception. Three points support the broad approach to the public safety exception: the necessity for public safety; the long-standing precedent set forth by Quarles over 28 years ago; and the rationale for police action during a kidnap scenario.The Supreme Court should adopt the 8th Circuit’s broad approach to the public safety exception. Specifically, the Court should hold the Miranda requirement does not apply when there is a risk of police officers being injured from the mishandling of unknown firearms or drug paraphernalia, and the risk provides a sufficient public safety basis to ask a suspect who has been arrested and secured whether there are weapons or contraband in a car or apartment the police are about to search.

Section of thermohaline circulation driven by transient current rings

The southward branch of the Atlantic Meridional Overturning Circulation (AMOC), the stretch that carries deep, cold water from the North Atlantic to the Southern Ocean, predominantly flows along the eastern shoreline of the Americas. This deep water transport, known as the Deep Western Boundary Current, hits a fork in the flow at 25°S, off the coast of Brazil. Here the current splits in two, with the majority continuing its southbound journey and a smaller ribbon veering to the east. This eastbound water travels at depth across the South Atlantic, eventually passing around Africa's southern coast. In its path from Brazil to Africa the water crosses lines of consistent vorticity—essentially traveling uphill. Though researchers have known of this current for decades, little is known of what drives it.

'Final' Awards Reconceptualized: A Proposal to Resolve the Hall Street Circuit Split

This article discusses the current circuit split over the continued validity of manifest disregard of the law (“manifest disregard”) as a nonstatutory ground for vacatur of arbitration awards under the Federal Arbitration Act (“FAA”). Today, as commercial parties decide whether to include arbitration agreements in their business contracts, they weigh the risks of proceeding to arbitration versus litigation to resolve their disputes. This topic is especially pertinent in light of the current economic climate. Dicta from the U.S. Supreme Court’s decision in Hall Street Associates, L.L.C. v. Mattel, Inc. called into question the continued validity of nonstatutory grounds for vacatur. The circuit courts have severely split on the question of one ground in particular: manifest disregard. Although seemingly ripe for review, the Supreme Court has appeared reluctant to resolve the issue, even side-stepping the Second Circuit’s opinion in Stolt-Nielsen S.A. v. AnimalFeeds International Corp. and ruling on other grounds. Rather than opining on which side of the split should prevail, this article posits first that manifest disregard should never have been a valid ground for vacatur under the FAA. Next, the article takes a historical perspective that shows the FAA does not allow courts to look at the merits of an arbitration award. Instead, courts should look only to the award itself, determining its enforceability exclusive of the merits of the arbitrator’s or tribunal’s decision. Inquiry into the merits of the decision violates the FAA and damages arbitration’s finality and efficiency, two of the most important benefits of the arbitration bargain. Excluding the merits from judicial review conforms to FAA requirements and retains these two critical benefits. In other words, this article proposes a resolution to the circuit split that maintains the integrity of both the FAA and the arbitration process without excluding concerns surrounding a full abandonment of judicial review.

Affum v. United States: Expanding the Three-Way Circuit Split on Judicial Review of USDA’s Choice of Penalties for Food Stamp Trafficking

