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In deciding ZF Automotive US, Inc., et al. v. Luxshare, Ltd. ("ZF Automotive") (June 13, 2022), the United States Supreme Court sought to determine whether either a private international arbitration or a semi-private investor-state arbitration was a "tribunal" for the purposes of 28 U.S.C. § 1782 ("§ 1782"), in particular section (a)--a provision which authorizes a district court to order the production of evidence "for use in a proceeding in a foreign or international tribunal." This Note will comprehensively review the statutory history of § 1782, canvas the circuit split on defining a "proceeding in a foreign or international tribunal," and cover the Supreme Court's most recent ruling on § 1782 in ZF Automotive. This Note will further analyze the effects of the decision, identify this author's understanding of both of the new and revised applicable tests for determining a body's qualification as a "foreign or international tribunal" that is "imbued with governmental authority," and survey the few cases addressing this question in the post-ZF Automotive landscape. The statute has a long history dating back to 1855 and underwent significant changes in 1964. Following amendments made in 1964, there has been a question as to what constitutes a "foreign or international tribunal" under the statute. Before deciding this case, five federal circuit courts were split on the issue, with the Fourth and Sixth arguing that a private arbitration tribunal was a "tribunal" for the purposes of the statute, and the Second, Fifth, and Seventh arguing that it was not. To resolve this split, the U.S. Supreme Court consolidated and granted certiorari to ZF Automotive from the Sixth Circuit, and AlixPartners, LLP, et al. v. The Fund for Protection of Investor Rights in Foreign States ("AlixPartners") from the Second Circuit. In ZF Automotive, the tribunal at issue was a private dispute-resolution organization resolving a dispute between two corporations. In AlixPartners, the tribunal was an ad hoc arbitration panel resolving a dispute between a sovereign state and a private party as outlined in an international treaty. The Court held in a 9--0 ruling that only a governmental or intergovernmental adjudicative body constitutes a "foreign or international tribunal" under 28 U. S. C. § 1782, and that both bodies at issue in these cases did not qualify. According to the Court, for the purposes of § 1782, the inquiry is whether the features of the adjudicatory body and other evidence establish the intent of the relevant nations to imbue the body in question with governmental authority. The U.S. Supreme Court's decision in ZF Automotive did much to clarify not only the meaning of the statutory term "foreign or international tribunal" but also subtly clarify the entire statutory analysis of § 1782 applications. First, the Court analyzes the statutory factors. The "For Use" factor now has two clearly defined tests available to discern whether a body is both a tribunal to begin with (the Intel Functional test) and whether it is a "foreign or international tribunal" intended to be imbued with governmental authority (the "Governmental Intended Authority Test" with the Guo Tribunal Character Factors). Then, only if the statutory requirements of § 1782 are met should the court apply Intel's Discretionary test when exercising its discretion in granting or denying the § 1782 application for discovery. While the door is now closed to private arbitrations, there is sure to be continued debate on § 1782's application to investor-state and other "public" arbitrations, but these clarified and categorized tests should help to properly focus the debate until the U.S. Supreme Court offers more guidance, hopefully in less time than transpired between their decisions in Intel and ZF Automotive. [ABSTRACT FROM AUTHOR]

Background: Artificial intelligence (AI) has the potential to revolutionize nursing education. This study compared NCLEX-RN questions generated by AI and those created by nurse educators. Method: Faculty of accredited baccalaureate programs were invited to participate. Likert-scale items for grammar and clarity of the item stem and distractors were compared using Mann-Whitney U, and yes/no questions about clinical relevance and complex terminology were analyzed using chi-square. A one-sample binomial test with confidence intervals evaluated participants' question preference (AI-generated or educator-written). Qualitative responses identified themes across faculty. Results: Item clarity, grammar, and difficulty were similar for AI and educator-created questions. Clinical relevance and use of complex terminology was similar for all question pairs. Of the four sets with preference for one item, three were generated by AI. Conclusion: AI can assist faculty with item generation to prepare nursing students for the NCLEX-RN examination. Faculty expertise is necessary to refine questions written using both methods. [J Nurs Educ. 2023;62(12):679–687.] [ABSTRACT FROM AUTHOR]

