#Definitely based on a taskmaster video

[a-timely-problem]

Overheard at the BAU

The team: doing challenges during game night

Penelope: "For this task, you have to get this vase to the table without using your hands."

The rest of the team: "Alrighty!"

Spencer: "...like... not at all? Am I supposed to use my feet? Can I touch this with gloves and it doesn't count? Am I supposed to pick up other tools with my hands or would that disqualify me?"

The others: ...

Spencer: "I'm autistic, you should have seen this coming."

[panelshowsource]

hi, sarah! i see you've watched a lot of british panel shows/comedians and i need a specific recommendation: where to start with dara o briain? he's right now my favourite taskmaster contestant ever and after listening to his episodes on the tm podcast and off menu, and watching him on wilty, i'm completely in love with his humor and manner of speech. what are the "must see" things he's done in the past? he's such a prominent figure in british tv but idk how to choose what to watch next

i have watched a lot of panel shows...you got that right hehehe...

i'm happy for you that you found someone you really like and get to explore a lot of new content! i gotta say, that doesn't happen often for someone quite so famous and prolific like dara, so it's fun for me to think back to all the stuff he's been in :')

he's a comedian, but he's also known for being mr big smarty pants, so he's done a lot of comedy programmes as well as smarty pants programmes & documentaries. you may choose to start in one of these distinct directions if there's a side of dara you like best! let me start with a few of my own faves...

he's probably best known — definitely by my followers, but also in general — for being the long-time host of the news-focused panel show mock the week, which JUST ended after 17 years. of the panel shows about news, of which there are many, this one is the most accessible and the most silly. dara is a GREAT host and has hilarious dynamics with the regular panelists, especially his literal best friend ed byrne (who we heavily stan). in fact, on mtw, you'll also see lots of other taskmaster contestants you may recognise, including panel captain and cult fave hugh dennis, frankie boyle, russell howard, and ed gamble. i know 17 years is A LOT, so if you've never seen the show and aren't sure where to start, i'm gonna recommend you give series 15 a go — as a new-er panel show fan, i think a more recent season like this one will be most accessible. also, this compilation of comedians roasting dara on mtw for half an hour is fucking hilarious lmaooo

dara has been on tons of panel shows as a panelist opposed to hosting, and you'd be amiss not to catch up on him on qi! one of stephen's smart lil boys and a clever laugh, he was made for that show. you can find dara's episodes here and i have all of qi linked on the masterpost! if you've never seen qi here's a silly clip that is mostly sean being one of stephen's naughty lil boys but it's a great example of the learning a lot/learning absolutely nothing dichotomy that can happen with a great panel (including dara!!)!

apart from that, i'd highly recommend you watch his stand-up! i put two specials on drive for you, 2012's craic dealer and 2015's crowd tickler (sorry for the mid quality — they're just dvd rips). these are pretty perfect for blossoming dara fans because they're funny, witty, clever, goofy — all the things we love about dara at once!!

as for my final personal recommendation, you should definitely check out dara & ed's great big adventure, a bbc two miniseries where the besties travel along the pan-american highway! they have top-tier wholesome bantz, ed is very fucking goofy (you will find quickly that being a fan of dara is being a fan of ed hahaha), and they explore some very beautiful cultures. i will work on getting decent rips of the show for my drive, but in the meantime you can watch this on dailymotion!

it would be amiss if i ended the recs here, because dara has hosted a lot of different series — but these series are based around very specific interests of his. some of the big ones include the following: go 8 bit, one of his most recent shows about classic and indie video games, very nostalgic with fun guests; science club (if you need full eps of this lmk, i should be able to get them but it will just take a lil time) and school of hard sums, nerds talking about science and maths, def have qi vibes; and the underrated stargazing live, broadcast every winter and when dr brian cox & our fave amateur astronomer mr ó briain talk about stars and shit! these are less necessary watching and more worth watching if the topics tickle your fancies~

okay i hope that helps!! there is obviously so much more to his career — including his many books — but i think this is overwhelming enough and i hope you don't mind the long post! feel free to catch us up on what you're enjoying down the line, we love dara and hearing what others love about him too :')

[danshive]

I made my new Starfield character while eating lunch. I based her design on Suletta from The Witch From Mercury (which I'll share later), in part because I decided to get the Soldier backstory for the boost and ballistics perks (plus extra oxygen, which is a nice to have).

For traits, I went with Adoring Fan, Taskmaster, and Wanted.

Adoring fan because I want him to carry things...

Taskmaster because paying twice as much to hire people seems absolutely worth it for the chance of them randomly fixing things for free on the ship mid-combat...

And Wanted because Skyrim and New Vegas have taught me that hired goons randomly showing up to try and kill you is a fantastic thing that I definitely want to have happen (in a video game), and the bonus damage when low on health is just icing on the cake.

Seriously, it's bonus loot, and something interesting that can happen at random while exploring. I can't think of an actual downside to the trait unless they're just way out of my league to beat.

Additional toppings on the cake is gradually figuring out my personal canon for WHY Suletta is wanted. I'm not roleplaying as Suletta from the anime, but basing my character on her to some degree does have me thinking banned mechs were involved somehow.

[danglovely]

Regrading Taskmaster: S02 E02 Pork is a sausage.

*Score changes noted in parenthesis.

Prize Task: Trendiest Item of clothing.

Richard brings in a t-shirt of the Osmonds but with his face edited over them. It's a clever joke, but a complete whiff on trendiness as the Mormon sing group gradually becomes less and less relevant over time.

Katherine brings in a pair of leggings with a unicorn fighting a robot dinosaur with a rainbow overhead. This actually isn't bad; the 80's aesthetic is pretty bullet proof and it exudes a level of non-sequitarian humor that can be pretty trendy.

Jon brings in a cardigan with a a black waist coat sewn in. He impresses Katherine with it, but outside of cardigans being a decently popular item of clothing, this isn't particularly impressive.

Joe brings in his best tie with his aunt (definitely a lie) and a small vintage car embroidered on it. It doesn't look terrible but he really needed to sell this with a better story.

Doc brings in bright red waterproof converse, or what he calls "wellies with laces." He tries to sell it by saying how ridiculous they are and that's what he finds trendy.

They all sort of whiff on the category to varying degrees. Richard's is the opposite of trendy and Katherine's is the best. The other three are largely dependent on taste.

Doc: 4 (-1) Joe: 2 (0) Jon: 3 (0) Katherine: 5 (+1) Richard: 1 (0)

VT 01: Eat me. Fastest wins.

Theoretically objective task but there is a ton of pedantry involved in how much of an egg one has to consume to "eat it." None of them eat the shell, but it's pretty collectively understood that it isn't included when you say you've consumed an egg.

Doc and Joe appear to completely consume their eggs. Katherine abstains after tasting raw egg and takes a DQ as a result The issue is that Jon and Richard both lose some of their egg to the table because they crack it into the egg-cup and it isn't big enough to hold the contents.

It's not an easy question because interpreting the task to mean consume any of the egg puts Katherine back in the game, but interpreting it to mean the entire egg DQ's Jon and Richard. Greg seems to take an intent-based approach (Jon and Richard didn't mean to lose part of their eggs and consumed as much as they possibly could) and the outcome feels just.

Doc: 4 (0) Joe: 2 (0) Jon: 3 (0) Katherine: DQ (0) Richard: 5 (0)

VT 02: Make the best music video for a nursery rhyme.

Doc's music video for Once I Caught a Fish Alive is so good that I occasionally go back and rewatch it, just because it jams. Jon's horror movie version of Three Blind Mice is a close second.

I'm not sure Katherine actually completed the task because one of the requirements of being a nursery rhyme is that it's traditional and she wrote an original song.

Richard's rendition of She'll Be Coming Round the Mountain while he's generally being mean to people is interesting, if a little confusing thematically. However, I'm actually going to give the nod to Joe, who I think achieved a level of terribleness that brought it back around to good again.

Doc: 5 (0) Joe: 3 (+2) Jon: 4 (-1) Katherine: DQ (-4) Richard: 2 (-1)

Studio Task: Using this camera, take a picture of an inanimate object that looks like you. Closest resemblance wins.

Most of them got pretty close and Richard did deserve top marks here because his is the only object that, if I saw it out in the wild, I would say "that looks like Richard Osman." Doc Brown looks a little more like Marvin Humes than Katherine does the woman on the Spanx box and somehow they both look more like their objects than Jon's 3D print of himself. Joe got two points for bringing in a toaster then dressing up like a toaster. Good bit, but unless he always dresses up like a toaster there's no resemblance.

Doc: 4 (+3) Joe: 1 (-1) Jon: 2 (-2) Katherine: 3 (0) Richard: 5 (0)

VT 03: Order the following pizza for the Taskmaster: Extra large vegetarian pizza with pepperoni and bacon, and without tomato and cheese. You may not use the following words: Extra, Large, Vegetarian, Pizza, Pepperoni, Bacon, Tomato, Cheese.

The task doesn't lay out the winning condition and all of them say one of the forbidden words at least once. They decide in studio that the best pizza delivered wins it. It isn't the fairest way to grade because they all were calling different pizza places and the task specifies that you just have to order the pizza, not receive it. As such, I'll rescore based on violations + the "bubbles" bonus point.

Doc: 2 (-1) Joe: 5 (0) Jon: 2 (-3) Katherine: 5 (+1) Richard: 5 (+4)

Live Task: Using these big chopsticks, get these potatoes into your basket. You must only hold the big chopsticks on the grips provided. The big chopsticks alone may touch the potatoes in turn. Whoever has the most potatoes in the basket after 100 seconds wins.

Richard breaks the rules right off the bat. Jon gets 11/10 potatoes which is great, and within the rules, because "these" could mean any of the potatoes on stage. Doc and Joe take zeroes because their baskets fall off the stage, but they should actually come in joint third unless the task required all 10 potatoes to go in the basket (which would DQ Katherine).

Doc: 3 (+3) Joe: 3 (+3) Jon: 5 (0) Katherine: 4 (0) Richard: DQ (0)

Final

Doc: 22 (+4) Joe: 16 (+3) Jon: 19 (-6) Katherine: 17 (-2) Richard: 18 (+3)

So it seems like Jon was heavily overscored in this episode mostly because the pizza task didn't penalize mistakes. Doc probably should have won the episode where he dropped the amazing nursery rap.

[rjjameshiii]

RJ's Platinum Collection #5: Marvel's Spider-Man

Achieved on 7/21/2022 at 4:52 PM

I had already played this game when it came out on my PS4, but I knew I was DEFINITELY going to replay it and get the platinum a second time on my PS5. This is, without a doubt, one of the BEST superhero video games that has ever existed. I would call it the best Spider-Man game ever made too!

Like Detroit: Become Human and Jak & Daxter, I have already played this game once before, and I knew everything I needed to do to unlock the platinum. So I decided to take a, shall we saw, cinematic approach to this game. I wanted to get certain tasks done before the end of each of the games three acts, and I wanted to get EVERYTHING done before the final battle. That may be weird and not make sense, but it's how I played!

Of course I started with the game's fantastic opening sequence where you take down Kingpin.

1/51: Knocking Down Kingpin - Defeat Wilson Fisk.

And then I decided to just get the trophy for greeting people on the street out of the way.

2/51: Spider-Man About Town - Greet 10 citizens.

And THEN I made sure to activate every single surveillance tower so I could get the entire map from the beginning. Seriously, I watched a few videos of people playing this game, and so many just DON'T activate the towers. Do you like having an unfinished map in an open world game? Cuz I don't.

3/51: Amazing Coverage - Activate all the Surveillance Towers.

After that I just continued playing the game, doing collectibles and side stuff in-between the main story missions.

4/51: Lost and Found - Collect 5 backpacks.

5/51: The Scientific Method - Craft your first upgrade.

6/51: Spider-Sensible - Perfect dodge 10 attacks.

7/51: Ace The Base - Complete all objectives in a base.

8/51: Hero For Higher - Perch atop Avengers Tower.

