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• How to use a getter with a nullable?

  - by Desmond Lost

  I am reading a bunch of queries from a database. I had an issue with the queries not closing, so I added a CommandTimeout. Now, the individual queries read from the config file each time they are run. How would I make the code cache the int from the config file only once using a static nullable and getter. I was thinking of doing something along the lines of: static int? var; get{ var = null; if (var.HasValue) ...(i dont know how to complete the rest) My actual code: private object ExecuteQuery(string dbConnStr, bool fixIt) { object result = false; using (SqlConnection connection = new SqlConnection(dbConnStr)) { connection.Open(); using (SqlCommand sqlCmd = new SqlCommand()) { AddSQLParms(sqlCmd); sqlCmd.CommandTimeout = 30; sqlCmd.CommandText = _cmdText; sqlCmd.Connection = connection; sqlCmd.CommandType = System.Data.CommandType.Text; sqlCmd.ExecuteNonQuery(); } connection.Close(); } return result; }}

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• Simulate Facebook with Delphi

  - by Desmond

  Is there anybody out there that can give me some tips I need to create a program in delphi to simulate something like Facebook Where do I start

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• What are the Java equivalents to Linq and Entity Framework

  - by Colin Desmond

  Having played with Linq (to SQL and Objects) as well as the Entity Framework from Microsoft recently, I was wondering what the non-.Net (specifically Java) equivalents are?

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• Range validation not working properly in MVC3

  - by Colin Desmond

  I am generating data validation javascript in an Asp.Net MVC 3 application with the following code [DisplayName("Latitude Degrees")] [Range(0, 90, ErrorMessage = "Latitude degrees must be between {1} and {2}")] public Int32? LatitudeDegrees { get; set; } on a view model. When it was MVC2 this worked just fine, if I entered a value outside of 0-90 in the textbox I got the validation warnings. Since I moved the application to MVC 3, whenever I put any value into the texbox, legal or illegal I get the validation error appear next to it. I have EnableClientValidation set to true and UseUnobtrusiveJavascript is off (nothing in web.config or the views to turn it on).

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• Building VS2008 solution using MSBuild 2010?

  - by Colin Desmond

  Is it possible to build a VS2008 solution (C# and VC++ projects) using the automated MSBuild built into TFS2010? When I niavely just run it, the build fails because the 2008 Solution file needs to be upgraded (and presumably so would the project files). Can I tell MSBuild 2010 to just build the 2008 files?

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• problem with opening link through safari with webview

  - by Desmond

  hi i had encounter a problem opening a web link through safari. this is my code header #import <UIKit/UIKit.h> @interface qrcode_info : UIViewController <UIWebViewDelegate,UIAlertViewDelegate> { } @property (nonatomic, retain) IBOutlet UIWebView *Web; @end //main file #import "qrcode_info.h" @implementation qrcode_info @synthesize Web; -(BOOL)Web:(UIWebView *)Web shouldStartLoadWithRequest:(NSURLRequest *)request navigationType:(UIWebViewNavigationType)navigationType { if (navigationType == UIWebViewNavigationTypeLinkClicked) { [[UIApplication sharedApplication] openURL:[request URL]]; return NO; } return YES; } //[[UIApplication sharedApplication] openURL:[inRequest URL]]; //return NO; - (void)viewDidLoad { [super viewDidLoad]; [Web loadRequest:[NSURLRequest requestWithURL:[NSURL fileURLWithPath:[[NSBundle mainBundle] pathForResource:@"help" ofType:@"html"] isDirectory:NO]]]; //self.wvTutorial = [[WebViewController alloc] initWithNibName:@”WebView” bundle:[NSBundle mainBundle]]; }

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• Mallocing an unsigned char array to store ints

