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"Liang, Amy"
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Property Versus Antidiscrimination
The Fair Housing Act is a groundbreaking federal law enacted in 1968 during the civil rights movement. Reflecting a policy judgment that the public's interest in eliminating housing discrimination outweighs a prejudicial landlord's property right to exclude, it prohibits landlords from rejecting tenants on a discriminatory basis. However, as the Act's promises remain in the process of fulfillment, the Supreme Court's 2021 decision in Cedar Point Nursery v. Hassid has placed it into unprecedented danger: by holding that a regulation authorizing temporary occupations of private property constituted a per se taking that requires compensation under the Takings Clause, Cedar Point threatens the constitutionality of the Act, which grants tenants a similar temporary right to access rental properties.
This Comment takes up the task of finding an escape valve for the Act within the current legal landscape. Looking to Cedar Point's Court-created exceptions, this Comment argues that the Act should fall under the \"open to the public\" exception because case law, common law considerations, and the normative value in preserving an important antidiscrimination law all support a finding that the Act regulates the business of offering dwelling rentals, a type of business open to the public.
Journal Article
The Effects of Visual and Verbal Coding Mnemonics on Learning Chinese Characters in Computer-Based Instruction
The effects of different approaches to learning Chinese characters were investigated. Ninety-two high-school students were randomly assigned to one of five treatment groups: translation, verbal mnemonics, visual mnemonics, dual coding mnemonics, or self-generated mnemonics. All groups received instruction and completed posttests in a computer-based environment. The results indicate that participants who generated their own mnemonics demonstrated higher posttest performance than those in visual coding, verbal coding, and translation groups; subjects in the dual coding group scored higher than those in the translation group. Those who generated their own mnemonics spent more time on task than any other group, and those in the verbal coding group took more time than those in the translation group. Survey and qualitative data suggest that learners' interpretations of the Chinese characters were rooted in their cultural backgrounds and personal experiences.
Journal Article
A lipid atlas of human and mouse immune cells provides insights into ferroptosis susceptibility
The cellular lipidome comprises thousands of unique lipid species. Here, using mass spectrometry-based targeted lipidomics, we characterize the lipid landscape of human and mouse immune cells (
www.cellularlipidatlas.com
). Using this resource, we show that immune cells have unique lipidomic signatures and that processes such as activation, maturation and development impact immune cell lipid composition. To demonstrate the potential of this resource to provide insights into immune cell biology, we determine how a cell-specific lipid trait—differences in the abundance of polyunsaturated fatty acid-containing glycerophospholipids (PUFA-PLs)—influences immune cell biology. First, we show that differences in PUFA-PL content underpin the differential susceptibility of immune cells to ferroptosis. Second, we show that low PUFA-PL content promotes resistance to ferroptosis in activated neutrophils. In summary, we show that the lipid landscape is a defining feature of immune cell identity and that cell-specific lipid phenotypes underpin aspects of immune cell physiology.
Morgan, Pernes and colleagues perform mass spectrometry-based targeted lipidomics and provide a comprehensive lipid profile of human and mouse immune cells, which they then show confer differential ferroptosis susceptibilities.
Journal Article
Characterization of a high-intensity band that cross-reacts with FLAG-M2 antibodies in immunoblots in a subset of laboratory strains of Saccharomyces cerevisiae
Epitope tags are commonly used for various purposes in research labs. The DYKDDDDK-peptide epitope, trademarked as the FLAG epitope, is a commonly used epitope tag. It is often used for monitoring protein levels and for affinity chromatography. Multiple DYKDDDDK-binding antibodies are available; however, the mouse monoclonal anti-FLAG M2 is widely used due to its commercial availability in several formats. Many laboratory
strains, including the BY4741 strain that was used in multiple systematic deletion and tagging libraries, have a high-intensity band that cross-reacts with the FLAG-M2 antibody. The presence of this high-intensity cross-reactive band can be problematic in some applications. Here, we show that despite high-intensity in immunoblots, the cross-reacting band is not enriched by FLAG-M2 affinity beads under native conditions. We also report the fortuitous identification of a strain closely related to BY4741 that lacks the high-intensity cross-reactive band. Finally, contrary to anecdotal reports, we determined that the high-intensity cross-reacting band is not Rtf1. These findings and resources should assist other researchers using the DYKDDDDK-epitope for immunoblots and affinity chromatography.
