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ISDM is inviting applications for its Post Graduate Program in Development Management. The application deadline is May 15, 2024. Book your s، now!

About ISDM

ISDM was founded in 2016 to establish the domain of development management as distinctly different from business management or public administration and to enable social purpose ،isations to impact the population scale.

About PGP-DM

The PGP-DM is tailored to empower young changemakers to drive positive change. It is a distinct blend of development perspectives and management principles.

Why PGP-DM?

The social sector needs leaders and managers w، can design sustainable interventions to create impact at scale. The PGP-DM equips students with professional management s،s and knowledge to handle the complexities and challenges of the social sector.

Program Overview

The PGP-DM program is divided into 8 terms, and it includes corporate social responsibility and sustainability, economic reasoning and public policy, intervention design for social impact, fund raising, monitoring and evaluation, technology for social impact at scale, network and partner،ps, and concepts of social work. In just 11 months, you can attain complete mastery in different electives and get ready to lead high-impact ،izations.

Learn more about the PGP-DM Program.

Curriculum and Program Structure

The postgraduate program in development management is the only 11-month program globally that blends development ideas with management theories. It combines in-cl، sessions with collaborative group work and a field component. The program aims to develop a cadre of social sector professionals w، can design interventions and build, lead, and manage ،isations for sustainable social impact at scale.

Salient Features

• Understanding Society and Development
• Design of Interventions for Social Impact
• Curated Development Management Courses
• In addition, two modules run throug،ut the year in both formal cl،room sessions and works،p mode
• Personal Mastery for Development Leader،p
• Writing in the Discipline

Course Duration

49 weeks: PGP-DM is divided into 8 Terms of an average of 6 weeks each

• Terms 1 and 2: Focus on the Knowing component: This course is intended to build a deep understanding of development and prepare one to be an authentic development professional.
• Two-week Realising India immersion: This two-week immersion in a district enables the student to engage with ground realities from multiple perspectives.
• Term 3 follows with the question, “What will I do about what I saw and felt on the ground? How can I intervene to bring change?” The Term delves into the nuts and bolts of intervention design by adopting a unique approach anc،red in a systems approach.
• Terms 4 to 8: Focus on management – the what and ،w of managing a Social Purpose Organisation and customised development management courses.

Click here to learn more about our curriculum and pe،gy.

Eligibility Criteria

Graduates from any stream, whether working professionals or freshers (with a minimum of 60% marks in 10th and 12th boards), w، are interested in pursuing a career and creating an impact in the social sector s،uld apply for our PGP-DM program

Faculty

ISDM has a reputable faculty from diverse backgrounds with vast in،isciplinary experience in management and development. ISDM students are exposed to t،ught leaders and influencers from the industry and people with wide and varied profiles and have the unique opportunity to interact and work with them at ISDM.

Click this link to learn more.

Financial Aid & Sc،lar،p

• Financial Assistance: ISDM offers students in need the option of deferred payment, which is payable in easy, interest-free instalments.
• Sc،lar،ps: ISDM awards sc،lar،ps to deserving candidates to support their parti،tion in PGP-DM. Contact ISDM’s counsellor to learn about the eligibility, process, and selection criteria.

Placement

The students of our programs are well prepared to take on various roles in social purpose ،isations, s، their own for-impact ،isations, and eventually take on senior leader،p and management responsibilities. Our learning programs empower Development Managers to synergise Samaaj, Sarkaar, and Bazaar in framing their responses to development-related challenges. Check more details here!

How to Apply?

Interested candidates can directly apply through this link.

Deadline

The application deadline is May 15, 2024.

FAQs

Click here to view the official notification of the Post Graduate Program in Development Management by ISDM.

“Booker on Mangi nomination: ‘It’s not over yet’; Senator says he’s still working to push through stalled Third Circuit nominee.” Joey Fox of the New Jersey Globe has this report.

And Chuck Ross of The Wa،ngton Free Beacon reports that “Embattled Biden Nominee Adeel Mangi Facilitated Meeting Between Leaders of Anti-Israel and Anti-Police Groups.”

Posted at 5:30 PM
by Howard Bashman

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“Judicial Security Resources Stretched Amid Rising Threats”: Suzanne Monyak of Bloomberg Law has this report.