9/51: And Stay Down! - Complete a Level 1 combat benchmark.

And just a quick side note: I still have no clue how the heck the "Wing It" trophy works. I feel like I spend the entire game traversing across the city rooftops. What is the trophy's exact unlock requirements? I dunno.

10/51: Wing It - Traverse across the city rooftops.

Anyway, back to playing Act 1.

11/51: King of Swing - Complete a Level 1 traversal benchmark.

12/51: Snappy Dresser - Wear 5 new Spider-Suits.

13/51: Shock and Awe - Defeat Shocker.

14/51: Cat's Out of the Bag - Collect a Black Cat collectible.

15/51: Arachnophobia - Perform 75 stealth takedowns.

Before doing the final mission of Act 1, I decided to finish all of the Fisk Hideouts to symbolize how Fisk is taken out of the picture for good so that Li and the Demons can become the big threat of the story.

Look, I know the way I'm getting this platinum is weird, but I was a theatre nerd, I like to do things DRAMATICALLY.

16/51: All The King's Men - Take down each Fisk Hideout.

17/51: Demons Emerge - Complete Act 1.

Since you start Act 2 in a graveyard, I decided to go say hi to Uncle Ben to get a quick miscellaneous trophy out of the way.

18/51: With Great Power... - Pay your respects to Uncle Ben's grave.

And then I started playing through Act 2. Basically, I decided I wanted ALL of the side content done before I finished the second act, because knowing what happens to New York City in Act 3, I felt like all the fun stuff needed to be completed first for the best dramatic impact possible.

19/51: Science FTW! - Craft 15 upgrades.

20/51: Born to Ride - Ride the Subway five times.

21/51: Backpacker - Collect all backpacks.

22/51: Overdrive - Complete 10 vehicle takedowns.

23/51: Short Fuse - Get a Spectacular or better in a Taskmaster Bomb Challenge.

24/51: Sightseeing - Photograph all Landmarks on the map.

25/51: Tombstone Takedown - Defeat Tombstone.

26/51: Hug It Out - Knock together 10 pairs of enemies using Trip Mines.

27/51: Inner Sanctuary - Take down each Demon Warehouse.

28/51: Cat Prints - Track down Black Cat.

29/51: A Bit of a Fixer Upper - Complete all the optional projects in the lab.

30/51: Pigeon Hunter - Catch all of Howard's pigeons.

31/51: Spy Hunter - Get Spectacular or better in a Taskmaster Drone Challenge.

32/51: Fists of Fury - Get Spectacular or better in a Taskmaster Combat Challenge.

33/51: R&D - Complete all of the Research Stations.

34/51: Ninja - Get Spectacular or better in a Taskmaster Stealth Challenge.

35/51: Schooled - Complete all of the Corrupted Student missions.

36/51: Challenge Finder - Complete every Taskmaster Challenge in the city once.

37/51: Master of Masters - Defeat Taskmaster.

38/51: Friendly Neighborhood Spider-Man - Complete all side missions.

With the final side mission done, I finished Act 2 and got to enjoy the incredible cinematic shot of Spider-Man looking over a New York City that had descended into complete chaos.

39/51: The Six Assemble - Complete Act 2.

With almost everything done, Act 3 was spent doing the main missions while also taking care of all the faction crimes to make progress toward 100% each district, taking down the Sable Outposts and Prison Camps, and getting enough XP to finish buying all the suits and skills.

40/51: Grounded - Defeat Electro and Vulture.

41/51: Neighborhood Watch - Complete all Faction Crimes in a district.

42/51: Sticky and Tricky - Chain 4 unique tricks before landing.

43/51: A Suit For All Seasons - Purchase all the suits.

44/51: Superior Spider-Man - Unlock all skills.

45/51: Mercenary Tactics - Take down each Sable Outpost.

46/51: Sting and Smash - Defeat Scorpion and Rhino.

47/51: Staying Positive - Defeat Martin Li.

48/51: Back in the Slammer - Take down each Prisoner Camp.

49/51: I Heart Manhattan - 100% complete all districts.

And voila! With the game basically at 100% completion, I just had to do the final fight against Doctor Octopus and BOOM I got me a spidery platinum trophy!

50/51: End Game - Complete Act 3.

51/51: Be Greater - Collect all the trophies.

Spider-Man for PS4 is, without a doubt, one of the BEST video games of all time. And it is SO MUCH FUN to platinum. I recommend this game to ALL.

Rating: 15/10

[panelshowsource]

links to everything i use when making gifs!! yay

hi all, based on some asks i got this week, i thought i would post all the resources i use to make gifs in case they help you with your own :)

01. here’s my gif with no sharpening, no colour, and no adjusted speed setting. so far, all i’ve done is crop out the logo and resize it!

* pulled from this youtube video

02. first step is to sharpen it! i use this sharpening action — adjust the opacity between 48 and 65 depending on how sharp or soft you want the gif to be. i used that action with an opacity of 58, so here’s how my gif looks now:

* you can go here to learn how to install and access actions

03. colour your gif! here are the exact and imperfect settings i used for this specific gif. curves, select colour, and exposure are your best friends. i’ll also post more psds at the end of this post, so try them out and see if you like them :’)

04. now change the speed of your gif. i set this one to 0.05, and generally 0.04 or 0.05 is just right. you definitely want to make sure your gif isn’t too slow, as the smoothness of the movement can hide some imperfections in quality. the slower your gif, the lower quality it looks. i don’t make the rules ¯\_(ツ)_/¯

05. add some text!!! if you’re like me, you might also add a watermark. i always make sure the text isn’t too close to the bottom of the gif, but that’s my own pet peeve. here are my text settings!

all done! it’s not the perfect-est gif in the world but tbf it’s 2:41am and i am delirious :)

i really have no secrets at all — download everything i linked to above and you can make this exact gif in about 4 minutes!

additional psds & resources below the cut and happy giffing!!

as for psds... unfortunately i’m always adjusting my psds because the quality of video we panel show giffers deal with is always changing, or a series changes its set, or different episodes are lit differently, or skjhfslkgdhfghrgdsas. so these aren’t necessarily perfect for slapping on to any ol’ clip, but they should only require mild curves, exposure, and saturation adjustments before they work for you! or so i hope...please let me know if these are actually trash when you try and use them lmao

taskmaster psd

catsdown psd

* i use this psd with adjustments for pretty much everything because, for some reason, most panel shows have neon blue-ish sets? inh, room 101, celebrity juice, big fat quiz, argumental...

wilty psd

misc resources:

my favourite gif making tutorial

this is my favourite black & white psd and this is my favourite psd for colouring something that is already black & white

i download all of my “special fonts” (like the one i used here) from dafont.com

i generally use this site to download videos from youtube (720p with sound or 1080p without sound, because i don’t need the sound to grab a clip for photoshop)

i don’t usually use topaz clean for panel shows gifs, but here’s where i got it, here are some installation instructions and keys, here’s how i learned to use it, here are the default settings i use or if i need serious clean then i adjust edges to 4/1.46/0.48, and this ask cleared up my questions about ps crashing when saving a file with topaz effect

* i use photoshop cc 2015

[pelisplus-hd-viuda-negra-ver2021]

[HD]Pelisplus!!▷Ver Viuda Negra (2021) Película Completa Audio Latino

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Sinopsis

Viuda Negra será la primera película perteneciente a la Fase 4 del Universo Cinematográfico de Marvel. La cinta de apertura de esta etapa tendrá como protagonista a Natascha Romanoff, la talentosa espía y asesina rusa a la que da vida Scarlett Johansson en el Universo Cinematográfico Marvel. Un papel que ha desempeñado desde que apareció por vez primera en 2010, con el estreno de Iron Man 2.

Según las primeras informaciones, facilitadas durante la presentación de la Fase 4 del Universo Cinematográfico de Marvel en la San Diego Comic-Con de 2019, no se tratará propiamente de una historia de orígenes, sino que discurrirá tras los eventos posteriores a Capitán América: Civil War, revelando cómo Natascha hubo de huir tras traicionar a Tony Stark al bando pro-acuerdos de Sokovia durante la Guerra Civil de los Vengadores.

La fuga de la Viuda Negra la llevará a entrar en conflicto con sus antiguos aliados del KGB, entre los que se encuentra su ex-marido, Alexei, el hombre conocido como el Guardián Rojo (David Harbour). Además, también llamará la atención del peligroso mercenario conocido como el Supervisor (Taskmaster, en el original), un supercriminal con memoria fotográfica, capaz de replicar cualquier movimiento de cualquier luchador que haya visto en acción previamente. Y todo ello, mientras, finalmente, se revela lo que sucedió en Budapest junto a Ojo de Halcón (Jeremy Renner).

La película contará con un guión de Ned Benson y la dirección de Cate Shortland (Lore). Su estreno programado para el 6 de noviembre de 2021, por lo que se rodará a lo largo del año 2019. Inicialmente se esperaba que la película tuviera calificación R, pero al incluirse en el UCM de Marvel Studios se rebajó ligeramente su calificación para así captar a un público más amplio.

Lanzamiento : 2021-07-07

Duración : 133 minutos

Género : Acción, Aventura, Suspense

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❍❍❍ Definition and Definition of Film / Movie ❍❍❍

While the players who play a role in the film are referred to as actors (men) or actresses (women). There is also the term extras that are used as supporting characters with few roles in the film. This is different from the main actors who have bigger and more roles. Being an actor and an actress must be demanded to have good acting talent, which is in accordance with the theme of the film he is starring in. In certain scenes, the actor’s role can be replaced by a stuntman or a stuntman. The existence of a stuntman is important to replace the actors doing scenes that are difficult and extreme, which are usually found in action action films.

Films can also be used to convey certain messages from the filmmaker. Some industries also use film to convey and represent their symbols and culture. Filmmaking is also a form of expression, thoughts, ideas, concepts, feelings and moods of a human being visualized in film. The film itself is mostly a fiction, although some are based on fact true stories or based on a true story.

There are also documentaries with original and real pictures, or biographical films that tell the story of a character. There are many other popular genre films, ranging from action films, horror films, comedy films, romantic films, fantasy films, thriller films, drama films, science fiction films, crime films, documentaries and others.

That’s a little information about the definition of film or movie. The information was quoted from various sources and references. Hope it can be useful. ❍❍❍ TV MOVIE ❍❍❍

The first national color broadcast (the 1954 Tournament of Roses Parade) in the US occurred on January 1, 1954. During the following ten years most network broadcasts, and nearly all local programming, continued to be in black-and-white. A color transition was announced for the fall of 1965, during which over half of all network prime-time programming would be broadcast in color. The first all-color prime-time season came just one year later. In 19402, the last holdout among daytime network shows converted to color, resulting in the first completely all-color network season.

❍❍❍ Formats and Genres ❍❍❍

See also: List of genres § Film and television formats and genres

Television shows are more varied than most other forms of media due to the wide variety of formats and genres that can be presented. A show may be fictional (as in comedies and dramas), or non-fictional (as in documentary, news, and reality television). It may be topical (as in the case of a local newscast and some made-for-television films), or historical (as in the case of many documentaries and fictional MOVIE). They could be primarily instructional or educational, or entertaining as is the case in situation comedy and game shows.[citation needed]

In 2022, it was reported that television was growing into a larger component of major media companies’ revenues than film.[5] Some also noted the increase in quality of some television programs. In 2022, Academy-Award-winning film director Steven Soderbergh, commenting on ambiguity and complexity of character and narrative, stated: “I think those qualities are now being seen on television and that people who want to see stories that have those kinds of qualities are watching television.

❍❍❍ Thank’s For All And Happy Watching❍❍❍

Find all the movies that you can stream online, including those that were screened this week. If you are wondering what you can watch on this website, then you should know that it covers genres that include crime, Science, Fi-Fi, action, romance, thriller, Comedy, drama and Anime Movie.