The Food Stamp Act allows retail stores and food wholesalers authorized by the Secretary of Agriculture to participate in the Food Stamp Program and accept food stamps as payment instead of cash for qualifying food products. If the Secretary finds that a food stamp merchant — or their employee — has trafficked in food stamps, the Secretary may permanently disqualify the merchant from accepting food stamps. But the Secretary also has “discretion” to impose a civil monetary penalty (CMP) of up to $54,000 in lieu of permanent disqualification if the Secretary finds “significant evidence” that the merchant had effective policies in place to prevent food stamp violations. The Act establishes a statutory right to judicial review of the Secretary’s decision to impose disqualification or a civil penalty, and according to the Act, that review is by “trial de novo . . . in which the court . . . determine[s] the validity of the questioned administrative action in issue . . . .” In Affum v. United States, a food stamp merchant whose sole part-time employee exchanged food stamps for $30 cash was found by the Secretary to have trafficked in food stamps. Affum challenged the Secretary’s decision to permanently disqualify her rather than impose a fine, but the district court denied her request for injunctive relief and did not reach the merits of her claim after it held, in part, that she did not have standing to challenge the Secretary’s decision. Appealing that decision, Affum did not dispute whether her employee engaged in food stamp trafficking. Rather, she asserted, inter alia, that not only was the Secretary’s decision of whether to punish a merchant reviewable de novo, but the Secretary’s choice of punishments is also reviewable de novo. The D.C. Circuit reversed the district court’s finding that Affum did not have standing and remanded the case for de novo review of the administrative proceeding. To guide the district court on which was the proper standard of review to apply, the circuit court found that “nothing in the Act suggest[s] that trials de novo relating to ‘administrative action[s] in issue’ are limited solely to review of determinations that a trafficking action occurred.” Nevertheless, it held that because Congress amended the Act in 1988 to give the Secretary “discretion” in choosing the appropriate penalty for trafficking, it “meant to impose different standards of review for a judicial action challenging the agency’s finding of a violation as opposed to a judicial action challenging the Secretary’s choice of penalty.” Thus, the D.C. Circuit held that though plaintiffs are entitled to de novo review of whether a violation occurred, the Secretary’s choice of penalties under 7 U.S.C. § 2021(b)(3)(B) is reviewable under an arbitrary and capricious standard. In reaching this conclusion, the D.C. Circuit joined in the current three-way circuit split over which standard of judicial review should apply to the Secretary of Agriculture’s choice of penalties for food stamp merchants. The D.C. Circuit’s position — that the penalty is reviewable under an arbitrary and capricious standard — is consistent with that held by the Fourth and Ninth Circuits. The Eighth Circuit, however, holds that the Secretary’s choice of penalties is reviewable de novo, and the Sixth Circuit holds that the Secretary’s choice is not reviewable. This comment examines the three-way circuit split, argues that the arbitrary and capricious standard is correct, and recommends that either the Supreme Court should adopt the majority rule or Congress should amend § 2023(a) to expressly provide that the Secretary’s choice of penalty is reviewable under the Administrative Procedure Act’s arbitrary and capricious standard of review. Section I reviews the Food Stamp Act and why Congress amended it to grant the Secretary discretion to impose a civil monetary penalty in lieu of permanent disqualification for trafficking offenses. Section II briefly reviews standards of review of administrative agency actions. Section III analyzes the circuit split at issue by examining cases from the Fourth, Sixth, Eighth, Ninth, and D.C. Circuits. Finally, Section IV suggests how the Supreme Court or Congress could mend the three-way circuit split over judicial review of the Secretary’s choice of penalties under § 2021.

Can rating agencies look through the cycle?

Rating agencies claim to look through the cycle when assigning corporate credit ratings, which entails that they are able to separate trend components of default risk from transitory ones. To test whether agencies possess this competence, I take market-based estimates of 1-year default probabilities of corporate bond issuers and estimate their long-run trend using the Hodrick-Prescott filter, local regression, or centered moving averages. I find that ratings help identify the current split into trend and cycle. In addition, rating stability is similar to the one of hypothetical ratings based on long-term trends. The results are robust to the use of different filter techniques. They are confirmed by a model-free analysis, which shows that ratings predict future changes in market-based default probability estimates. Since the examined trends are forward-looking in the sense that the trend filtering algorithms use future data, agency ratings exhibit important characteristics one would expect from ratings that see through the cycle.