Individuals with South Asian ancestry have a higher risk of heart disease than other groups but have been largely excluded from genetic research. Using data from 22,000 British Pakistani and Bangladeshi individuals with linked electronic health records from the Genes & Health cohort, we conducted genome-wide association studies of coronary artery disease and its key risk factors. Using power-adjusted transferability ratios, we found evidence for transferability for the majority of cardiometabolic loci powered to replicate. The performance of polygenic scores was high for lipids and blood pressure, but lower for BMI and coronary artery disease. Adding a polygenic score for coronary artery disease to clinical risk factors showed significant improvement in reclassification. In Mendelian randomisation using transferable loci as instruments, our findings were consistent with results in European-ancestry individuals. Taken together, trait-specific transferability of trait loci between populations is an important consideration with implications for risk prediction and causal inference. Most genetic studies of disease have been done in European ancestry cohorts, and the relevance to other populations is not guaranteed. Here, the authors use data from 22,000 British South Asian individuals and find that the transferability of polygenic scores was high for lipids and blood pressure, and lower for BMI and coronary artery disease. [ABSTRACT FROM AUTHOR]

Background: Systemic racism and inequity are embedded in higher education, especially in nursing. By disregarding health disparities and inequities, a hidden curriculum is endorsed, implicitly letting both instructors and students know that not addressing these subjects is acceptable. Method: Needs assessments were performed to assess faculty and student attitudes about the needs for justice, equity, diversity, and inclusion (JEDI) concepts. Using the Plan-Do-Study-Act model, the School of Nursing leadership, faculty, and students created taskforces to implement anti-oppression curricula throughout prelicensure courses. Results: Anti-oppression curricula and workshops were piloted successfully in the first semester of prelicensure nursing. Student feedback was positive with constructive suggestions. JEDI curriculum mapping was completed across the prelicensure nursing curriculum. Conclusion: JEDI concepts must be integrated across nursing curricula to identify gaps. Forming a collaboration between leadership, faculty, and students is an optimal way to proceed as they all are invested and accountable for change. [J Nurs Educ. 2022;61(8):447–454.] [ABSTRACT FROM AUTHOR]

Previous genetic and public health research in the Pakistani population has focused on the role of consanguinity in increasing recessive disease risk, but little is known about its recent population history or the effects of endogamy. Here, we investigate fine-scale population structure, history and consanguinity patterns using genotype chip data from 2,200 British Pakistanis. We reveal strong recent population structure driven by the biraderi social stratification system. We find that all subgroups have had low recent effective population sizes (Ne), with some showing a decrease 15‒20 generations ago that has resulted in extensive identity-by-descent sharing and homozygosity, increasing the risk of recessive disorders. Our results from two orthogonal methods (one using machine learning and the other coalescent-based) suggest that the detailed reporting of parental relatedness for mothers in the cohort under-represents the true levels of consanguinity. These results demonstrate the impact of cultural practices on population structure and genomic diversity in Pakistanis, and have important implications for medical genetic studies. Little is known about the recent population history or the effects of endogamy on the Pakistani population. Here the authors examine the impact of the biraderi social stratification system on the population structure of individuals of British Pakistani ancestry in the Born in Bradford cohort. [ABSTRACT FROM AUTHOR]

Despite the high prevalence and negative outcomes associated with poorly managed dementia-related behavioral expressions (BE) during hospitalization, evidence-based interventions for BE management in acute care environments are lacking. To address this gap, we designed, implemented, and evaluated feasibility, utility, and exploratory nurse and patient outcomes associated with a low-cost, nurse-led multicomponent decision support intervention—the Personalized Approach and Targeted Interventions (PROACTIVE) Treatment Approach—which was implemented as a quality improvement program and evaluated with a historical matched comparison group. The intervention was feasibly implemented and improved nurse-sensitive outcomes (stress, confidence), practices (use of nonpharmacological approaches) for BE management, and perceived utility of intervention resources. Patients receiving the PROACTIVE Treatment Approach (N = 40) had higher rates of acetaminophen use, and shorter lengths of stay (N = 40). More rigorous evaluation is needed to better determine optimal implementation strategies and intervention impact. [Journal of Gerontological Nursing, 47(9), 21–30.] [ABSTRACT FROM AUTHOR]