Thank you very much. We tell everyone who is happy to receive us as news or information about this year’s film schedule and how you watch your favorite films. Hopefully we can become the best partner for you in finding recommendations for your favorite movies. That’s all from us, greetings!

Thanks for watching The Video Today.

I hope you enjoy the videos that I share. Give a thumbs up, like, or share if you enjoy what we’ve shared so that we more excited.

Sprinkle cheerful smile so that the world back in a variety of colors.

[wazafam]

Marvel's Avengers might have received some critical panning, but it's campaign has certainly been praised for its detailed characters and nods to the source material. Following the young hero Kamala Khan, players reunite the Avengers as A.I.M. and M.O.D.O.K. begin their reign of terror over Earth.

RELATED: Marvel's Avengers: 10 Costume Options Fans Want In The Video Game

With so many characters from the comics featured throughout the video game, some of them making their debut in the medium for the first time, each has to have a standout moment to signify their importance in the universe. Every Avenger and even some of the supporting characters feature in iconic scenes which establish them as heroes.

10 Hawkeye: Old Man Clint

Players were excited to finally get to play as Clint Barton in the new Hawkeye DLC, however, no one expected to be starting that journey as Old Man Clint. Taking a story straight from the comics, the game allowed fans to play through a mission in the far future.

It's a pretty iconic moment and one that sets the video game apart from any other on-screen adaptation of the character. With Old Man Clint likely having a larger role to play in the future of this narrative, this was an iconic way to play around with the timeline.

9 Hulk: Maestro Reveal

While the Hulk has some fantastic moments throughout the game, including when he gets out of control around the other Avengers, the best reveal was that of future Hulk. Once again playing into the comics, at the end of the Earth, only Maestro remains.

The Maestro reveal and boss battle was especially epic when the character was surrounded by the symbols of other fallen heroes. It demonstrated that the Hulk can still become a major threat down the line and established an alternate version of the character.

8 Thor: Return Of The God Of Thunder

While Thor has had his own fair share of canceled projects and a few appearances in the medium, this is perhaps the best iteration of the character in video games. His debut is electrifying and he's one of the few characters that feel genuinely powerful.

RELATED: 10 Little-Known Details In Marvel's Avengers Video Game Everyone Completely Missed

However, his return to the field after doing charity work as Donald Blake is the most memorable of his moments from throughout the game. He doesn't even have time to suit up in his trademark armor, instead flying into the conflict in his civilian clothing.

7 Ms. Marvel: A-Day

The Avengers have appeared in a few retro titles previously, but this narrative is entirely unique thanks to the introduction of the modern character Kamala Khan. Her story has inspired millions and for Marvel's Avengers it all starts on A-Day.

There's perhaps no better origin story in video games than that of Ms. Marvel. This is really a coming of age tale, but the attack on Avengers Day which gives her the powers she needs is both an exciting aspect of her narrative and a perfect way to showcase her love of the Earth's mightiest heroes.

6 Iron Man: Stark Heading To Space

It's somewhat surprising that before this there hadn't been any truly great video games based on Iron Man. What's Tony Stark without his suits of armor and rock music anyway? Marvel's Avengers managed to provide fans with the definitive Iron Man scene.

Going to space in his new, sleek, specially designed suit, Iron Man flies into the atmosphere accompanied by the sounds of Flight Of The Icarus by Iron Maiden. It's probably one of the most intense and comic book-based moments in the game.

5 Black Widow: Fighting Taskmaster

A-Day is a major conflict thanks in large part to the interference of Taskmaster. While all the Avengers have their part to play within the battle, it's the face-off between Black Widow and Taskmaster that truly sets up the former assassin as a badass.

RELATED: 10 Marvel's Avengers Updates That Can Save The Game

Jumping on the back of the jetpacking Taskmaster, players get to showcase Natasha's various skills as she looks to take down the hired hand. It's a lot of fun to play through and while Black Widow has a number of other standout moments throughout the game, it's certainly one of the most memorable.

4 Captain America: Revival

The story surrounding the main campaign saw Steve Rogers seemingly killed in action and the Avengers disbanded. It's up to Ms. Marvel to unite them all again, but what's the Earth's mightiest heroes without their leader shouting for them to assemble?

It's revealed that Captain America is actually alive. The mission to rescue him and his return to his iconic costume is definitely a heartwarming moment for players. The status quo is returned to normal and the shield is back with its rightful owner.

3 Ant-Man: Ant-Hill Debut

Ant-Man, unfortunately, doesn't have his abilities in the game thus far, but he has put his Pym Particles to good use throughout all of the technology he uses. His appearance in the game caught many by surprise, although his arrival couldn't have come at a better time.

Hank Pym is now the leader of those fighting back against A.I.M.'s reign of terror. With an underground resistance needing a location to hide out, players are introduced to the aptly named Ant-Hill, one of the most significant locations in the game and a sign that Hank never gave up hope.

2 Kate Bishop: Awesome Entrance

There's a lot of brilliant aspects to Kate Bishop's character. From her hilarious quotes to her amazing teleportation abilities. Her arrival into the game as the first piece of additional DLC was a sign that Square Enix and Crystal Dynamics knew where to take the title next.

With A.I.M. robots suddenly shutting down thanks to a mysterious arrow taking them out, Kate makes a truly cool entrance, with all of the wit and badassery that fans have come to expect from the character. It's an awesome moment and one that previewed how much fun the character would be to play as.

1 Scientist Supreme: The Cosmic Cube

The future of the game's campaign has been heavily teased thanks to the arrival of the Cosmic Cube. The fate of Nick Fury and the Scientist Supreme has been revealed, with the latter fighting off the Kree with her own artifact of destruction.

It's quite the powerful image; Monica Rappaccini is clearly not messing around anymore and has surpassed M.O.D.O.K. in terms of her ambition and her power. It will be interesting to see where the story goes from here with so much energy in the palm of her hand.

NEXT: Marvel's Avengers: Every Hero In The Game So Far, Ranked

Marvel's Avengers: Each Main Character's Most Iconic Scene from https://ift.tt/3htb3Rx

[uglysantas]

I May Live In New York But My Story Began In New Jersey T Shirt

0 is a I May Live In New York But My Story Began In New Jersey T Shirt that sound quite popular again right with the actor by I do want to point this out here’s the only here’s the only point Bernie was ahead let’s let’s look at so it was from February early February until late February only in the month of February was Bernie head you know why I you know why this surge year Black history month of yet so so most of that was when the other charities dropped out yes that’s true that there were definitely potentially some people the DNC the roadway the Arroyo yeah once these dispersed drop salvation they should definitely endorsed by etc. To the Flint River that the water was improperly treated allowing and other chemicals from the pipes to leach into the water supply the city switched back to its original water source in 2015 wire CBS news was on the ground in Flint from my side of the crisis we heard first hand from parents about how they believed the tainted water affected their children my son gave his bones hurt to give him there’s nothing to do for to take away although tens of thousands of plaintiffs ever pointedly saturating the payout as part of the settlement much of the money is expected to go toward the children affected by the crisis that may or shall the nearly says he hopes the settlement provides some sense of victory for families allows residents to move for a positive way of getting out of the mindset of being victims but more of as victors and that’s what we need to move as a community dollars per person the condo had to come to making a party is like Noel over the we are in this theory the idea being made to look through a. This taking the lives of tens of thousands of Americans rural areas like this your Navajo nation are specially at our 1530 of all citizens have the water cycle is our most vulnerable and hardest by covert agreements we need to bring awareness to the attention of the United States citizens Need to focus on the first citizens in years hundred thousand workers probably off in the distance you can see some factors are still humming most of whom are just kind of banded like continues to be lowest plans last I really young kids are feeling what’s going on right now should parents be talking to them about this whole question of racial justice embraces no real really must focus protested policy in Los Angeles for free download your favorite devices or streaming 24 seven to share what does it in a day party sense of your own over the officers all around the country is when you are you safety uniform just after general controversial changes to the US Postal Service the election he had been carving Mandalay many worried

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In the fight that we can add to it and in the summer we know that summer like conditions are going to create an environment with a I May Live In New York But My Story Began In New Jersey T Shirt transmission can be decreased and that’s an opportunity for us to get ahead in the eye there’s no serious Wednesday we don’t do that within that effect by saying that there are more and more people it would be irresponsible for us to say that we feel that the summer is just in a totally kill the virus in the free for all and that people ignore those guys is not the case we we had an opportunity to get ahead with what we know now infected end of the decision making for what open humidity like that that would have said on surfaces where it can be picked up it will do fairly some boys in the winter when yes is present once exposed to UV rays take a playground for example you be raising piece of playground equipment will kill the virus when a headset figure but underneath with a son does not yet if somatostatin had on their hands it could still be there it has been directed by. To inspire up and coming physicians who are in medicine sports medicine and so that the legacy will be how many and I like how many more doctors can I encourage with the key to continued success still like another three months to go through the celebrate now do not celebrate the first milestone was Wilson 22 teams on the ground into the hotel the next milestone for me was from his court active lights around came to be transmitted and end of the milestone after that was the start of the season. America villains so first up is Darren’s email now this is a character that I like a lotand this is a cool figure like a lot of the smaller skinny guys he’s a little lengthy sometimes I don’t like the way have you extra pieces of the fur lined slides around the placeand things this extra piece of shoulder Congress that was just attached sculpted to the main portal settlement with both round brother was it’s nice figureand they did make a Marvel legend of him back in 2014 before I had really committed to the 6 inch line I passed on itand is one of my most regretted pastor figures because I do love this guyand fields glaring hole in my Marvel legend collection to not have him some good taskmaster quite hot in my last video as he is featured in the new black widow wave now this is a nice figure with lots of accessories sees that the bowand arrow pistol’s swordand shield the quiver is always nice is a cool figure set I don’t listen love the head sculpt it’s just a little to one point of being a skeleton where I prefer his face to be a little moreand not so much a exact skeleton where the idea of the Skelton because skull faces here next we have the red skulland this is the bad figure but this is based on the movie look so his face isn’t quite as skeletal I would’ve preferred a comic version of it but that is all I was able to get so it’ll have to doand lastly we have crossbones noticeably cool version of him I just got the new Essex’s version in the black widow line of Marvel legends him so I had this figure out to talk about during that dealand unfortunately plan around some yesterdayand broke his leg off sorry now just got stuck in there were some sticky deck so that’s pretty disappointing because cool figure but Capt See Other related products: Bear Drinking Coffee I Hare Morning People And Mornings And Peoples Vintage T Shirt

[sliceannarbor]

Eric Saarinen

Director/Cinematographer
 Los Angeles, California
 ericsaarinenfilms.com

Photo by Perigrin Jung

SPECIAL GUEST SERIES

Eric Saarinen is a Los Angeles-based director and cinematographer best known for his work in feature films, documentaries, and wide-ranging commercial projects. The son of architect and designer, Eero Saarinen, and the grandson of architect, designer, and educator, Eliel Saarinen, Eric’s latest documentary project, Eliel Saarinen, now in development, is a tribute to his grandfather’s life and architectural contributions in Finland and the United States. He also co-produced, hosted, and was the director of photography on the documentary, Eero Saarinen, The Architect Who Saw the Future, part of a 2016 PBS American Masters series about his father. In earlier years, Eric served as director of photography in feature films by Albert Brooks, including Lost in America, Modern Romance, and Real Life. He also filmed music videos for Joni Mitchell, Jimi Hendrix, Pat Metheny, The Rolling Stones, Neil Young, and others. The recipient of numerous awards for his commercial work, Eric received 13 Clios, four MOMA’s, two Gold Hugo’s, and the Grand Prix at Cannes. He is a member of the Director’s Guild of America and was the first director of photography ever to be inducted into the American Society of Cinematographers for “Extraordinary Achievement in the Field of Television Commercials.” Eric earned a bachelor of arts at Goddard College, and a master of fine arts in filmmaking at UCLA. He was also inducted into the Finnish Society of Cinematographers. When Eric is not working, you can find him searching for the perfect woman. He resides near Los Angeles, in Harbor City, in a house filled with Mid-century modern furniture and art. Eric has two sons, Eliot and Evan.