  - by Max Desmond

  I keep getting a segmentation fault when i test the following code. I am currently unable to find an answer after having searched the web. a = (byte *)malloc(sizeof(byte) * x ) ; for( i = 0 ; i < x-1 ; i++ ) { scanf("%d", &y ) ; a[i] = y ; } Both y and x are initialized. X is the size of the array determined by the user. The segmentation fault is on the second to last integer to be added, i found this by adding printf("roar") ; before setting a[i] to y and entering one number at a time. Byte is a typedef of an unsigned char. Note: I've also tried using a[i] = (byte)y ; A is ininitalized as follows byte *a ; If you need to view the entire code it is this: #include <stdio.h> #include <stdlib.h> #include "sort.h" int p_cmp_f () ; int main( int argc, char *argv[] ) { int x, y, i, choice ; byte *a ; while( choice !=2 ) { printf( "Would you like to sort integers?\n1. Yes\n2. No\n" ) ; scanf("%d", &choice ) ; switch(choice) { case 1: printf( "Enter the length of the array: " ) ; scanf( "%d", &x ) ; a = (byte *)malloc(sizeof( byte ) * x ) ; printf( "Enter %d integers to add to the array: ", x ) ; for( i = 0 ; i < x -1 ; i++ ) { scanf( "%d", &y ) ; a[i] = y ; } switch( choice ) { case 1: bubble_sort( a, x, sizeof(int), p_cmp_f ) ; for( i = 0 ; i < x ; i++ ) printf( "%d", a[i] ; break ; case 2: selection_sort( a, x, sizeof(int), p_cmp_f ) ; for( i = 0 ; i < x; i++ ) printf( "%d", a[i] ; break ; case 3: insertion_sort( a, x, sizeof(int), p_cmp_f ) ; for( i = 0 ; i < x ; i++ ) printf( "%d", a[i] ; break ; case 4: merge_sort( a, x, sizeof(int), p_cmp_f ) ; for( i = 0 ; i < x ; i++ ) printf( "%d", a[i] ; break ; case 5: quick_sort( a, x, sizeof(int), p_cmp_f ) ; for( i = 0 ; i < x ; i++ ) printf( "%d", a[i] ; break ; default: printf("Enter either 1,2,3,4, or 5" ) ; break ; } case 2: printf( "Thank you for using this program\n" ) ; return 0 ; break ; default: printf( "Enter either 1 or 2: " ) ; break ; } } free(a) ; return 0 ; } int p_cmp_f( byte *element1, byte *element2 ) { return *((int *)element1) - *((int *)element2) ; }

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• Deny access to a PHP file (Nginx)

  - by Desmond Hume

  I want Nginx to deny access to a specific PHP file, let's call it donotexposeme.php, but it doesn't seem to work, the PHP script is run as usual. Here is what I have in the config file: location / { root /var/www/public_html; index index.php; } location ~ \.php$ { fastcgi_pass 127.0.0.1:9000; fastcgi_index index.php; fastcgi_param SCRIPT_FILENAME /var/www/public_html$fastcgi_script_name; include fastcgi_params; } location /donotexposeme.php { deny all; } Of course, I do sudo service nginx reload (or restart) each time I edit the config.

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• ArchBeat Facebook Friday: Top 10 Shared Links - May 30- June 5, 2014