Background: The emergence of the COVID‐19 pandemic resulted in a sudden transition to remote learning. These circumstances presented many challenges for higher education faculty and students around the world but especially for nursing education programs which are traditionally conducted in a face‐to‐face learning environment that includes hands‐on experiential learning. Methods: Guided by Meleis' Transition Theory, a qualitative descriptive design was utilized to explore prelicensure nursing students' experiences of the transition to remote learning during the Spring 2020 semester. Participants were recruited from one baccalaureate program in the Pacific Northwestern United States. Interviews were conducted and transcribed using a web conferencing platform. Data were analyzed using Colaizzi's phenomenological reduction. Results: Eleven students participated. Interviews revealed four overarching themes: technological challenges, academic relationship changes, role stress and strain, and resilience. Conclusion: The sudden transition to remote learning resulted in a number of challenges for nursing students. Despite these challenges, students demonstrated a remarkable sense of resilience and perseverance. Faculty have an opportunity to address student stressors and design remote courses in such a way to facilitate student engagement and community building. [ABSTRACT FROM AUTHOR]

Staphylococcal enterotoxin type C (SEC) is one of the classical enterotoxins implicated in staphylococcal food poisoning. Staphylococcus aureus strains isolated from bovine unpasteurised milk and associated cheese samples produced the SEC sub-type. The objectives of this study were to determine the cell numbers required for SEC production in milk and to determine if SEC was produced by S. aureus during cheesemaking. To predict the point at which toxin production begins, SEC production was modelled against cell numbers of S. aureus (at different controlled pH/temperature combinations) in sterile reconstituted milk using a biphasic model fitted using the Solver routine in Excel. Under the conditions tested, the average cell number required for SEC production was log 8.43 ± 0.39 in sterile reconstituted milk. A semi-soft cheese was manufactured using milk inoculated with either washed (to remove any pre-formed toxin) or unwashed (containing toxin) S. aureus at 10 and 10 cfu.mL. An enzyme-linked immunosorbent assay was used to quantify toxin production and Baird-Parker agar to quantify S. aureus. Cheese made with washed and unwashed cells showed a one log increase in S. aureus cell numbers during cheesemaking. In cheese made with washed cells, no SEC was detected. With unwashed cells, the SEC concentration remained constant throughout cheesemaking. The results show that SEC is not formed in milk or cheese at <10 cfu.mL, and therefore, the risk-associated with SEC in cheese is low. [ABSTRACT FROM AUTHOR]

As cheese is often frozen prior to microbiological analysis, the aim of this study was to determine the survival of foodborne pathogens to freezing in cheese. A semi-soft cheese was produced, in independent triplicate for each pathogen mix, using milk inoculated with two pathogen mixes: Listeria monocytogenes + Staphylococcus aureus and Escherichia coli O157:H7 + Salmonella typhimurium. Three different strains were used for each pathogen, except for E. coli O157:H7 for which two strains were used. Cheeses were manufactured, wrapped in plastic bags and frozen at −20 °C. For the E. coli O157:H7 + S. typhimurium pathogen mix, the effect of different freezing conditions on survival was studied. In all cases, the numbers of starter bacteria and pathogens were monitored in fresh cheese and after 2, 7, 30 and 90 days of storage. Two methods of thawing were compared after 30 days (14 h at 4 °C and 4 h at 20 °C). The numbers of L. monocytogenes, S. aureus and starter bacteria did not change significantly during frozen storage at −20 °C, but E. coli and S. typhimurium decreased significantly after 2 days. There was no significant ( p > 0.05) influence of the thawing method. Freezing of cheese at −80 °C or flash freezing in liquid nitrogen only facilitated survival of E. coli O157:H7 and S. typhimurium for 1 day. The study shows that cheese samples should not be frozen prior to analysis for detection or enumeration of E. coli or S. typhimurium. [ABSTRACT FROM AUTHOR]