FAVORITES

Book: The Old Man and the Sea by Ernest Hemingway

Destination: Places no one has seen.

Motto: “Dare to be great” - Gordon Willis.

Sanctuary:  Mantaharyu, Finland (Midsummer’s Eve)

THE QUERY

Where were you born?

Detroit, Michigan

What were some of the passions and pastimes of your earlier years?

Pretending to be an Indian in the forest at the Cranbrook Educational Community, building a machine gun nest on the roof of the abandoned barn behind our house, and underwater kissing at Hilltop Camp, Northern Michigan.

What is your first memory of film as an experience?

When I was young, I made a film in a cardboard box with two cranks and paper images viewed through a large hole cut in the box. It seemed important at the time, although I don’t remember any plot twists.

How did you begin to realize your intrigue with cinematography/film?

By forgetting to close the gate in a 16mm Bolex camera, and later learning how beautiful a mistake can be. I felt that every frame I shot was proof that I was alive, then and there. I was legally blind and walleyed when I was young, so I taught myself the painter’s tricks of how to make three dimensions out of two.

How did you get your start in the profession of filmmaking/directing?

I made art films after UCLA film school for the Los Angeles County Museum of Art and Gemini GEL, a publisher of fine art limited edition prints and sculptures. I went to EXPO ‘70 in Osaka, Japan, and worked with artists of that period. I decided to try to work with other directors and bought a camera and worked my way up to feature films, shooting as a director of photography for more than 15 features.

Was there a project/period along the way that presented an important learning curve?

In 1981, my cameraman’s reel was shown to an agency, and someone had ‘mistakenly’ labeled it ‘director/cameraman.’ I directed a spot for the San Diego Zoo that went on to win best commercial in California (The Belding). This was the beginning of Plum Productions, a thriving commercial production company that my partner, Chuck Sloan, and I ran for 28 years.

What role did your father play in the creation of the Cranbrook community in Bloomfield Hills, Michigan?

Eero came to the United States when he was 13 years old. At that time, Cranbrook didn’t exist as a school. Growing up, Eero participated in the design of many of the details, placemats, school logos, chairs, gate designs, interior furnishings, etc. at Cranbrook. Years later, after studying at Yale, he came back to Michigan and taught architecture at Cranbrook. Charles and Ray Eames (my godparents), and my mother, Lily, studied there under Eliel Saarinen and Carl Millis. In its entirety, the educational community took about 15 years to build. Meanwhile, Eliel (then president at Cranbrook) and my father worked together on eight other projects before my grandfather passed away in 1950.  

How did the concept for the PBS American Masters documentary Eero Saarinen, The Architect Who Saw the Future, take seed?

Robert Zeigleman, an architect who worked for my dad, wanted to make a documentary about Eero. He did some research, found Peter Rosen, a seasoned documentary producer/director, and approached businessman and philanthropist, A. Alfred Taubman (he designed the shopping mall) who was a fan of my father’s work. Peter called and asked me if I wanted to shoot the documentary, and I turned him down. At the time, I still hated my father, largely because he had an affair with another woman, in 1953, when I was eleven years old. A divorce followed, and my mother, sister, and I had to leave Michigan. It was an unsettling time for me.

A year after I turned down the Eero documentary offer, I read the love letters between my father and Aline, and was able to put myself in his shoes. He was in love. Peter wisely filmed my journey back in time…looking at my father’s work, some I never had seen before. He let me shoot Eero’s work, design the shots, and so on, while he filmed my own discovery process - making it a multi-level story. I shot most of my father’s architecture in high definition (6K), to repurpose later, and donate to architectural causes.  

What was the greatest challenge in making this documentary?

I wanted to film my father’s work for people, now and in the future. I was working for him, and I had to ask myself repeatedly what my dad would say, as I planned and executed the shots. He had been a very hard taskmaster.

What wisdom emerged as a result of the making of this project?

The making of the documentary changed me. Ultimately, I forgave my father after studying and filming his work and raising him up again. It also turned out to be a way of forgiving myself. I realized it was no one’s fault. There is a huge benefit in forgiveness, even if it comes 50 years later. I finally felt centered in my own life.

How did the concept for your new documentary project, Eliel Saarinen, take seed/develop?

Being in the Eero film, as the through-line, I realized it was important to have a strong grasp of the truth in telling this story. I gathered all the books on my father and read and reread them. I had to be able to set the record straight, so to speak. Under that tall pile of books was Eliel’s little book, The Search for Form in Art and Architecture, published in 1948, which became the philosophy that both Eliel and my father practiced. For example, one of the tenets was to never imitate anyone; not even yourself. That was why every building that Eliel and Eero designed had its own style - to best solve the particular set of problems that were revealed.

For Dulles Airport, the problem was that travelers would be walking for miles, so the mobile lounge was created so each passenger had to walk no more than 150 feet. My father made this structure to express the new age of jet travel as a grand entrance…to enhance man’s self esteem.

In the early 1900s, train travel was similar. In designing the Helsinki Railroad Station, Eliel created a grand vision of the future of train travel. That building, too, was expressive and totally unique.

For additional information about the making of the Eliel Saarinen documentary, please visit ericsaarinenfilms.com.

What was your relationship with your grandfather?

“Farfar” or “father’s father,” we called him in Swedish, spoke to me before I knew words. We would spend time at Cranbrook, and he would let me run free in the woods. Christmas Eve was always spent there. Art was everything and Cranbrook became a favorite place for me…kind of like heavenly Elysian Fields. I would see the great scale, and ride on the wonderful sculptures by Carl Milles, and ask myself – who were these people that made this timeless and transcendent world? Eliel died when I was just eight years old. He was a very warm grandfather. I learned by watching him. He was very methodical.

In filming the Eero and Eliel documentaries, where did your travels take you?

In the United States, we scouted, and later filmed, so we went everywhere twice, including the General Motors Technical Center in Warren, Michigan; Saarinen office building in Bloomfield Hills, Michigan; John Deere International Headquarters in Moline, Illinois; Irwin Miller House in Columbus, Indiana; MIT Auditorium and Chapel in Cambridge, Massachusetts; CBS Black Rock skyscraper in New York, New York; North Christian Church in Columbus, Indiana; The Ingalls Hockey Rink, and subsequently the Morse and Stiles Colleges of Yale University in New Haven, Connecticut; and the Gateway Arch in St. Louis, Missouri. Of course, we also filmed at Cranbrook in Bloomfield Hills, Michigan. In Finland we went to Eliel's Hvittrask Museum in Kirkkenonummi; Finnish National Railroad Station, Finnish National Museum, and Pohola Building in Helsinki; and Lahti City Hall in Lahti.

What architectural work of your grandfather’s do you find most beautiful?

Cranbrook was Eliel’s city plan: The Cranbrook School for Boys; Cranbrook Kingswood Girl’s School; Cranbrook Academy of Art; Cranbrook Institute of Science; Cranbrook Art Museum; and Cranbrook Library all used different forms. As president for many years, Eliel ended up bringing a large group of artists and architects together at Cranbrook, which became a focal point of Mid-century art and architecture. Eliel always said, “We don’t teach architecture at Cranbrook - the students learn it.” Eliel won the AIA Gold Medal for Cranbrook.

How would you describe your creative process?

Deductive, which is similar to my father’s process. You don’t start with a vision; instead the vision should be the result of problem solving. The first step is to find what the real problems are. That comes by understanding the client, and what he/she wants and needs. Ideally, it is a collaborative partnership. Then you gather the smartest people around and generate more ideas. Once you have the strong bones of the story, you figure out how to shoot it and where, and develop a kind of model, or pre-visualization, and then revise it. During filming, I try to stay low key - knowing I can trust the people around me.

What three things can’t you live without?

Passion, originality, and honesty.

Is there a filmmaker living today that you admire most?

Ridley Scott

What’s the best advice you’ve ever received?

“Success is 97% hard work and 3% talent.” - Eero Saarinen 
“Work is the key to creative growth of the mind.” - Eliel Saarinen

What drives you these days?

Completing the Saarinen legacy by filming Eliel’s work, incorporating his philosophy and thoughts. In addition, I’d love to do a film about Frank Gehry and his amazing work. These people did inspiring work. It’s rewarding to pass their passion on to our youth.

[junker-town]

A viewer’s guide to Yasiel Puig in the 2018 World Series

There are better players. There are not more unpredictable players.

Baseball is a regional sport now. There are no judgments attached to that statement, and it’s not even remotely controversial. In an era where you can have 95 percent of all recorded media beamed from space directly into your pocket, it’s too much to expect people to follow 30 different teams for 162 games. The World Series is often where fans check back in with the game on a national level. Who are these players? You’ve heard of a lot of them, sure, and you’ve seen a few highlights, but unless your team plays the Red Sox or Dodgers 18 times a year, you don’t know them.

Yasiel Puig is a player you’ve heard of. You might have heard a lot about him, even. But if you don’t know him, it’s crucial to your viewing enjoyment to read up on him before the next four, five, six, or seven games. After hitting .148 in last year’s World Series, Puig is likely to be a story for the 2018 World Series.

You should get to know Yasiel Puig. For instance, did you know ...

Yasiel Puig has bees in his pants

I’ve used this description for several years now, and someone once described it as a “turn of phrase” to me. I had to stop them, grab them by the wrist, look them in the eyes, and say, “This is not a turn of phrase. This is a literal fact. Yasiel Puig literally has bees in his pants. A writhing, stinging swarm of bees that ensure he will never be at rest, that he will never know peace. Pray for him. Pray for his merciful release.”

This true, literal fact informs many of the sections below this, so before you learn anything else, know that Puig has a living swarm of bees in his pants at all times. They are angry, bitey bees.

Yasiel Puig absolutely loves to show off his arm

Sometimes this manifests itself in an obvious way, which is Puig throwing a runner out.

These are tremendously fun, enjoyable baseball moments. But Puig can’t stop there. My working theory for this video is that Puig definitely knew there were three outs and didn’t care.

There will be a pitcher on second — let’s say it’s Rick Porcello after fouling a ball off his foot — and Puig will still fire to third base from 250 feet away. I get it, too. If I could play “Eruption” on a banjo, I would do it all the time. It would be the best party trick I had, so you can’t blame Puig. He’s doing what we would all do if we had that arm.

Yasiel Puig hustles

This is probably because he wants to humiliate everyone who is not Yasiel Puig, but we’re not here to psychoanalyze him. All you should know is that he hustles. He hustles in the field, constantly making you think he’s going to run right through a wall, like poor Bump Bailey from The Natural.

And even if he occasionally hustles his way into silly outs, his brand of base running is tremendous fun.

Look at how he dives! He goes into second like he’s screaming obscenities at Newtonian physics while trying to reach Earth’s core. This was in the first inning of a regular-season game, and no one would have blamed him if he just made a wide turn at first, and then moseyed back to first.

But the bees in his pants do not allow for any moseying. They are a ruthless taskmaster.

Yasiel Puig will also watch his long extra-base-hits

Well, maybe some moseying. Bees gotta sleep sometime.

That’s a bat-flipped double and probably not the best example, considering that only a second elapses before he realizes it’s not gone.

He holds this celebratory pose for a beat longer, but it’s also not the best example because he still stretches it into a stand-up triple:

There are other examples out there, but the videos elude me. The point is that Puig isn’t above watching a ball hit a fence, which is almost as entertaining as when he hits a hustle double.

Yasiel Puig is the greatest show on earth, according to Yasiel Puig

And he’s not wrong! But this is a useful way to think about him when he is doing Extremely Yasiel Puig Things.

Photo by Dylan Buell/Getty Images

He is not doing this to show up Jeremy Jeffress. He is doing this because it is what the moment demands. He is doing this because Yasiel Puig just did something grandiose, and the only logical reaction is to sell what just happened with the greatest showmanship he can muster.

And he can muster quite a lot, what with being the Greatest Show on Earth, and all.