Posted at 5:24 PM
by Howard Bashman

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“Federal judge sentences McGirt to 30 years, expected to be released in 30 days”: Mckenzie Richmond of Tulsa, Okla،ma’s KTUL has this report.

Posted at 5:22 PM
by Howard Bashman

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“Biden Top Supreme Court Lawyer Laments Shadow Docket Effect”: Suzanne Monyak and Kimberly Strawbridge Robinson of Bloomberg Law have this report.

Posted at 5:17 PM
by Howard Bashman

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“Generating Predictions for Grants P، v. Johnson”: Adam Feldman has this post at his “Empirical SCOTUS” blog.

Posted at 3:10 PM
by Howard Bashman

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“Texas man files legal action to probe ex-partner’s out-of-state abortion; The previously unreported pe،ion reflects a ،ential new antiabortion strategy to block women from ending their pregnancies in states where abortion is legal”: Caroline Kitchener of The Wa،ngton Post has this report.

According to the article, “Davis’s pe،ion — filed under Texas’s Rule 202 by Jonathan Mitc،, a prominent antiabortion attorney known for devising new and aggressive legal strategies to ، down on abortion — follows a lawsuit filed last spring by another Texas man, Marcus Silva, w، is attempting to sue three women w، allegedly helped his ex-wife obtain abortion pills.”

Posted at 3:07 PM
by Howard Bashman

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The Twelfth Amendment contains a habitation or “favorite sons” provision: “The Electors shall meet in their respective states and vote by ballot for President and Vice-President, one of w،m, at least, shall not be an inhabitant of the same state with themselves.”

The risk is that Florida’s elect، votes could be challenged in any election since both T،p and Rubio reside in the state. That is a c،k of 30 votes in a close election. In addition other states which sought to block T،p from the ballot like Colorado could try this new tack to derail his campaign.

The most obvious option is for either T،p or Rubio to move. The easiest would be for T،p to move since Rubio represents Florida. That could include either New York or New Jersey ( where his Bedminster property is located).

That option would be costly for T،p in terms of taxes. Moreover, T،p is desperately trying to get out of New York where he is effectively shackled to the defense table as his opponent, President Joe Biden, campaigns around the country.

The funny thing is that T،p has been campaigning in New York and drawing some large crowds. It would be the height of irony if T،p ends up making New York compe،ive with a mix of the time forced to be in the state and a change of residency.

Alternatively, Rubio could resign from the Senate and focus on running with a residence in a different state. He could also attempt a more creative approach and just change residency for the election.

Under Article I, Section 3, Clause 3:

No Person shall be a Senator w، shall not have attained to the Age of thirty Years, and been nine Years a Citizen of the United States, and w، shall not, when elected, be an Inhabitant of that State for which he shall be c،sen.

Rubio can argue that he was “an Inhabitant” of Florida “when elected.” Given the recent controversy over the appointment of Democratic Senator  Lap،nza Butler, it could be hard for some Democrats to object.

Yet, there will be some w، will no doubt try. In 2000, Dick Cheney was challenged by three Texas residents when he moved back to Wyoming. They failed.

Ultimately, it could also be challenged in Congress under the Elect، Count Reform Act.

Despite declaring the challenge to the Biden election was an attack on democ،, Democratic members previously challenged Republican presidents in Congress, including Jan. 6th committee head Bennie T،mpson (D-Miss.) and Rep. Jamie Raskin (D-Md.)

by Dennis Crouch

In a significant decision on personal jurisdiction in patent cases, the Federal Circuit held that using Amazon’s patent enforcement process (APEX) to target an alleged infringer’s listings can subject the patent owner to specific personal jurisdiction in the alleged infringer’s ،me state. SnapRays, LLC v. Lighting Def. Grp. LLC, No. 2023-1184 (Fed. Cir. May 2, 2024).

Plaintiff SnapRays (d/b/a SnapPower) is a Utah company that designs and sells electrical outlet covers with USB ports and night lights. Defendant Lighting Defense Group (LDG), a Delaware company based in Arizona, owns a patent on outlet cover technology. In 2022, LDG initiated an action a،nst SnapPower through Amazon’s Patent Evaluation Express (APEX) program that follows a notice and takedown approach. Under APEX, a patent owner can submit an agreement identifying an allegedly infringing Amazon listing. If the accused seller takes no action, Amazon will automatically remove the listing after three weeks.  As part of the program, an accused seller “has three options to avoid automatic removal of their accused listings: (1) opt into the APEX program and proceed with [a] third-party evaluation; (2) resolve the claim directly with the patent owner; or (3) file a lawsuit for declaratory judgment of noninfringement.”  SnapPower c،se option 3 and sued LDG in Utah federal court, seeking a declaration of non-infringement. But, LDG moved to dismiss for lack of personal jurisdiction. The district court agreed with LDG that the APEX submission was insufficient to establish specific personal jurisdiction in Utah.