  - by OTN ArchBeat

  The list below is comprised of the Top 10 most popular articles, blog posts, videos, and other content shared over the last seven days with the more than 5,100 people fans of the OTN ArchBeat Facebook Page. What is REST? | Maarten Smeets "Most Middleware developers will encounter RESTful services," says Oracle SOA / BPM / Java integration specialist Maarten Smeets. "It is good to understand what they are, what they should be and how they work." His extensive post will help you achieve that understanding. Integrating with Fusion Applications using SOAP web services and REST APIs | Arvind Srinivasamoorth This article, part one of Arvind Srinivasamoorth's two-part series on Integrating with Fusion Applications using SOAP web services and REST APIs, shows you how to identify the Fusion Applications SOAP web service to be invoked. Oracle Technology Network | Architect Community Have you visited the OTN Solution Architect homepage lately? I've just updated it with information about the big OTN Virtual Tech Summit on July 9, plus the latest OTN tech articles, and a fresh list of community videos and podcasts. Check it out! Starting and Stopping a Java EE Environment when using Oracle WebLogic | Rene van Wijk Oracle ACE Director and Oracle Fusion Middleware specialist Rene van Wijk explores ways to simplify the life-cycle management of a Java EE environment through the use of scripts developed with WebLogic Scripting Tool and Linux Bash. Application Composer Series: Where and When to use Groovy | Richard Bingham Richard Bingham describes his post as "more of a reference than an article." The post is comprised of a table that highlights where you can add your own custom logic via Groovy code and when you might use the various features. Kscope 2014: HFM Metadata Diagnostics | Eric Erikson Oracle Certified Hyperion Financial Management Specialist Eric Erikson will present three sessions at ODTUG Kscope 2014, June 22-26 in Seattle. Why should you care? Watch the video. Tuning Asynchronous Web Services in Fusion Applications | Jian Liang This article, the fourth in solution architect Jian Liang's five-part series on Fusion Applications and asynchronous Web Services, shows you how to conduct performance tuning of the asynchronous web services in relation to Fusion Applications. IDM FA Integration Flows | Thiago Leoncio Fusion Applications uses the Oracle Identity Management for its identity store and policy store by default. This article by solution architect Thiago Leoncio explains how user and role flows work from different points of view, using key IDM products for each flow in detail. GoldenGate and Oracle Data Integrator - A Perfect Match in 12c... Part 1: Getting Started | Michael Rainey Michael Rainey has already written extensively about about integration between Oracle Data Integrator and GoldenGate -- but he's not done. "With the release of the 12c versions of ODI and GoldenGate last October, and a soon-to-be-updated reference architecture, it’s time to write a few posts on the subject again, " he says. Here's the first of those posts. Video: Kscope 2014 Preview: Tim Tow on Essbase Java API and ODTUG Community Oracle ACE Director and ODTUG board member Tim Tow talks about his Kscope 2014 sessions focused on the Essbase Java API in this short video interview.

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• Extend Your Applications Your Way: Oracle OpenWorld Live Poll Results

  - by Applications User Experience

  Lydia Naylor, Oracle Applications User Experience Manager At OpenWorld 2012, I attended one of our team’s very exciting sessions: “Extend Your Applications, Your Way”. It was clear that customers were engaged by the topics presented. Not only did we see many heads enthusiastically nodding in agreement during the presentation, and witness a large crowd surround our speakers Killian Evers, Kristin Desmond and Greg Nerpouni afterwards, but we can prove it…with data! Figure 1. Killian Evers, Kristin Desmond, and Greg Nerpouni of Oracle at the OOW 2012 session. At the beginning of our OOW 2012 journey, Greg Nerpouni, Fusion HCM Principal Product Manager, told me he really wanted to get feedback from the audience on our extensibility direction. Initially, we were thinking of doing a group activity at the OOW UX labs events that we hold every year, but Greg was adamant- he wanted “real-time” feedback. So, after a little tinkering, we came up with a way to use an online survey tool, a simple QR code (Quick Response code: a matrix barcode that can include information like URLs and can be read by mobile device cameras), and the audience’s mobile devices to do just that. Figure 2. Actual QR Code for survey Prior to the session, we developed a short survey in Vovici (an online survey tool), with questions to gather feedback on certain points in the presentation, as well as demographic data from our participants. We used Vovici’s feature to generate a mobile HTML version of the survey. At the session, attendees accessed the survey by simply scanning a QR code or typing in a TinyURL (a shorthand web address that is easily accessible through mobile devices). Killian, Kristin and Greg paused at certain points during the session and asked participants to answer a few survey questions about what they just presented. Figure 3. Session survey deployed on a mobile phone The nice thing about Vovici’s survey tool is that you can see the data real-time as participants are responding to questions - so we knew during the session that not only was our direction on track but we were hitting the mark and fulfilling Greg’s request. We planned on showing the live polling results to the audience at the end of the presentation but it ran just a little over time, and we were gently nudged out of the room by the session attendants. We’ve included a quick summary below and this link to the full results for your enjoyment. Figure 4. Most important extensions to Fusion Applications So what did participants think of our direction for extensibility? A total of 94% agreed that it was an improvement upon their current process. The vast majority, 80%, concurred that the extensibility model accounts for the major roles involved: end user, business systems analyst and programmer. Attendees suggested a few supporting roles such as systems administrator, data architect and integrator. Customers and partners in the audience verified that Oracle‘s Fusion Composers allow them to make changes in the most common areas they need to: user interface, business processes, reporting and analytics. Integrations were also suggested. All top 10 things customers can do on a page rated highly in importance, with all but two getting an average rating above 4.4 on a 5 point scale. The kinds of layout changes our composers allow customers to make align well with customers’ needs. The most common were adding columns to a table (94%) and resizing regions and drag and drop content (both selected by 88% of participants). We want to thank the attendees of the session for allowing us another great opportunity to gather valuable feedback from our customers! If you didn’t have a chance to attend the session, we will provide a link to the OOW presentation when it becomes available.