Photo by Kevork Djansezian/Getty Images

Take the lead image up there. Just a guy lying down, gazing at the stars, which are also a part of the Truman Show-like set that was created for Puig and Puig alone. It’s why he is so quick to jump into a celebratory pose, even while the opposing player is behind him with a “Sir, this is a Wendy’s” look on his face.

Photo by Harry How/Getty Images

It’s why he’s the king of turning around and making faces while the ball is in play.

Photo by Kevork Djansezian/Getty Images

The best part is that all of the pictures in this post? They’re from the last week. I’ll work up a “Best Pictures of Yasiel Puig’s Career” post at one point and dig through the thousands, but for right now, I took a minute or two to find these examples of Puig putting on a show, and they work perfectly.

He’s doing this because the world is here to see Yasiel Puig, and he does not want to bore them. He is incapable of boring them. For he is our Greatest Showman. He hustles. He infuriates. He acts like someone convinced the world is desperate for more, more, more Yasiel Puig content and doesn’t want to disappoint his fans. He is pretty sure he’s the only person in this simulation, so he’d might as well live it up.

You should watch the World Series for all sorts of reasons, but now that you know a little bit about Puig, make sure to keep an closer eye on him. He usually makes it worthwhile.

[marymosley]

Emojis in Court

Love them or hate them, it looks like “emojis” are here to stay. As of this writing, more than 3,000 emojis have been officially recognized, standardized, and named by the Unicode Consortium (a group that cares very deeply about emojis, among other things) and they have been adopted for widespread use on cell phones, tablets, email clients, and social media platforms.

Emojis now exist as a way to succinctly express everything from the ordinary and familiar ( smiling face;  thumbs-up) to the surprisingly specific ( mountain cableway; moon viewing ceremony) to the routinely misunderstood ( not “angry” but rather “persevering face;”  not “shooting star” but rather “dizzy”), to the criminally repurposed ( snowflake to mean cocaine;  rocket to mean high drug potency).

The explosive growth of this alternative form of communication is raising some interesting questions for criminal attorneys and the court system as a whole. Should emojis be considered “statements,” on equal footing with written or spoken words? If they’re not statements, then what are they? Who decides what is meant by the use of a particular emoji? Do they have to be published to the jury and included in the record as images, or can they be summarized and described by words? What should practitioners do to make sure that emojis are accurately reflected in transcripts, court orders, and appellate opinions, since many court systems are text-based and do not allow for the inclusion of images?

Let’s about it.

Emojis? Really?

I’m afraid so. If this topic makes you  and want to  your , I sympathize. It took me far longer to find and insert those three images than it would have taken to simply type the words. But like it or not, emojis are showing up as evidence up in court cases with increasing frequency.

This topic garnered some national attention a few years ago, when the U.S. Supreme Court decided Elonis v. United States, 135 S.Ct. 2001 (2015). The defendant in Elonis challenged his conviction for threatening his estranged wife on Facebook, and one of the arguments on appeal was that the posts could not be interpreted as threats because the defendant included a smiley face emoji with the tongue sticking out, indicating that he was not serious. The emoji did not end up factoring into the Court’s opinion, but to some observers it was proof that emojis had finally arrived as an issue on the legal landscape, and would likely become more common and more significant.

Recent cases across the country seem to bear that prediction out. See, e.g., United States v. Jefferson, 911 F.3d 1290 (10th Cir. 2018) (affirming defendant’s robbery convictions, and noting that the “substantial” evidence of his guilt included not only surveillance videos and his admissions, but also a “Facebook post made after the January 9 robberies, which included a firearm emoji”);  Commonwealth v. Hunt, 94 Mass. App. Ct. 1123 (Feb. 22, 2019) (unpublished) (evidence on cross-examination to show nature of relationship and alleged bias of witness included text messages with “three kissey emoji,” “emoji of … two people with [a] heart … above their heads” and an “emoji of … [a] diamond ring”); State v. King, 2018 WL 4868127 (N.J. Super. Ct. App. Div., Oct. 9, 2018) (unpublished) (evidence in witness tampering case included Facebook post that included a picture of a subpoena, multiple references to the subject as a “rat,” and “seven middle finger emojis”).

According to Professor Eric Goldman, a law professor at Santa Clara University who tracks this issue, the prevalence of emojis in court cases across the country has followed a “J curve” pattern, beginning with just a few cases back in 2004 but then rising exponentially; in fact, more than 30% of all reported court cases mentioning emojis appeared in 2018 alone.

I have not yet seen any North Carolina or 4th Circuit cases in which the presence, admissibility, or meaning of an emoji was a crucial factor in the decision, but they are undoubtedly beginning to show up in the evidence. See, e.g., State v. Aracena, __ N.C. App. __, 817 S.E.2d 628 (Aug. 21, 2018) (unpublished) (evidence in robbery and assault case included a Facebook post directed at victim boasting about the assault, along with “five laughing emojis with tears coming out”); see also Nexus Services, Inc., v. Moran, 2018 WL 1461750 (W.D. Va., March 23, 2018) (concluding that an email between two co-workers which contained a “Hitler emoji” was not an attempt to chill plaintiff’s speech – it had to be “taken in context” where “one was jokingly calling the other a ‘meanie’ and a taskmaster”).

Emojis: Words, Thoughts, Both, or Neither?

As explained here, emojis first appeared in the mid- to late-1990’s as a feature on select Japanese cell phones, but their popularity exploded in the early 2000’s after they were standardized to work across multiple platforms and in different countries. The term “emoji” comes from the Japanese words “e” (絵, or “picture”) and “moji” (文字, or “character”), so emoji literally means “picture character.”

Emojis aren’t words in the traditional sense, of course, but it’s clear that they are something more communicative than mere doodles or illustrations.  Like their text-based ancestors known as “emoticons” (figures or symbols such as  ¯\_(ツ)_/¯ or :-), created with regular keyboard characters), emojis can be used to add context and tone to an accompanying statement, or they can express a separate and independent thought on their own. Conceptually, this makes emojis analogous to gestures, nods, or facial expressions that can likewise modify the meaning of accompanying words (like a shrug for “no offense,” or a glare for “I’m not kidding”), or convey a complete thought (like a nod to mean “yes,” or pointing to mean “over there”), depending on the circumstances.

Until we receive specific guidance from North Carolina’s appellate courts, and in light of the fact that emojis are being used as a form of communication, the most logical approach is to treat them as “statements,” comparable to any other type of “written or oral assertion or nonverbal conduct intended by the declarant as an assertion.” G.S. 8C-1, Rule 801(a) (definition of hearsay); see also State v. Satterfield, 316 N.C. 55 (1986) (“An act, such as a gesture, can be a statement for purposes of applying rules concerning hearsay”). Treating emojis as nonverbal statements provides a ready-made body of law for tackling issues like relevance and admissibility, which is a great start, but it gets a little more complicated when we turn to the matter of interpretation.

What Do Emojis Mean?

Imagine a troubled young defendant who texts his girlfriend that he is willing to   her disapproving parents so that they can finally be together. She texts back with what the Unicode Consortium calls the “folded hands” emoji: . What does that reply mean? Is it hands clasped in prayer, begging him not to do it? Or praying that he will? Or perhaps she misunderstands the emoji and thinks it’s a “high five,” celebrating their murderous plan? Additionally, consider what happens if the sender and receiver are using different cell phones or operating systems. The same emoji, “pistol,” displays this way on a Microsoft device:  but it shows up like this on an LG smartphone:  . The potential for misunderstandings and conflicting interpretations is (literally) easy to see.

In many cases, the jurors will make the final determination about the true meaning or intent behind an ambiguous emoji, just as they would with any other potentially incriminating statement that the declarant contends was “only a joke” or “not how I meant it.” And to help the jury answer those questions, it appears that we have already entered the age of emoji interpretation expert witnesses. In a recent human trafficking case out of California, the state qualified a detective “as an expert in the areas of pimping, pandering and prostitution,” based on his training and experience, and the expert was permitted to testify about several emojis that the defendant texted (a crown, high heels, and bags of money) and the meaning of those images “specific to commercial … sexual exploitation.” See People v. Jamerson, 2019 WL 459012 (Cal. Ct. App., February 6, 2019) (unpublished).

But judges, magistrates, attorneys, and law enforcement officers also need to become at least conversationally fluent in emoji-speak, in order to address a number of other issues that could surface before trial. For example, is the “folded hands” emoji in the example above enough to charge the girlfriend with conspiracy? Is it admissible at trial as a statement of a co-conspirator? If the girlfriend testifies and insists that her reply meant “I’m praying you don’t do it,” can the state still argue the mistaken high five interpretation as a “reasonable inference” in closing? Opposing parties will inevitably disagree on what certain emojis mean, but it helps if both sides can at least agree on their names and recognize the differences between them.

How to Publish and Preserve

The growing use of emojis in texts, social media posts, and emails poses two additional problems for the court system. First, how should emojis be presented in court proceedings, such as when an officer is using them as part of a warrant application, or when an attorney wants to publish them to the jury? Second, how should they be documented and preserved in court records, such as transcripts or appellate opinions?

Whenever possible, the best option is to use the entire text, email, or post, showing all the words and emojis together. Officers can attach a printout or screenshot to their warrant applications, and attorneys can publish to the jury by handing out copies and letting the jurors see it for themselves. This approach helps to avoid disputes about misrepresentation or cross-platform display errors, and best ensures that the full and true intent of the communication will be conveyed (whatever the parties contend that intent is).

If including an image is not possible, it is imperative that the written description of the emojis be as complete and accurate as possible, preferably by using the standardized Unicode Consortium names. There are 148 different emojis listed in the “Smileys and Emotion” category alone, so a vague description like “smiley face emoji” could lead to confusion or error. In addition to its distinctive name, every emoji also has a unique code assigned to it. Including both the full name and the code in the description will ensure that “sleepy face” (, U+1 F62A) is not incorrectly characterized as “drooling face” (, U+1 F924).

The least desirable option is to leave the emojis out entirely, or replace them with a generic placeholder in brackets like [emojis omitted] or [various emojis]. For all the reasons explained above, this option doesn’t accurately convey the full meaning of the statement. See, e.g., United States v. Johnson, 280 F. Supp. 3d 772 (D. Md., Nov. 21, 2017) (referencing an Instagram post where defendant wrote “…they welcomed me home like it was 88 [emojis]. Real luv never fails…”). The post in Johnson would read quite differently if the defendant said he was being “welcomed home” with  instead of .

Emoji or Emojis?

Finally, what is the correct plural of emoji? If there are several of them in a row, is it still “emoji” like we would say “the seven samurai,” or should it be “emojis” like we would say “multiple tsunamis?” As you can tell from this post I’ve already made my choice, but for a contrary view check out this Atlantic article. Let the comment war begin.

The post Emojis in Court appeared first on North Carolina Criminal Law.

Emojis in Court published first on https://immigrationlawyerto.tumblr.com/

[thegoodlifebiz-blog]

3 Realistic Online Business Opportunities I Personally Use

3 Realistic Online Business Opportunities I Personally Use

If you're anything like me you're feeling trapped by the restrictions of your chosen career. A year ago I decided it was time to reclaim my life and my future and begin working toward building a business that would give back my time, bring fulfillment and financial freedom. The idea of working from home or even while traveling sounded like a dream to me; and if it sounds like something you'd prefer over your current work-life balance then read on. I've listed 3 legitimate online business opportunities that have been profitable for me and might just turn out to be a great place for you to start too! Are you figuring out how to start a business of your own and what type of online business opportunities you're most suited to? I bet it didn't take long to figure out that there are literally 1000's of get-rich-quick schemes instead of legitimate online business opportunities advertised online. So by now you realize that starting an online business isn’t going to be as easy as you first thought. But the good news is that it IS well worth persevering when you find one that's right for you! Let's take a closer look at 3 REALISTIC online business opportunities and see if I can help you to reach a light bulb moment!