Ion diode logics for pH control

Electronic control over the generation, transport, and delivery of ions is useful in order to regulate reactions, functions, and processes in various chemical and biological systems. Different kinds of ion diodes and transistors that exhibit non-linear current versus voltage characteristics have been explored to generate chemical gradients and signals. Bipolar membranes (BMs) exhibit both ion current rectification and water splitting and are thus suitable as ion diodes for the regulation of pH. To date, fast switching ion diodes have been difficult to realize due to accumulation of ions inside the device structure at forward bias--charges that take a long time to deplete at reverse bias. Water splitting occurs at elevated reverse voltage bias and is a feature that renders high ion current rectification impossible. This makes integration of ion diodes in circuits difficult. Here, we report three different designs of micro-fabricated ion bipolar membrane diodes (IBMDs). The first two designs consist of single BM configurations, and are capable of either splitting water or providing high current rectification. In the third design, water-splitting BMs and a highly-rectifying BM are connected in series, thus suppressing accumulation of ions. The resulting IBMD shows less hysteresis, faster off-switching, and also a high ion current rectification ratio as compared to the single BM devices. Further, the IBMD was integrated in a diode-based AND gate, which is capable of controlling delivery of hydroxide ions into a receiving reservoir.

A novel low voltage very low power CMOS class AB current output stage with ultra high output current drive capability

In this paper a novel low voltage (LV) very low power (VLP) class AB current output stage (COS) with extremely high linearity and high output impedance is presented. A novel current splitting method is used to minimize the transistors gate–source voltages providing LV operation and ultra high current drive capability. High linearity and very high output impedance are achieved employing a novel resistor based current mirror avoiding conventional cascode structures to be used. The operation of the proposed COS has been verified through HSPICE simulations based on TSMC 0.18μm CMOS technology parameters. Under supply voltage of ±0.7V and bias current of 5μA, it can deliver output currents as high as 14mA with THD better than −53dB and extremely high output impedance of 320MΩ while consuming only 29μW. This makes the proposed COS to have ultra large current drive ratio (Ioutmax/Ibias or the ratio of peak output current to the bias current of output branch transistors) of 2800. By increasing supply voltage to ±0.9V, it can deliver extremely large output current of ±24mA corresponding to 3200 current drive ratio while consuming only 42.9μW and exhibiting high output impedance of 350MΩ. Interestingly, the proposed COS is the first yet reported one with such extremely high output current and a THD even less than −45dB. Such ultra high current drive capability, high linearity and high output impedance make the proposed COS an outstanding choice for LV, VLP and high drive current mode circuits. The superiority of the proposed COS gets more significance by showing in this work that conventional COS can deliver only ±3.29mA in equal condition. The proposed COS also exhibits high positive and negative power supply rejection ratio (PSRR+/PSRR−) of 125dB and 130dB, respectively. That makes it very suitable for LV, VLP mixed mode applications. The Monte Carlo simulation results are provided, which prove the outstanding robust performance of the proposed block versus process tolerances. Favorably the proposed COS resolves the major limitation of current output stages that so far has prevented designing high drive current mode circuits under low supply voltages. In brief, the deliberate combination of so many effective novel methods presents a wonderful phenomenal COS block to the world of science and engineering.

Model of resistances in systems of Tomonaga-Luttinger liquid wires

In a recent paper, we combined the technique of bosonization with the concept of a Rayleigh dissipation function to develop a model for resistances in one-dimensional systems of interacting spinless electrons [Europhys. Lett. 93, 57007 (2011)]. We also studied the conductance of a system of three wires by using a current splitting matrix $M$ at the junction. In this paper, we extend our earlier work in several ways. The power dissipated in a three-wire system is calculated as a function of $M$ and the voltages applied in the leads. By combining two junctions of three wires, we examine a system consisting of two parallel resistances. We study the conductance of this system as a function of the $M$ matrices and the two resistances; we find that the total resistance is generally quite different from what one expects for a classical system of parallel resistances. We do a sum over paths to compute the conductance of this system when one of the two resistances is taken to be infinitely large. We study the conductance of a three-wire system of interacting spin-1$/$2 electrons, and show that the charge and spin conductances can generally be different from each other. Finally, we consider a system of two wires that are coupled by a dissipation function, and we show that this leads to a current in one wire when a voltage bias is applied across the other wire.