Coeliac disease (CeD) is a highly heritable common autoimmune disease involving chronic small intestinal inflammation in response to dietary wheat. The human leukocyte antigen (HLA) region, and 40 newer regions identified by genome wide association studies (GWAS) and dense fine mapping, account for ∼40% of the disease heritability. We hypothesized that in pedigrees with multiple individuals with CeD rare [minor allele frequency (MAF) <0.5%] mutations of larger effect size (odds ratios of ∼ 2–5) might exist. We sequenced the exomes of 75 coeliac individuals of European ancestry from 55 multiply affected families. We selected interesting variants and genes for further follow up using a combination of: an assessment of shared variants between related subjects, a model-free linkage test, and gene burden tests for multiple, potentially causal, variants. We next performed highly multiplexed amplicon resequencing of all RefSeq exons from 24 candidate genes selected on the basis of the exome sequencing data in 2,248 unrelated coeliac cases and 2,230 controls. 1,335 variants with a 99.9% genotyping call rate were observed in 4,478 samples, of which 939 were present in coding regions of 24 genes (Ti/Tv 2.99). 91.7% of coding variants were rare (MAF <0.5%) and 60% were novel. Gene burden tests performed on rare functional variants identified no significant associations (p<1×10−3) in the resequenced candidate genes. Our strategy of sequencing multiply affected families with deep follow up of candidate genes has not identified any new CeD risk mutations. [ABSTRACT FROM AUTHOR]

During routine sampling of bulk raw milk on a dairy farm, the pathogenic bacteria Listeria monocytogenes was found to be a contaminant, at numbers<100 cfu/ml. A strain with an indistinguishable pulsed-field gel electrophoresis pattern was isolated from the bulk milk two months later. Environmental swabs taken at the dairy environment were negative for the presence of L. monocytogenes, indicating a possible case of excretion of the L. monocytogenes directly into the milk. Milk samples were collected from the individual cows and analysed, resulting in the identification of L. monocytogenes excretion (at 280 cfu/ml) from one of the 4 mammary quarters of one dairy cow out of 180. When the infected cow was isolated from the herd, no L. monocytogenes was detected from the remaining herd. The pulsed-field gel electrophoresis pattern of the strain from the individual cow was indistinguishable from that originally isolated from the bulk milk. The infected cow did not show any clinical signs of disease, nor did the appearance of the milk have any physical abnormalities. Antibiotic treatment of the infected mammary quarter was found to be ineffective. This study shows that there can be risks associated with direct contamination of raw milk with L. monocytogenes. [ABSTRACT FROM AUTHOR]

Genome-wide association studies (GWAS) have identified common variants of modest-effect size at hundreds of loci for common autoimmune diseases; however, a substantial fraction of heritability remains unexplained, to which rare variants may contribute. To discover rare variants and test them for association with a phenotype, most studies re-sequence a small initial sample size and then genotype the discovered variants in a larger sample set. This approach fails to analyse a large fraction of the rare variants present in the entire sample set. Here we perform simultaneous amplicon-sequencing-based variant discovery and genotyping for coding exons of 25 GWAS risk genes in 41,911 UK residents of white European origin, comprising 24,892 subjects with six autoimmune disease phenotypes and 17,019 controls, and show that rare coding-region variants at known loci have a negligible role in common autoimmune disease susceptibility. These results do not support the rare-variant synthetic genome-wide-association hypothesis (in which unobserved rare causal variants lead to association detected at common tag variants). Many known autoimmune disease risk loci contain multiple, independently associated, common and low-frequency variants, and so genes at these loci are a priori stronger candidates for harbouring rare coding-region variants than other genes. Our data indicate that the missing heritability for common autoimmune diseases may not be attributable to the rare coding-region variant portion of the allelic spectrum, but perhaps, as others have proposed, may be a result of many common-variant loci of weak effect. [ABSTRACT FROM AUTHOR]