3 REALISTIC Online Business Opportunities I've Used

Online Business #1 - Freelancing

Do you have great organizational and task management skills? Why not stack the odds in your favor by playing to your strengths? There is a whole range of tasks you can do that both individuals and businesses need to outsource regularly. As far as online business opportunities go this is akin to virtual subcontracting. Wikipedia's definition; A freelancer or freelance worker is a term commonly used for a person who is self-employed and is not necessarily committed to a particular employer long-term.

STEPS TO TAKE:

BRAINSTORM YOUR STRENGTHS: Why not put fingers to keyboard and start making a list of the things you currently do for yourself and your loved ones that you have a special talent for or just love doing? RESEARCH THE MARKET: Use Google to find out if there is a need for the strengths and services you came up with. TAKE ACTION: Pick one or 2 outsourcing platforms and set up a profile. A few that I use are Freelancer & Airtasker and there are lots of others too! INVESTMENT: Nil PRO'S: No additional skills required, focused on your existing strengths and interests, pick and choose the jobs to bid for or accept, Freelancer & Airtasker bring your clients to you. CON'S: The income per task is be limited to what the taskmaster is willing to pay. Also, you will be bidding for tasks in a highly competitive environment. Freelancer & Airtasker will both take a percentage of your hard-earned cash. It's difficult to establish long-term clients in this environment so be mindful that you will always be playing the bidding game. It's worth keeping in mind that the person who posted the task has the power to withhold payment and leave negative feedback if they're not 100% satisfied with the quality of your work.

Online Business #2 Affiliate Marketer 

Easily the most accessible online business opportunity for anyone to get up and running quickly. The possibilities are only limited by your imagination. One of the simplest examples of Affiliate Marketing is blogging. Bloggers write posts about topics they're either interested in or knowledgeable about. However, blogging is NOT the only way to build an Affiliate Marketing business. Grab our Free Video Series or jump into our Free Affiliate Marketing School to learn more about setting up an Affiliate Marketing business with minimal fuss and a tonne of expert advice that will save you time and money setting up this kind of business. Wikipedia's definition: Affiliate marketing is a type of performance-based marketing in which a business rewards one or more affiliates for each visitor or customer brought by the affiliate's own marketing efforts.

STEPS TO TAKE:

FIND 2-3 AFFILIATE PROGRAMS I recommend starting with only 2-3 affiliate programs, to begin with. Joining too many when you're just getting started can mean spreading your resources too thin. At least one of the affiliate programs you choose will need to pay high affiliate commissions (preferably over $1000 per sale). The other two affiliate programs will need to complement the primary affiliate program in some way. START BUILDING A SUBSCRIBER LIST: Altho you don't need your own email list to start marketing affiliate products and services, it sure does make life easier and a lot more lucrative. I learned a lot about how to attract free targeted traffic and grow my own subscriber list on this Free Membership Site. START BLOGGING: This is something you can choose to do yourself if you love writing or recording videos, or you can easily outsource this for a minimal fee. Blogging is a great way to reach and connect with people who share an interest in what you have to say and the products and services you're interested in and blog about. More about blogging for profit here. Make sure your posts bridge the gap between your chosen affiliate products and services and the people who want them. Blogging is also one of the most cost-effective ways of growing your subscriber list. EMAIL AUTORESPONDERS: You will need a way to collect your subscribers when they visit your blog or website as well as connect and build a relationship with your subscribers regularly. Fortunately, you do both with AWeber and they are offering a FREE 30 Day Trial for new members. For more in-depth information about email autoresponders make sure you check out my post on email marketing which includes video demos. INVESTMENT: There are lots of Affiliate Programs available for free when searching for complimentary affiliate programs. However, ones offering high commissions will usually come with a small affiliate membership fee. More about choosing a high paying affiliate partner here. PRO'S: It's a great way to build a business around your existing knowledge base, strengths, and interests. No need for a business idea of your own. No time and money wasted on purchasing stock, testing products in the marketplace. No need to have an e-commerce website of your own. Once established, this kind of business will bring time and financial freedom. CON'S: A willingness to invest time in learning effective affiliate marketing practices.

Online Business #3 E-commerce - Amazon/eBay/Shopify

Building an e-commerce business can take quite a bit of work to get started but once set up, it will practically run itself. It's a good idea to start with just one or two products to test in the market before jumping in boots n all! I suggest focusing on just one of the major seller platforms while you're getting started, get to know it and how to leverage all the features before branching out to others. Amazon has a brilliant new-seller support team, they are happy to jump on the phone and walk you through any issues you may be facing. If you're looking for a business you can scale over time you can take your income levels to 6 figures and higher by selling on other platforms and creating your own retail websites. The point is, the sky’s the limit! Wikipedia's definition: Modern electronic commerce typically uses the internet for at least one part of the transaction's life cycle although it may also use other technologies such as e-mail. Typical e-commerce transactions include the purchase of online books (such as Amazon) and music purchases (music download in the form of digital distribution such as iTunes Store).

STEPS TO TAKE:

SOURCE OR DEVELOP A PRODUCT: Perhaps you have your own product you'd like to develop and take to market? Or maybe you'd like to try importing a product that's already proven in the marketplace? An easy place to get started sourcing products to sell on Amazon or eBay is DHgate, however, not all sellers on DHgate are trustworthy so make sure you read the reviews. IMPORT YOUR PRODUCT: This is where things can get a little tricky in the early days if you're new to the importing game. Navigating all the legalities of customs and import fees, logistics and distribution can be a little overwhelming and it pays to get the right information and have good relationships with the factories you are importing from before you start ordering large quantities. I suggest reading this before diving in head first, particularly if you are new to the importing game. INVESTMENT: Getting started with one or two products can be an inexpensive way to get a legitimate and profitable e-commerce business off the ground reasonably quickly. You'll be looking at the cost of importing your products and whatever fee's and charges are incurred with selling them on Amazon, eBay or whatever seller platform you choose. If you haven't checked out our Import Experts page yet make sure to watch our short video for expert tips on the safest way to getting yourself set up importing with minimal fuss and how to set up shop leveraging Amazon FDA. PRO'S: As far as online business opportunities go; an e-commerce business can be up and running in a matter of weeks. No limit to the variety of products you can sell. No limit to the size of the market you can sell to. Easily scalable. Once established, this kind of business will bring time and financial freedom. CON'S: Upfront cash investment to purchase and import your chosen product. You will need to do product and market research. You will need a willingness to spend time learning how to import products safely and how to market them online. So with all that said here's your chance to start a legitimate online business. Is it your time to get off the sidelines and create the ultimate financial and lifestyle freedom for yourself? By now, you have 3 genuine online business opportunities that have been proven to work over and over again.  Be sure to report back and let me know how you’re going! Disclosure: Some of the links in this post are affiliate links. I will only make recommendations on products and services  I personally believe to be of value.  Read the full article

[marymosley]

Emojis in Court

Love them or hate them, it looks like “emojis” are here to stay. As of this writing, more than 3,000 emojis have been officially recognized, standardized, and named by the Unicode Consortium (a group that cares very deeply about emojis, among other things) and they have been adopted for widespread use on cell phones, tablets, email clients, and social media platforms.

Emojis now exist as a way to succinctly express everything from the ordinary and familiar ( smiling face;  thumbs-up) to the surprisingly specific ( mountain cableway; moon viewing ceremony) to the routinely misunderstood ( not “angry” but rather “persevering face;”  not “shooting star” but rather “dizzy”), to the criminally repurposed ( snowflake to mean cocaine;  rocket to mean high drug potency).

The explosive growth of this alternative form of communication is raising some interesting questions for criminal attorneys and the court system as a whole. Should emojis be considered “statements,” on equal footing with written or spoken words? If they’re not statements, then what are they? Who decides what is meant by the use of a particular emoji? Do they have to be published to the jury and included in the record as images, or can they be summarized and described by words? What should practitioners do to make sure that emojis are accurately reflected in transcripts, court orders, and appellate opinions, since many court systems are text-based and do not allow for the inclusion of images?

Let’s about it.

Emojis? Really?

I’m afraid so. If this topic makes you  and want to  your , I sympathize. It took me far longer to find and insert those three images than it would have taken to simply type the words. But like it or not, emojis are showing up as evidence up in court cases with increasing frequency.

This topic garnered some national attention a few years ago, when the U.S. Supreme Court decided Elonis v. United States, 135 S.Ct. 2001 (2015). The defendant in Elonis challenged his conviction for threatening his estranged wife on Facebook, and one of the arguments on appeal was that the posts could not be interpreted as threats because the defendant included a smiley face emoji with the tongue sticking out, indicating that he was not serious. The emoji did not end up factoring into the Court’s opinion, but to some observers it was proof that emojis had finally arrived as an issue on the legal landscape, and would likely become more common and more significant.

Recent cases across the country seem to bear that prediction out. See, e.g., United States v. Jefferson, 911 F.3d 1290 (10th Cir. 2018) (affirming defendant’s robbery convictions, and noting that the “substantial” evidence of his guilt included not only surveillance videos and his admissions, but also a “Facebook post made after the January 9 robberies, which included a firearm emoji”);  Commonwealth v. Hunt, 94 Mass. App. Ct. 1123 (Feb. 22, 2019) (unpublished) (evidence on cross-examination to show nature of relationship and alleged bias of witness included text messages with “three kissey emoji,” “emoji of … two people with [a] heart … above their heads” and an “emoji of … [a] diamond ring”); State v. King, 2018 WL 4868127 (N.J. Super. Ct. App. Div., Oct. 9, 2018) (unpublished) (evidence in witness tampering case included Facebook post that included a picture of a subpoena, multiple references to the subject as a “rat,” and “seven middle finger emojis”).

According to Professor Eric Goldman, a law professor at Santa Clara University who tracks this issue, the prevalence of emojis in court cases across the country has followed a “J curve” pattern, beginning with just a few cases back in 2004 but then rising exponentially; in fact, more than 30% of all reported court cases mentioning emojis appeared in 2018 alone.

I have not yet seen any North Carolina or 4th Circuit cases in which the presence, admissibility, or meaning of an emoji was a crucial factor in the decision, but they are undoubtedly beginning to show up in the evidence. See, e.g., State v. Aracena, __ N.C. App. __, 817 S.E.2d 628 (Aug. 21, 2018) (unpublished) (evidence in robbery and assault case included a Facebook post directed at victim boasting about the assault, along with “five laughing emojis with tears coming out”); see also Nexus Services, Inc., v. Moran, 2018 WL 1461750 (W.D. Va., March 23, 2018) (concluding that an email between two co-workers which contained a “Hitler emoji” was not an attempt to chill plaintiff’s speech – it had to be “taken in context” where “one was jokingly calling the other a ‘meanie’ and a taskmaster”).

Emojis: Words, Thoughts, Both, or Neither?

As explained here, emojis first appeared in the mid- to late-1990’s as a feature on select Japanese cell phones, but their popularity exploded in the early 2000’s after they were standardized to work across multiple platforms and in different countries. The term “emoji” comes from the Japanese words “e” (絵, or “picture”) and “moji” (文字, or “character”), so emoji literally means “picture character.”

Emojis aren’t words in the traditional sense, of course, but it’s clear that they are something more communicative than mere doodles or illustrations.  Like their text-based ancestors known as “emoticons” (figures or symbols such as  ¯\_(ツ)_/¯ or :-), created with regular keyboard characters), emojis can be used to add context and tone to an accompanying statement, or they can express a separate and independent thought on their own. Conceptually, this makes emojis analogous to gestures, nods, or facial expressions that can likewise modify the meaning of accompanying words (like a shrug for “no offense,” or a glare for “I’m not kidding”), or convey a complete thought (like a nod to mean “yes,” or pointing to mean “over there”), depending on the circumstances.