Effect of thermoelectric current splitting on the magnetic topology in DIII-D

An extended model is proposed to describe the magnetic topology during appearance of edge localized modes (ELMs). It is applied to an ELMing H-mode in a lower single null discharge at DIII-D [J. L. Luxon, Nucl. Fusion 42, 614 (2002)]. The process of flux tube formation is discussed based on a previously proposed two-step model. Large currents, as found in measurements in DIII-D, are assumed running through newly formed large flux tubes. Two different realizations of the current distribution within the tubes are compared, namely a single filament in each tube and a scenario where the current in each tube is split into subfilaments. The latter scenario is shown to be the more realistic distribution because it leads to much better agreement with infrared camera observations. It is demonstrated that stripe patterns in the divertor heat flux produced by an ELM in the DIII-D tokamak can be reproduced numerically by taking into account the magnetic perturbation caused by the thermoelectric current subfilaments.

Unequal Application of RLUIPA's 'Equal Terms' Provision

This Comment addresses the current split between the United States Court of Appeals for the Eleventh Circuit, the Third Circuit, and, most recently, the Seventh Circuit regarding the equal terms provision of the Religious Land Use and Institutionalized Persons Act (RLUIPA). The equal terms provision is within the land use provisions of RLUIPA. Even though these land use provisions implicate important issues, such as the extent to which state and local governments can exclude religious establishments from commercial districts, the United States Supreme Court has not addressed the equal terms provision. Since the Supreme Court has not addressed the issue, lower federal courts are left to rely upon their own case by case analysis without any guidance from the Court. The recent three way split among the circuits shows that, not only are lower federal courts interpreting the equal terms provision differently, but that the Supreme Court should address this RLUIPA provision to avoid more confusion among circuits.The equal terms provision of RLUIPA provides that the government cannot prefer secular institutions or assemblies over religious assemblies when dealing with land use regulations. Courts’ interpretation of this provision, regardless of its scope, affects the ability of religious institutions to locate in densely populated areas and convenient locations. As many cities attempt to revitalize the economies of urban districts and engage in city projects to increase commercial activity and city productivity, the equal terms provision interpretations are becoming more important. For example, in New York, the zoning commission recently refused to allow a religious institution to build in a particular zone stating that the issue was the traffic and other half was the church’s tax exempt status. Although a few articles have been written on the split between the Eleventh and Third Circuit, the recent Seventh Circuit’s choice to deviate from both circuits’ standards and create its own for interpreting the equal terms provision further shows that the Supreme Court must address this important provision. The lack of governing precedent on the issue has led to a doctrinal circuit split between the Eleventh, Third, and Seventh Circuits. The circuits have differing interpretations as to the meaning of the equal terms provision and disagree as to what standard of should be used when deciding whether a secular institution (or assembly) is treated more favorably than a religious institution (or assembly). Further, the circuits also differ as to what of scrutiny should be applied when local and state governments implement regulations that favor secular institutions or assemblies over religious ones. This Comment argues that the United States Supreme Court should address and interpret the equal terms provision of RLUIPA, and recommends an the Court should adopt. Specifically, it recommends that the Eleventh Circuit’s should be adopted. Further, it discusses the Eleventh, Third, and Seventh Circuit approaches. The analysis of the Seventh Circuit is in-depth, and most critiqued, since it was only recently articulated in July 2010. The Author argues for the adoption of the Eleventh Circuit to the of for determining whether a secular assembly is treated more favorably than a religious one, and that the Eleventh Circuit’s level of scrutiny that federal courts should apply to governmental regulations favoring secular assemblies should be adopted. The Eleventh Circuit’s comparison by category approach allows for protection of religious establishments from discrimination, and also further congressional intent behind the equal terms provision. Moreover, the Third and Seventh Circuit approaches allows creators of land use regulations to manipulate these regulations in ways in a way the permit discriminatory land use provisions that should be invalidated under RLUIPA. Further, the Eleventh Circuit’s strict scrutiny requirement is preferable to the other circuits’ scrutiny levels, because it allows the occasional statute truly designed to further a compelling governmental interest to survive an equal terms provision challenge.This Comment first outlines Supreme Court religious exercise jurisprudence prior to RLUIPA’s enactment. Next, it discusses RLUIPA and its relevant portions, and addresses the different approaches from the Eleventh, Third, and Seventh Circuits. Then, it discusses why the Eleventh Circuit is preferable to the Third and Seventh Circuit approaches. Finally, it explains why a Supreme Court precedent on this issue, regardless of which is chosen, is imperative.