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• Office 2010 & SharePoint 2010: Platform for Innovation

  There's a great new article by Michael Desmond in Visual Studio Magazine called "Office Alignment: Why Office 2010 and SharePoint 2010 are poised to unleash a new wave of developer innovation". Read it and you'll get Michael's always engaging insight into the new products investments in this release, and you'll read about some key customers who have leveraged the platform to drive their business. I've been reading a lot about innovation, and it can be a topic that begins to elude us when we...Did you know that DotNetSlackers also publishes .net articles written by top known .net Authors? We already have over 80 articles in several categories including Silverlight. Take a look: here.

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• :contains for multiple words

  - by Emin

  I am using the following jQuery var etag='kate' if (etag.length > 0) { $('div').each(function () { $(this).find('ul:not(:contains(' + etag + '))').hide(); $(this).find('ul:contains(' + etag + ')').show(); }); }? towards the following HTML <div id="2"> <ul> <li>john</li> <li>jack</li> </ul> <ul> <li>kate</li> <li>clair</li> </ul> <ul> <li>hugo</li> <li>desmond</li> </ul> <ul> <li>said</li> <li>jacob</li> </ul> </div> <div id="3"> <ul> <li>jacob</li> <li>me</li> </ul> <ul> <li>desmond</li> <li>george</li> </ul> <ul> <li>allen</li> <li>kate</li> </ul> <ul> <li>salkldf</li> <li>3kl44</li> </ul> </div> basically, as long as etag has one word, the code works perfectly and hides those elements who do not contain etag. My problem is, when etag is multiple words (and I don't have control over it. Its coming from a database and could be combination of multiple words seperated with space char) then the code does not work.. is there any way to achieve this?

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• ArchBeat Link-o-Rama Top 20 for April 1-9, 2012

  - by Bob Rhubart

  The top 20 most popular items shared via my social networks for the week of April 1 - 8, 2012. Webcast: Oracle Maximum Availability Architecture Best Practices w/Tom Kyte - April 12 Oracle Cloud Conference: dates and locations worldwide Bad Practice Use Case for LOV Performance Implementation in ADF BC | Oracle ACE Director Andresjus Baranovskis How to create a Global Rule that stores a document’s folder path in a custom metadata field | Nicolas Montoya MySQL Cluster 7.2 GA Released How to deal with transport level security policy with OSB | Jian Liang Webcast Series: Data Warehousing Best Practices http://bit.ly/I0yUx1 Interactive Webcast and Live Chat: Oracle Enterprise Manager Ops Center 12c Launch - April 12 Is This How the Execs React to Your Recommendations? | Rick Ramsey Unsolicited login with OAM 11g | Chris Johnson Event: OTN Developer Day: MySQL - New York - May 2 OTN Member discounts for April: Save up to 40% on titles from Oracle Press, Pearson, O'Reilly, Apress, and more Get Proactive with Fusion Middleware | Daniel Mortimer How to use the Human WorkFlow Web Services | Oracle ACE Edwin Biemond Northeast Ohio Oracle Users Group 2 Day Seminar - May 14-15 - Cleveland, OH IOUG Real World Performance Tour, w/Tom Kyte, Andrew Holdsworth, Graham Wood WebLogic Server Performance and Tuning: Part I - Tuning JVM | Gokhan Gungor Crawling a Content Folio | Kyle Hatlestad The Java EE 6 Example - Galleria - Part 1 | Oracle ACE Director Markus Eisele Reminder: JavaOne Call For Papers Closing April 9th, 11:59pm | Arun Gupta Thought for the Day "A distributed system is one in which the failure of a computer you didn't even know existed can render your own computer unusable." — Leslie Lamport