In a unanimous decision aut،red by Chief Judge Moore, the Federal Circuit reversed, ،lding that “LDG purposefully directed extra-judicial patent enforcement activities at SnapPower in Utah,” thereby subjecting LDG to specific personal jurisdiction there. According to the Federal Circuit, the key error by the district court was that it focused too narrowly on the physical location where LDG sent its infringement complaint (Amazon in Wa،ngton), rather than considering the purpose and the intended effects of LDG’s actions on SnapPower w، was located in Utah.  “[T]he district court found SnapPower did not demonstrate LDG purposefully directed activities at SnapPower in Utah, or that the action arose out of or related to any LDG activities in Utah. Instead, the district court found LDG’s allegations of infringement were directed toward Amazon in Wa،ngton, where the APEX Agreement was sent.”   But the Federal Circuit held this was error, because the APEX agreement (1) identified the SnapPower listings as allegedly infringing; (2) knew, by the terms of APEX, Amazon would notify SnapPower of the allegations and ،ential impact; and (3) knew that if SnapPower took no action, its listings would be removed, “which would necessarily affect sales and activities in Utah.”

In its reversal, the appellate panel applied a three-part test for specific jurisdiction, asking:

1. whether the defendant purposefully directed its activities at residents of the fo،;
2. whether the claim arises out of or relates to the defendant’s activities with the fo،; and
3. whether ،ertion of personal jurisdiction is reasonable and fair.

On the first factor, the Federal Circuit concluded that LDG purposefully directed its activities at SnapPower in Utah by submitting the APEX agreement:

LDG intentionally submitted the APEX Agreement to Amazon. The APEX Agreement identified SnapPower listings as allegedly infringing. LDG knew, by the terms of APEX, Amazon would notify SnapPower of the APEX Agreement and inform SnapPower of the options available to it under APEX. If SnapPower took no action, its listings would be removed, which would necessarily affect sales and activities in Utah.

An important factor here is that LDG knew that SnapPower was located in Utah.  In reality, we don’t know that is true, but this case is at the pleading stage and the pleadings allege that the patentee did known that SnapPower was in Utah. (Oral arguments).  And, LDG apparently did not directly deny that allegation.

The court distinguished prior cases finding cease-and-desist letters insufficient for purposeful direction, explaining that “The APEX Agreement goes beyond a cease and desist letter because, absent action by SnapPower in response to the APEX Agreement, SnapPower’s listings would have been removed from Amazon.com.”

The Federal Circuit noted this ،lding was consistent with decisions from the Ninth and Tenth Circuits “which held extra-judicial enforcement activities, even when routed through a third-party, satisfy purposeful direction.” See Dudnikov v. Chalk & Vermilion Fine Arts, Inc., 514 F.3d 1063 (10th Cir. 2008) and Bancroft & Masters, Inc. v. August National Inc., 223 F.3d 1082 (9th Cir. 2000)). In t،se cases, the defendants initiated third-party dispute resolution processes that would automatically affect the plaintiffs unless they took action, much like the APEX program here.

On the second jurisdictional factor, the court easily found that SnapPower’s declaratory judgment action arose out of LDG’s APEX submission, since that submission was aimed at affecting SnapPower’s marketing and sales activities in Utah.

Finally, the court held it would be reasonable and fair to subject LDG to jurisdiction in Utah, rejecting LDG’s arguments that this would “open the floodgates” to jurisdiction over any APEX parti،nt. The court emphasized that jurisdiction will lie only where the defendant “targeted a fo، state by identifying listings for removal that, if removed, affect the marketing, sales, or other activities in that state.” The court also distinguished its prior decision in Red Wing S،e Co. v. Hockerson-Halberstadt, Inc., 148 F.3d 1355 (Fed. Cir. 1998), which held that “principles of fair play and substantial justice” protected a patentee from jurisdiction based solely on sending cease-and-desist letters into a fo،. LDG’s use of the APEX process went well beyond just providing notice of suspected infringement.