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Using variants from the 1000 Genomes Project pilot European CEU dataset and data from additional resequencing studies, we densely genotyped 183 non-HLA risk loci previously associated with immune-mediated diseases in 12,041 individuals with celiac disease (cases) and 12,228 controls. We identified 13 new celiac disease risk loci reaching genome-wide significance, bringing the number of known loci (including the HLA locus) to 40. We found multiple independent association signals at over one-third of these loci, a finding that is attributable to a combination of common, low-frequency and rare genetic variants. Compared to previously available data such as those from HapMap3, our dense genotyping in a large sample collection provided a higher resolution of the pattern of linkage disequilibrium and suggested localization of many signals to finer scale regions. In particular, 29 of the 54 fine-mapped signals seemed to be localized to single genes and, in some instances, to gene regulatory elements. Altogether, we define the complex genetic architecture of the risk regions of and refine the risk signals for celiac disease, providing the next step toward uncovering the causal mechanisms of the disease. [ABSTRACT FROM AUTHOR]

This article looks at three case reports which show the clinical effects of the inelastic, adjustable device, Juxta-Fit™(medi UK). This device allows patients to be self-caring and independent. It is also effective in reducing the volume of the lymphoedematous limb and as maintenance therapy following decongestive lymphatic therapy (DLT). Juxta-Fit can be used as a stand-alone treatment, or in conjunction with compression garments if oedema formation is unable to be controlled with compression garments alone. Juxta-Fit offers a comfortable inelastic high working pressure and low resting pressure similar to short-stretch bandaging. [ABSTRACT FROM AUTHOR]

The essay examines how traveling influenced the political activity of English suffragist and communist Dore Montefiore, with emphasis given to her political tourism, networking abilities, and propaganda efforts. The author explores the ways in which increased police surveillance of political activists affected their travel as well.

We performed a second-generation genome-wide association study of 4,533 individuals with celiac disease (cases) and 10,750 control subjects. We genotyped 113 selected SNPs with PGWAS < 10−4 and 18 SNPs from 14 known loci in a further 4,918 cases and 5,684 controls. Variants from 13 new regions reached genome-wide significance (Pcombined < 5 × 10−8); most contain genes with immune functions (BACH2, CCR4, CD80, CIITA-SOCS1-CLEC16A, ICOSLG and ZMIZ1), with ETS1, RUNX3, THEMIS and TNFRSF14 having key roles in thymic T-cell selection. There was evidence to suggest associations for a further 13 regions. In an expression quantitative trait meta-analysis of 1,469 whole blood samples, 20 of 38 (52.6%) tested loci had celiac risk variants correlated (P < 0.0028, FDR 5%) with cis gene expression. [ABSTRACT FROM AUTHOR]

In 1917 and 1918 violent cost-of-living protests, largely peopled by poor urban housewives, erupted across the world. Although Britain did not experience such dramatic events, a women's politics of food can be found in local neighborhoods that touched the lives of unorganized housewives on the wartime home front. The new local committees created to defend consumer interests in the face of food shortages proved to be permeable to some women, particularly those who already had some experience with women's politics. However, limits were placed on this participation and on the self-organization of housewives by the ambiguous understanding of who constituted a consumer and thus who could speak for the ordinary housewife as she battled the food queues. By exploring the women's politics of food at a local level, it is argued that working-class women's participation in Food Vigilance Committees or in local boycotts may have had longer lasting effects in Britain than the more dramatic cost-of-living actions elsewhere. [ABSTRACT FROM AUTHOR]

In 1917 and 1918 violent cost-of-living protests, largely peopled by poor urban housewives, erupted across the world. Although Britain did not experience such dramatic events, a women's politics of food can be found in local neighborhoods that touched the lives of unorganized housewives on the wartime home front. The new local committees created to defend consumer interests in the face of food shortages proved to be permeable to some women, particularly those who already had some experience with women's politics. However, limits were placed on this participation and on the self-organization of housewives by the ambiguous understanding of who constituted a consumer and thus who could speak for the ordinary housewife as she battled the food queues. By exploring the women's politics of food at a local level, it is argued that working-class women's participation in Food Vigilance Committees or in local boycotts may have had longer lasting effects in Britain than the more dramatic cost-of-living actions elsewhere. [ABSTRACT FROM AUTHOR]

The article offers information on coeliac disease, which affects around one in 100 individuals in Europe. The disease generates an immune response in the small intestine to fragments of gluten leading to architectural changes in the small intestine which include villous atrophy and an increase in the number of intra-epithelial cells. It mentions the inherited genetic factors affecting the disease aside from the well known environmental factor, the gluten.