Giving Arbitration Some Credit: The Enforceability of Arbitration Clauses Under the Credit Repair Organizations Act

This Student Note addresses the unresolved question of the enforceability of arbitration agreements under the Credit Repair Organizations Act. While the Third and Eleventh Circuits have enforced such agreements, finding that the CROA does not preclude arbitration, the Ninth Circuit has refused to enforce these arbitration clauses, finding that the CROA entitles plaintiffs to a judicial forum. This conflict arises against a backdrop of debate over mandatory arbitration agreements between consumers and businesses. Scholars and legislators alike have argued that such agreements are unjust. A refusal to enforce such agreements, however, would fly in the face of the Supreme Court’s clear mandate to lower courts to enforce arbitration agreements. This Note examines the current circuit split over the enforceability of arbitration agreements under the Credit Repair Organizations Act in the context of both consumer protection law and relevant arbitration jurisprudence. Part I discusses the development of consumer protection law and the enactment of the Credit Repair Organizations Act, and examines the statute in detail. Part II describes the history and procedure of arbitration and examines the development of the Supreme Court’s policy regarding arbitration. Part III then analyzes the circuit split over the enforceability of arbitration agreements under the Credit Repair Organizations Act and the arguments for and against enforcing mandatory consumer arbitration clauses. Part IV advocates for the enforcement of such arbitration agreements, presenting several reasons why consumers will not be harmed by the enforcement of such agreements. Finally, Part IV proposes a simple solution to the problem: the elimination of credit repair organizations.

Predictive Control of Voltage and Current in a Fuel Cell–Ultracapacitor Hybrid

This paper presents a system integration and control strategy for managing power transients on a Nexa polymer electrolyte membrane fuel cell (FC) with the assistance of an ultracapacitor (UC) module. The two degrees of freedom provided by the use of two dc/dc converters enable the independent low-level control of dc bus voltage and the current split between the FC and UC. The supervisory-level control objectives are to respond to rapid variations in load while minimizing damaging fluctuations in FC current and maintaining the UC charge (or voltage) within allowable bounds. The use of a model predictive control approach which optimally balances the distribution of power between the FC and UC while satisfying the constraints is shown to be an effective method for meeting the supervisory-level objectives. The results are confirmed in experiments.

Power dissipation for systems with junctions of multiple quantum wires

We study power dissipation for systems of multiple quantum wires meeting at a junction, in terms of a current splitting matrix (M) describing the junction. We present a unified framework for studying dissipation for wires with either interacting electrons (i.e., Tomonaga-Luttinger liquid wires with Fermi liquid leads) or non-interacting electrons. We show that for a given matrix M, the eigenvalues of M^T M characterize the dissipation, and the eigenvectors identify the combinations of bias voltages which need to be applied to the different wires in order to maximize the dissipation associated with the junction. We use our analysis to propose and study some microscopic models of a dissipative junction which employ the edge states of a quantum Hall liquid. These models realize some specific forms of the M-matrix whose entries depends on the tunneling amplitudes between the different edges.

Synchronization of multiple coupled rf-SQUID flux qubits

A practical strategy for synchronizing the properties of compound Josephson junction (CJJ) radio frequency monitored superconducting quantum interference device (rf-SQUID) qubits on a multi-qubit chip has been demonstrated. The impact of small (∼1%) fabrication variations in qubit inductance and critical current can be minimized by the application of a custom-tuned flux offset to the CJJ structure of each qubit. This strategy allows for a simultaneous synchronization of the qubit persistent current and tunnel splitting over a range of external bias parameters that is relevant for the implementation of an adiabatic quantum processor.