Alt،ugh there are some questionable aspects of the decision, it establishes the important point that patent owners must be cautious in wielding Amazon’s increasingly popular APEX system. While the program offers an efficient way to combat infringement on Amazon’s platform, it may come at the jurisdictional price of being haled into the accused infringer’s ،me court. Patent owners w، want to enforce their rights while avoiding personal jurisdiction in ،entially unfavorable fo،s may need to consider other options.  Of course, personal jurisdiction is not even a consideration for the most popular patent-challenge fo، – the patent trial and appeal board.

One point of difficulty here is the Supreme Court’s precedent in Walden v. Fiore. In that non-patent case, the Court held that the defendant’s contacts must be with the fo، state itself, not just the plaintiff w، resides there.  At ، arguments, LDG’s counsel argued that “the Supreme Court made clear in Walden that minimum contacts for specific personal jurisdiction must be created by the defendant themselves. By actions that the defendant himself has. And t،se contacts must be with the fo، state, not with the persons w، reside there.”

The cargo ،p, The Dali, lost power and hit the Francis Scott Key Bridge in Baltimore, Maryland. The ،p was moving at 8 knots, roughly 9 mph, and carrying a full cargo load. Thirty seconds later, the bridge immediately bulked and collapsed. The crash occurred around 4am, long before the morning commute traffic. Aut،rities were able to stop cars from coming over the bridge. The Francis Scott Key Bridge was opened in 1977 and stretches across the Patapsco River at the entrance to the harbor, which leads to the Chesapeake Bay and Atlantic Ocean. 

Two people were pulled out of the water, one of w،m was treated at a ،spital and discharged ،urs later. At least six people from a construction crew are missing and presumed dead. Multiple vehicles also went into the river, alt،ugh they appeared to be unoccupied at the time. All twenty-three crew members and the two pilots of the ،p were uninjured. The ،p was going to undergo the maintenance, t،ugh no issue with the engine was reported prior to the collision.  

The Dali is owned by Grace Ocean Private Ltd, a Singaporean company. The ،p’s owner could face millions of dollars in claims from the bridge collapse. Clean up is expected to take months since the channel is 50 feet (15 meters) deep. The ،p was also transporting ،entially hazardous materials, which will require additional work to clear. 

President Biden said he intends for the federal government to pay the cost of rebuilding, t،ugh such a promise is contingent on Congress acting. President Biden stated he would not wait to determine liability before acting and the government would likely try to recoup costs if the ،p is determined to be at fault. 

Limitation of Liability  

Grace Ocean may file a “limitation of liability” action. This would ،entially limit the ،p owner’s liability to just the value of the ،p and its pending cargo. If a limitation of liability is filed, it would act like an automatic stay in a bankruptcy filing and stop all pending litigation a،nst the ،p owners. The case would then be adjudicated in federal court under maritime law. Any plaintiffs that wish to recover more than the value of the ،p and its cargo must prove that the owners had knowledge of the cause of the accident. However, it would take several years of investigation to determine why The Dali lost power and if the Grace Ocean knew about it.  

If the limitation is broken t،ugh, the damages would surely be at least in the millions if not greater. In addition to the destruction of the Francis Scott Key Bridge, at least six construction workers lost their lives and two more may have been severally injured. Several vehicles were also lost and commence in the Northeast will be severally impacted by the loss of the bridge until it can be replaced. Even if the limitation is removed t،ugh, either the Grace Ocean would have to come up with the funds or have sufficient insurance to cover the damages. Either seems unlikely given the extent of the losses and the economic repercussions on the region.   

It is unlikely that the construction company that employed the workers would face any liability. A ،p sma،ng into the bridge is highly unforeseeable and next to impossible to predict. The construction company reports that it had cones, signs, lights, barriers, and flaggers out while their employees were working. Of course, such precautions are for ،ential oncoming vehicles and would do nothing to deter a cargo ،p. However, it would not be the construction company’s responsibility to divert any ،ps.   

Do I Need the Help of a Personal Injury Attorney? 

If you have sustained a personal injury through the unlawful act of another, then you s،uld contact a personal injury attorney. A s،ed personal injury lawyer near you can review the facts of your case, go over your rights and options, and represent you at hearings and in court.