Until we receive specific guidance from North Carolina’s appellate courts, and in light of the fact that emojis are being used as a form of communication, the most logical approach is to treat them as “statements,” comparable to any other type of “written or oral assertion or nonverbal conduct intended by the declarant as an assertion.” G.S. 8C-1, Rule 801(a) (definition of hearsay); see also State v. Satterfield, 316 N.C. 55 (1986) (“An act, such as a gesture, can be a statement for purposes of applying rules concerning hearsay”). Treating emojis as nonverbal statements provides a ready-made body of law for tackling issues like relevance and admissibility, which is a great start, but it gets a little more complicated when we turn to the matter of interpretation.

What Do Emojis Mean?

Imagine a troubled young defendant who texts his girlfriend that he is willing to   her disapproving parents so that they can finally be together. She texts back with what the Unicode Consortium calls the “folded hands” emoji: . What does that reply mean? Is it hands clasped in prayer, begging him not to do it? Or praying that he will? Or perhaps she misunderstands the emoji and thinks it’s a “high five,” celebrating their murderous plan? Additionally, consider what happens if the sender and receiver are using different cell phones or operating systems. The same emoji, “pistol,” displays this way on a Microsoft device:  but it shows up like this on an LG smartphone:  . The potential for misunderstandings and conflicting interpretations is (literally) easy to see.

In many cases, the jurors will make the final determination about the true meaning or intent behind an ambiguous emoji, just as they would with any other potentially incriminating statement that the declarant contends was “only a joke” or “not how I meant it.” And to help the jury answer those questions, it appears that we have already entered the age of emoji interpretation expert witnesses. In a recent human trafficking case out of California, the state qualified a detective “as an expert in the areas of pimping, pandering and prostitution,” based on his training and experience, and the expert was permitted to testify about several emojis that the defendant texted (a crown, high heels, and bags of money) and the meaning of those images “specific to commercial … sexual exploitation.” See People v. Jamerson, 2019 WL 459012 (Cal. Ct. App., February 6, 2019) (unpublished).

But judges, magistrates, attorneys, and law enforcement officers also need to become at least conversationally fluent in emoji-speak, in order to address a number of other issues that could surface before trial. For example, is the “folded hands” emoji in the example above enough to charge the girlfriend with conspiracy? Is it admissible at trial as a statement of a co-conspirator? If the girlfriend testifies and insists that her reply meant “I’m praying you don’t do it,” can the state still argue the mistaken high five interpretation as a “reasonable inference” in closing? Opposing parties will inevitably disagree on what certain emojis mean, but it helps if both sides can at least agree on their names and recognize the differences between them.

How to Publish and Preserve

The growing use of emojis in texts, social media posts, and emails poses two additional problems for the court system. First, how should emojis be presented in court proceedings, such as when an officer is using them as part of a warrant application, or when an attorney wants to publish them to the jury? Second, how should they be documented and preserved in court records, such as transcripts or appellate opinions?

Whenever possible, the best option is to use the entire text, email, or post, showing all the words and emojis together. Officers can attach a printout or screenshot to their warrant applications, and attorneys can publish to the jury by handing out copies and letting the jurors see it for themselves. This approach helps to avoid disputes about misrepresentation or cross-platform display errors, and best ensures that the full and true intent of the communication will be conveyed (whatever the parties contend that intent is).

If including an image is not possible, it is imperative that the written description of the emojis be as complete and accurate as possible, preferably by using the standardized Unicode Consortium names. There are 148 different emojis listed in the “Smileys and Emotion” category alone, so a vague description like “smiley face emoji” could lead to confusion or error. In addition to its distinctive name, every emoji also has a unique code assigned to it. Including both the full name and the code in the description will ensure that “sleepy face” (, U+1 F62A) is not incorrectly characterized as “drooling face” (, U+1 F924).

The least desirable option is to leave the emojis out entirely, or replace them with a generic placeholder in brackets like [emojis omitted] or [various emojis]. For all the reasons explained above, this option doesn’t accurately convey the full meaning of the statement. See, e.g., United States v. Johnson, 280 F. Supp. 3d 772 (D. Md., Nov. 21, 2017) (referencing an Instagram post where defendant wrote “…they welcomed me home like it was 88 [emojis]. Real luv never fails…”). The post in Johnson would read quite differently if the defendant said he was being “welcomed home” with  instead of .

Emoji or Emojis?

Finally, what is the correct plural of emoji? If there are several of them in a row, is it still “emoji” like we would say “the seven samurai,” or should it be “emojis” like we would say “multiple tsunamis?” As you can tell from this post I’ve already made my choice, but for a contrary view check out this Atlantic article. Let the comment war begin.

The post Emojis in Court appeared first on North Carolina Criminal Law.

Emojis in Court published first on https://immigrationlawyerto.tumblr.com/

[marymosley]

Emojis in Court

Love them or hate them, it looks like “emojis” are here to stay. As of this writing, more than 3,000 emojis have been officially recognized, standardized, and named by the Unicode Consortium (a group that cares very deeply about emojis, among other things) and they have been adopted for widespread use on cell phones, tablets, email clients, and social media platforms.

Emojis now exist as a way to succinctly express everything from the ordinary and familiar ( smiling face;  thumbs-up) to the surprisingly specific ( mountain cableway; moon viewing ceremony) to the routinely misunderstood ( not “angry” but rather “persevering face;”  not “shooting star” but rather “dizzy”), to the criminally repurposed ( snowflake to mean cocaine;  rocket to mean high drug potency).

The explosive growth of this alternative form of communication is raising some interesting questions for criminal attorneys and the court system as a whole. Should emojis be considered “statements,” on equal footing with written or spoken words? If they’re not statements, then what are they? Who decides what is meant by the use of a particular emoji? Do they have to be published to the jury and included in the record as images, or can they be summarized and described by words? What should practitioners do to make sure that emojis are accurately reflected in transcripts, court orders, and appellate opinions, since many court systems are text-based and do not allow for the inclusion of images?

Let’s about it.

Emojis? Really?

I’m afraid so. If this topic makes you  and want to  your , I sympathize. It took me far longer to find and insert those three images than it would have taken to simply type the words. But like it or not, emojis are showing up as evidence up in court cases with increasing frequency.

This topic garnered some national attention a few years ago, when the U.S. Supreme Court decided Elonis v. United States, 135 S.Ct. 2001 (2015). The defendant in Elonis challenged his conviction for threatening his estranged wife on Facebook, and one of the arguments on appeal was that the posts could not be interpreted as threats because the defendant included a smiley face emoji with the tongue sticking out, indicating that he was not serious. The emoji did not end up factoring into the Court’s opinion, but to some observers it was proof that emojis had finally arrived as an issue on the legal landscape, and would likely become more common and more significant.

Recent cases across the country seem to bear that prediction out. See, e.g., United States v. Jefferson, 911 F.3d 1290 (10th Cir. 2018) (affirming defendant’s robbery convictions, and noting that the “substantial” evidence of his guilt included not only surveillance videos and his admissions, but also a “Facebook post made after the January 9 robberies, which included a firearm emoji”);  Commonwealth v. Hunt, 94 Mass. App. Ct. 1123 (Feb. 22, 2019) (unpublished) (evidence on cross-examination to show nature of relationship and alleged bias of witness included text messages with “three kissey emoji,” “emoji of … two people with [a] heart … above their heads” and an “emoji of … [a] diamond ring”); State v. King, 2018 WL 4868127 (N.J. Super. Ct. App. Div., Oct. 9, 2018) (unpublished) (evidence in witness tampering case included Facebook post that included a picture of a subpoena, multiple references to the subject as a “rat,” and “seven middle finger emojis”).

According to Professor Eric Goldman, a law professor at Santa Clara University who tracks this issue, the prevalence of emojis in court cases across the country has followed a “J curve” pattern, beginning with just a few cases back in 2004 but then rising exponentially; in fact, more than 30% of all reported court cases mentioning emojis appeared in 2018 alone.

I have not yet seen any North Carolina or 4th Circuit cases in which the presence, admissibility, or meaning of an emoji was a crucial factor in the decision, but they are undoubtedly beginning to show up in the evidence. See, e.g., State v. Aracena, __ N.C. App. __, 817 S.E.2d 628 (Aug. 21, 2018) (unpublished) (evidence in robbery and assault case included a Facebook post directed at victim boasting about the assault, along with “five laughing emojis with tears coming out”); see also Nexus Services, Inc., v. Moran, 2018 WL 1461750 (W.D. Va., March 23, 2018) (concluding that an email between two co-workers which contained a “Hitler emoji” was not an attempt to chill plaintiff’s speech – it had to be “taken in context” where “one was jokingly calling the other a ‘meanie’ and a taskmaster”).

Emojis: Words, Thoughts, Both, or Neither?

As explained here, emojis first appeared in the mid- to late-1990’s as a feature on select Japanese cell phones, but their popularity exploded in the early 2000’s after they were standardized to work across multiple platforms and in different countries. The term “emoji” comes from the Japanese words “e” (絵, or “picture”) and “moji” (文字, or “character”), so emoji literally means “picture character.”

Emojis aren’t words in the traditional sense, of course, but it’s clear that they are something more communicative than mere doodles or illustrations.  Like their text-based ancestors known as “emoticons” (figures or symbols such as  ¯\_(ツ)_/¯ or :-), created with regular keyboard characters), emojis can be used to add context and tone to an accompanying statement, or they can express a separate and independent thought on their own. Conceptually, this makes emojis analogous to gestures, nods, or facial expressions that can likewise modify the meaning of accompanying words (like a shrug for “no offense,” or a glare for “I’m not kidding”), or convey a complete thought (like a nod to mean “yes,” or pointing to mean “over there”), depending on the circumstances.

Until we receive specific guidance from North Carolina’s appellate courts, and in light of the fact that emojis are being used as a form of communication, the most logical approach is to treat them as “statements,” comparable to any other type of “written or oral assertion or nonverbal conduct intended by the declarant as an assertion.” G.S. 8C-1, Rule 801(a) (definition of hearsay); see also State v. Satterfield, 316 N.C. 55 (1986) (“An act, such as a gesture, can be a statement for purposes of applying rules concerning hearsay”). Treating emojis as nonverbal statements provides a ready-made body of law for tackling issues like relevance and admissibility, which is a great start, but it gets a little more complicated when we turn to the matter of interpretation.

What Do Emojis Mean?

Imagine a troubled young defendant who texts his girlfriend that he is willing to   her disapproving parents so that they can finally be together. She texts back with what the Unicode Consortium calls the “folded hands” emoji: . What does that reply mean? Is it hands clasped in prayer, begging him not to do it? Or praying that he will? Or perhaps she misunderstands the emoji and thinks it’s a “high five,” celebrating their murderous plan? Additionally, consider what happens if the sender and receiver are using different cell phones or operating systems. The same emoji, “pistol,” displays this way on a Microsoft device:  but it shows up like this on an LG smartphone:  . The potential for misunderstandings and conflicting interpretations is (literally) easy to see.

In many cases, the jurors will make the final determination about the true meaning or intent behind an ambiguous emoji, just as they would with any other potentially incriminating statement that the declarant contends was “only a joke” or “not how I meant it.” And to help the jury answer those questions, it appears that we have already entered the age of emoji interpretation expert witnesses. In a recent human trafficking case out of California, the state qualified a detective “as an expert in the areas of pimping, pandering and prostitution,” based on his training and experience, and the expert was permitted to testify about several emojis that the defendant texted (a crown, high heels, and bags of money) and the meaning of those images “specific to commercial … sexual exploitation.” See People v. Jamerson, 2019 WL 459012 (Cal. Ct. App., February 6, 2019) (unpublished).

But judges, magistrates, attorneys, and law enforcement officers also need to become at least conversationally fluent in emoji-speak, in order to address a number of other issues that could surface before trial. For example, is the “folded hands” emoji in the example above enough to charge the girlfriend with conspiracy? Is it admissible at trial as a statement of a co-conspirator? If the girlfriend testifies and insists that her reply meant “I’m praying you don’t do it,” can the state still argue the mistaken high five interpretation as a “reasonable inference” in closing? Opposing parties will inevitably disagree on what certain emojis mean, but it helps if both sides can at least agree on their names and recognize the differences between them.