The study of women's politics in the past raises important questions for research on party activism of whatever sort, whether undertaken by historians or political scientists. The evidence discussed here is drawn from research on British women's politics from the 1880s to the 1920s, particularly, but not exclusively, from the experience of socialist, Labour and Communist women. However, it is argued that the issues raised have a much broader resonance. By reflecting on continuities and changes in the practice of women's politics, the case is made for the transformative effect of the adoption of a comparative and contextual approach to the study of activism. [ABSTRACT FROM AUTHOR]

Our genome-wide association study of celiac disease previously identified risk variants in the IL2–IL21 region. To identify additional risk variants, we genotyped 1,020 of the most strongly associated non-HLA markers in an additional 1,643 cases and 3,406 controls. Through joint analysis including the genome-wide association study data (767 cases, 1,422 controls), we identified seven previously unknown risk regions (P < 5 × 10−7). Six regions harbor genes controlling immune responses, including CCR3, IL12A, IL18RAP, RGS1, SH2B3 (nsSNP rs3184504) and TAGAP. Whole-blood IL18RAP mRNA expression correlated with IL18RAP genotype. Type 1 diabetes and celiac disease share HLA-DQ, IL2–IL21, CCR3 and SH2B3 risk regions. Thus, this extensive genome-wide association follow-up study has identified additional celiac disease risk variants in relevant biological pathways. [ABSTRACT FROM AUTHOR]

The article attempts to examine how transnational practice might be developed from transnational experience based on the life and politics of Dora Montefiore, a British socialist, suffragist and later communist who spent key periods of her life traveling, networking and making her politics outside Great Britain. It highlights how Montefiore's encounter with South Africa had enriched her politics and confirmed for her that travel provided stimulation to her as a political woman. In conclusion, the author asserts that at the heart of Montefiore's brand of transnationalist practice sat a desire to make connections and to try to work towards a gendered and raced socialist internationalism.

Coeliac disease is a common enteropathy with a strong inherited risk characterised by dietary wheat, rye and barley induced T-cell activation. Although there is replicated linkage to 2q33, results are inconsistent from association studies of the most promising candidate genes: the CD28/CTLA4/ICOS cluster. CTLA4 plays a key role in regulating T lymphocyte mediated inflammatory responses, and variants in the 3'region influence development of diabetes and thyroid disease. We genotyped CTLA4 variants (-1722 C/T,-658 T/C,-318 C/T,+49 A/G,+1822 C/T, CT60 A/G) to tag all common haplotypes (>5%frequency) and an ICOS variant (IVS+173 C/T) in 340 white UK Caucasian coeliac disease cases. Strict ascertainment criteria for coeliac cases required both villous atrophy at diagnosis and positive serology. In total, 973 healthy controls were available for SNP, and 705 for CTLA4 haplotype, based association analyses. Coeliac disease showed weak association with the CTLA4+1822T (P=0.019) and CT60 G (P=0.047) alleles. Strong association was seen with a common CTLA4 haplotype (P=0.00067, odds ratio 1.41) of frequency 32.7%in coeliac disease and 25.5%in healthy controls. A common CTLA4 haplotype shows strong association with coeliac disease, and contains multiple alleles reported to affect immunological function. Loss of tolerance to dietary antigens in coeliac disease may be mediated in part by heritable variants in co-signalling genes regulating T-cell responses.European Journal of Human Genetics (2005) 13, 440-444. doi:10.1038/sj.ejhg.5201357 Published online 12 January 2005 [ABSTRACT FROM AUTHOR]