Journal Article
THE RETURN OF THE PLAGUE: INEQUITABLE CONDUCT AFTER REGENERON V. MERUS
In July 2017, the Federal Circuit decided Regeneron Pharmaceuticals Inc. v. Merus, where a split panel upheld the district court's decision to infer prosecution misconduct by Regeneron based on its subsequent litigation misconduct during the patent case, thus holding its patent unenforceable based on the doctrine of inequitable conduct. The decision raises new questions regarding the relevance of litigation misconduct to the unenforceability of a patent, which has traditionally been determined based upon evidence of misconduct before the U.S. Patent and Trademark Office (i.e., pre-litigation misconduct). The Regeneron decision also raises new questions regarding the standard of proof needed to establish inequitable conduct as a defense to patent infringement. In 2011, the Federal Circuit raised the bar for proving inequitable conduct in Therasense, Inc. v. Becton, Dickinson & Co., where an en banc panel held that clear and convincing evidence was needed to prove intent to deceive the USPTO, and that intent to deceive cannot be inferred by proving other elements of the defense. Prior to Therasense, claims of inequitable conduct were once so prevalent that the court wrote that the defense had \"become an absolute plague\" on patent litigation. By indicating that it is willing to consider litigation misconduct to infer a finding of inequitable conduct, the Federal Circuit appears to have expanded the scope of the doctrine, which may encourage defendants to raise inequitable conduct as a defense. If subsequent cases follow this expanded theory, the consequences could be far-reaching, exposing patent holders to a new wave of inequitable conduct charges. This Article examines the effect of Regeneron on the inequitable conduct defense and further discusses considerations for practitioners in light of the Federal Circuit's opinion in Regeneron.
Journal Article
The potential impact of Life Tech v. Promega
[...]the amicus brief argued that expanding the extraterritorial scope of U.S. patent law impinged on foreign states' interests in permitting use of imported goods to assemble inventions that are not protected by patents outside of the United States. [...]the government argued the practical difficulties of applying the Federal Circuit's qualitative rule weigh against upholding that ruling.
Journal Article
Modified shock index and mortality rate of emergency patients
BACKGROUND:This study aimed to determine whether modified shock index(MSI)is associated with mortality that is superior to heart rate,blood pressure,or the shock index(SI).in emergency patients.METHODS:A retrospective database review was performed on 22 161 patients who presented to Peking Union Medical College Hospital Emergency Department and received intravenous fluids from January 1 to December 31,2009.We gathered data of the patients on age,gender,vital signs,levels of consciousness,presenting complaints,and SI and MSI were calculated for all patients.RESULTS:Multivariate regression analysis was performed to determine the correlation between risk factors and outcome.There is a significant correlation between emergency patient mortality rate and patient’s vital signs obtained at the triage desk(HR>120 beats/min,systolic BP<90 mmHg,diastolic BP<60 mmHg).MSI is a stronger predictor of emergency patient mortality compared to heart rate and blood pressure alone,whereas SI does not have a significant correlation with emergency patient mortality rate.CONCLUSION:MSI is a clinically significant predictor of mortality in emergency patients.It may be better than using heart rate and blood pressure alone.SI is not significantly correlated with the mortality rate of the emergency patient.
Journal Article
THE RETURN OF THE PLAGUE: INEQUITABLE CONDUCT AFTER REGENERON V. MERUS
In July 2017, the Federal Circuit decided Regeneron Pharmaceuticals Inc. v. Merus, where a split panel upheld the district court's decision to infer prosecution misconduct by Regeneron based on its subsequent litigation misconduct during the patent case, thus holding its patent unenforceable based on the doctrine of inequitable conduct. The decision raises new questions regarding the relevance of litigation misconduct to the unenforceability of a patent, which has traditionally been determined based upon evidence of misconduct before the U.S. Patent and Trademark Office (i.e., pre-litigation misconduct). The Regeneron decision also raises new questions regarding the standard of proof needed to establish inequitable conduct as a defense to patent infringement. In 2011, the Federal Circuit raised the bar for proving inequitable conduct in Therasense, Inc. v. Becton, Dickinson & Co., where an en banc panel held that clear and convincing evidence was needed to prove intent to deceive the USPTO, and that intent to deceive cannot be inferred by proving other elements of the defense. Prior to Therasense, claims of inequitable conduct were once so prevalent that the court wrote that the defense had \"become an absolute plague\" on patent litigation. By indicating that it is willing to consider litigation misconduct to infer a finding of inequitable conduct, the Federal Circuit appears to have expanded the scope of the doctrine, which may encourage defendants to raise inequitable conduct as a defense. If subsequent cases follow this expanded theory, the consequences could be far-reaching, exposing patent holders to a new wave of inequitable conduct charges. This Article examines the effect of Regeneron on the inequitable conduct defense and further discusses considerations for practitioners in light of the Federal Circuit's opinion in Regeneron.
Journal Article