How to Publish and Preserve

The growing use of emojis in texts, social media posts, and emails poses two additional problems for the court system. First, how should emojis be presented in court proceedings, such as when an officer is using them as part of a warrant application, or when an attorney wants to publish them to the jury? Second, how should they be documented and preserved in court records, such as transcripts or appellate opinions?

Whenever possible, the best option is to use the entire text, email, or post, showing all the words and emojis together. Officers can attach a printout or screenshot to their warrant applications, and attorneys can publish to the jury by handing out copies and letting the jurors see it for themselves. This approach helps to avoid disputes about misrepresentation or cross-platform display errors, and best ensures that the full and true intent of the communication will be conveyed (whatever the parties contend that intent is).

If including an image is not possible, it is imperative that the written description of the emojis be as complete and accurate as possible, preferably by using the standardized Unicode Consortium names. There are 148 different emojis listed in the “Smileys and Emotion” category alone, so a vague description like “smiley face emoji” could lead to confusion or error. In addition to its distinctive name, every emoji also has a unique code assigned to it. Including both the full name and the code in the description will ensure that “sleepy face” (, U+1 F62A) is not incorrectly characterized as “drooling face” (, U+1 F924).

The least desirable option is to leave the emojis out entirely, or replace them with a generic placeholder in brackets like [emojis omitted] or [various emojis]. For all the reasons explained above, this option doesn’t accurately convey the full meaning of the statement. See, e.g., United States v. Johnson, 280 F. Supp. 3d 772 (D. Md., Nov. 21, 2017) (referencing an Instagram post where defendant wrote “…they welcomed me home like it was 88 [emojis]. Real luv never fails…”). The post in Johnson would read quite differently if the defendant said he was being “welcomed home” with  instead of .

Emoji or Emojis?

Finally, what is the correct plural of emoji? If there are several of them in a row, is it still “emoji” like we would say “the seven samurai,” or should it be “emojis” like we would say “multiple tsunamis?” As you can tell from this post I’ve already made my choice, but for a contrary view check out this Atlantic article. Let the comment war begin.

The post Emojis in Court appeared first on North Carolina Criminal Law.

Emojis in Court published first on https://immigrationlawyerto.tumblr.com/

[marymosley]

Emojis in Court

Love them or hate them, it looks like “emojis” are here to stay. As of this writing, more than 3,000 emojis have been officially recognized, standardized, and named by the Unicode Consortium (a group that cares very deeply about emojis, among other things) and they have been adopted for widespread use on cell phones, tablets, email clients, and social media platforms.

Emojis now exist as a way to succinctly express everything from the ordinary and familiar ( smiling face;  thumbs-up) to the surprisingly specific ( mountain cableway; moon viewing ceremony) to the routinely misunderstood ( not “angry” but rather “persevering face;”  not “shooting star” but rather “dizzy”), to the criminally repurposed ( snowflake to mean cocaine;  rocket to mean high drug potency).

The explosive growth of this alternative form of communication is raising some interesting questions for criminal attorneys and the court system as a whole. Should emojis be considered “statements,” on equal footing with written or spoken words? If they’re not statements, then what are they? Who decides what is meant by the use of a particular emoji? Do they have to be published to the jury and included in the record as images, or can they be summarized and described by words? What should practitioners do to make sure that emojis are accurately reflected in transcripts, court orders, and appellate opinions, since many court systems are text-based and do not allow for the inclusion of images?

Let’s about it.

Emojis? Really?

I’m afraid so. If this topic makes you  and want to  your , I sympathize. It took me far longer to find and insert those three images than it would have taken to simply type the words. But like it or not, emojis are showing up as evidence up in court cases with increasing frequency.

This topic garnered some national attention a few years ago, when the U.S. Supreme Court decided Elonis v. United States, 135 S.Ct. 2001 (2015). The defendant in Elonis challenged his conviction for threatening his estranged wife on Facebook, and one of the arguments on appeal was that the posts could not be interpreted as threats because the defendant included a smiley face emoji with the tongue sticking out, indicating that he was not serious. The emoji did not end up factoring into the Court’s opinion, but to some observers it was proof that emojis had finally arrived as an issue on the legal landscape, and would likely become more common and more significant.

Recent cases across the country seem to bear that prediction out. See, e.g., United States v. Jefferson, 911 F.3d 1290 (10th Cir. 2018) (affirming defendant’s robbery convictions, and noting that the “substantial” evidence of his guilt included not only surveillance videos and his admissions, but also a “Facebook post made after the January 9 robberies, which included a firearm emoji”);  Commonwealth v. Hunt, 94 Mass. App. Ct. 1123 (Feb. 22, 2019) (unpublished) (evidence on cross-examination to show nature of relationship and alleged bias of witness included text messages with “three kissey emoji,” “emoji of … two people with [a] heart … above their heads” and an “emoji of … [a] diamond ring”); State v. King, 2018 WL 4868127 (N.J. Super. Ct. App. Div., Oct. 9, 2018) (unpublished) (evidence in witness tampering case included Facebook post that included a picture of a subpoena, multiple references to the subject as a “rat,” and “seven middle finger emojis”).

According to Professor Eric Goldman, a law professor at Santa Clara University who tracks this issue, the prevalence of emojis in court cases across the country has followed a “J curve” pattern, beginning with just a few cases back in 2004 but then rising exponentially; in fact, more than 30% of all reported court cases mentioning emojis appeared in 2018 alone.

I have not yet seen any North Carolina or 4th Circuit cases in which the presence, admissibility, or meaning of an emoji was a crucial factor in the decision, but they are undoubtedly beginning to show up in the evidence. See, e.g., State v. Aracena, __ N.C. App. __, 817 S.E.2d 628 (Aug. 21, 2018) (unpublished) (evidence in robbery and assault case included a Facebook post directed at victim boasting about the assault, along with “five laughing emojis with tears coming out”); see also Nexus Services, Inc., v. Moran, 2018 WL 1461750 (W.D. Va., March 23, 2018) (concluding that an email between two co-workers which contained a “Hitler emoji” was not an attempt to chill plaintiff’s speech – it had to be “taken in context” where “one was jokingly calling the other a ‘meanie’ and a taskmaster”).

Emojis: Words, Thoughts, Both, or Neither?

As explained here, emojis first appeared in the mid- to late-1990’s as a feature on select Japanese cell phones, but their popularity exploded in the early 2000’s after they were standardized to work across multiple platforms and in different countries. The term “emoji” comes from the Japanese words “e” (絵, or “picture”) and “moji” (文字, or “character”), so emoji literally means “picture character.”

Emojis aren’t words in the traditional sense, of course, but it’s clear that they are something more communicative than mere doodles or illustrations.  Like their text-based ancestors known as “emoticons” (figures or symbols such as  ¯\_(ツ)_/¯ or :-), created with regular keyboard characters), emojis can be used to add context and tone to an accompanying statement, or they can express a separate and independent thought on their own. Conceptually, this makes emojis analogous to gestures, nods, or facial expressions that can likewise modify the meaning of accompanying words (like a shrug for “no offense,” or a glare for “I’m not kidding”), or convey a complete thought (like a nod to mean “yes,” or pointing to mean “over there”), depending on the circumstances.

Until we receive specific guidance from North Carolina’s appellate courts, and in light of the fact that emojis are being used as a form of communication, the most logical approach is to treat them as “statements,” comparable to any other type of “written or oral assertion or nonverbal conduct intended by the declarant as an assertion.” G.S. 8C-1, Rule 801(a) (definition of hearsay); see also State v. Satterfield, 316 N.C. 55 (1986) (“An act, such as a gesture, can be a statement for purposes of applying rules concerning hearsay”). Treating emojis as nonverbal statements provides a ready-made body of law for tackling issues like relevance and admissibility, which is a great start, but it gets a little more complicated when we turn to the matter of interpretation.

What Do Emojis Mean?

Imagine a troubled young defendant who texts his girlfriend that he is willing to   her disapproving parents so that they can finally be together. She texts back with what the Unicode Consortium calls the “folded hands” emoji: . What does that reply mean? Is it hands clasped in prayer, begging him not to do it? Or praying that he will? Or perhaps she misunderstands the emoji and thinks it’s a “high five,” celebrating their murderous plan? Additionally, consider what happens if the sender and receiver are using different cell phones or operating systems. The same emoji, “pistol,” displays this way on a Microsoft device:  but it shows up like this on an LG smartphone:  . The potential for misunderstandings and conflicting interpretations is (literally) easy to see.

In many cases, the jurors will make the final determination about the true meaning or intent behind an ambiguous emoji, just as they would with any other potentially incriminating statement that the declarant contends was “only a joke” or “not how I meant it.” And to help the jury answer those questions, it appears that we have already entered the age of emoji interpretation expert witnesses. In a recent human trafficking case out of California, the state qualified a detective “as an expert in the areas of pimping, pandering and prostitution,” based on his training and experience, and the expert was permitted to testify about several emojis that the defendant texted (a crown, high heels, and bags of money) and the meaning of those images “specific to commercial … sexual exploitation.” See People v. Jamerson, 2019 WL 459012 (Cal. Ct. App., February 6, 2019) (unpublished).

But judges, magistrates, attorneys, and law enforcement officers also need to become at least conversationally fluent in emoji-speak, in order to address a number of other issues that could surface before trial. For example, is the “folded hands” emoji in the example above enough to charge the girlfriend with conspiracy? Is it admissible at trial as a statement of a co-conspirator? If the girlfriend testifies and insists that her reply meant “I’m praying you don’t do it,” can the state still argue the mistaken high five interpretation as a “reasonable inference” in closing? Opposing parties will inevitably disagree on what certain emojis mean, but it helps if both sides can at least agree on their names and recognize the differences between them.

How to Publish and Preserve

The growing use of emojis in texts, social media posts, and emails poses two additional problems for the court system. First, how should emojis be presented in court proceedings, such as when an officer is using them as part of a warrant application, or when an attorney wants to publish them to the jury? Second, how should they be documented and preserved in court records, such as transcripts or appellate opinions?

Whenever possible, the best option is to use the entire text, email, or post, showing all the words and emojis together. Officers can attach a printout or screenshot to their warrant applications, and attorneys can publish to the jury by handing out copies and letting the jurors see it for themselves. This approach helps to avoid disputes about misrepresentation or cross-platform display errors, and best ensures that the full and true intent of the communication will be conveyed (whatever the parties contend that intent is).

If including an image is not possible, it is imperative that the written description of the emojis be as complete and accurate as possible, preferably by using the standardized Unicode Consortium names. There are 148 different emojis listed in the “Smileys and Emotion” category alone, so a vague description like “smiley face emoji” could lead to confusion or error. In addition to its distinctive name, every emoji also has a unique code assigned to it. Including both the full name and the code in the description will ensure that “sleepy face” (, U+1 F62A) is not incorrectly characterized as “drooling face” (, U+1 F924).

The least desirable option is to leave the emojis out entirely, or replace them with a generic placeholder in brackets like [emojis omitted] or [various emojis]. For all the reasons explained above, this option doesn’t accurately convey the full meaning of the statement. See, e.g., United States v. Johnson, 280 F. Supp. 3d 772 (D. Md., Nov. 21, 2017) (referencing an Instagram post where defendant wrote “…they welcomed me home like it was 88 [emojis]. Real luv never fails…”). The post in Johnson would read quite differently if the defendant said he was being “welcomed home” with  instead of .

Emoji or Emojis?

Finally, what is the correct plural of emoji? If there are several of them in a row, is it still “emoji” like we would say “the seven samurai,” or should it be “emojis” like we would say “multiple tsunamis?” As you can tell from this post I’ve already made my choice, but for a contrary view check out this Atlantic article. Let the comment war begin.

The post Emojis in Court appeared first on North Carolina Criminal Law.

Emojis in Court published first on https://immigrationlawyerto.tumblr.com/