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• MonoDroid Article in Visual Studio Magazine

  - by Wallym

  The February edition of Visual Studio magazine is now online.  In it, my article regarding MonoDroid, the implementation of C# and .NET for Android devices, is online.  I can't thank Michael Desmond enough for the opportunity.  Its fitting now that Android is the most popular smartphone platform.  This article is available online at: Intro to MonoDroid Part 1. Intro to MonoDroid Part 2. Along with the article, check out this short video that I did regarding MonoDroid on the Mac. The article(s) were written based on MonoDroid Preview 9.1, so there are a few updates necessary, but I think this gets the basics out.  I hope you enjoy the article(s). And yes, we're still working on our book on MonoDroid.  I've got a great author group and am excited about the book. If you get a chance, come to AnDevCon in San Francisco in March.  I'll be presenting on MonoDroid there.

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• SOA Community Newsletter September 2012

  - by JuergenKress

  Dear SOA partner community member Are you ready for Oracle Open World 2012? If you are planning to attend, make sure that you prepare your trip to San Francisco. If you could not make it, watch the keynotes live on-demand. You can also plan and decide to visit the SOA, Cloud and Service Technology Symposium 2012 and meet Tim Hall and Demed Lher from our product management team in London. As an Oracle partner you will get 50% discount on the conference pass, please use the code DJMXZ370 and avail your discount. The BPM Solution Catalogue is now live, make sure you use the process examples and contribute your processes. SOA Proactive support is the best resource to support your SOA implementations. To administrate your SOA systems Enterprise Manager Cloud Control 12c is the best tool, you can now attend thefree on-demand training. EM12c, Real User Experience Insight 12R1 gives you all the details, checkout our new demo. The BPM11g demo for Oracle E-Business Suite has become available. A wonderful SOA demo case is the Fusion Order Demo, Antony Reynolds posted an article how to update it on SOA Suite PS5. If you do use Coherence e.g. for SOA Suite, checkout the extension from our partner CloudTran. In this edition to this you will also find articles from: Automatically Disable Proxy Service to avoid overloading OSB By Jian Liang & Storing SCA Metadata in the Oracle Metadata Services Repository by Nicolás Fonnegra Martinez and Markus Lohn & Exploring MDS Explorer by Mark Nelson & Using Cloud OER to Find Fusion Applications On-Premise Service Concrete WSDL URL by Rajesh Raheja & Oracle Service Bus duplicate message check using Coherence by Jan van Zoggel & Installing Oracle SOA Suite10g on Oracle Enterprise Linux Lonneke Dikmans & Generating an EJB SDO Service Interface for Oracle SOA Suite by Edwin Biemond. Jürgen Kress Oracle SOA & BPM Partner Adoption EMEA To read the newsletter please visit http://tinyurl.com/soanewsSeptember2012 (OPN Account required) To become a member of the SOA Partner Community please register at http://www.oracle.com/goto/emea/soa (OPN account required) If you need support with your account please contact the Oracle Partner Business Center. Blog Twitter LinkedIn Mix Forum Technorati Tags: SOA Community newsletter,SOA Community,Oracle SOA,Oracle BPM,BPM Community,OPN,Jürgen Kress

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• Ul Li last element not aligning properly

  - by Chase

  I am having a problem where the last li element in a ul is pushing itself to the left further than the rest of all my pieces. Attached is a screen shot and my code. I have tried using the last-child element but it doesn't work in Safari or Chrome. #attending ul { display: inline; margin: 0 5px 0 0; padding-left: 0px; } #attending ul li { display: inline; list-style-image:none; padding: 5px; } #attending li:last-child { margin-right:-4px; } Suggestions? TIA, Chase http://desmond.yfrog.com/Himg338/scaled.php?tn=0&server=338&filename=screenshot20100526at808.jpg&xsize=640&ysize=640

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• MFMessageComposeViewControllerDelegate error - black screen

  - by user1053839

  I'm using the following code to show in-app sms. My app don't have a status bar. (I'm using 320x480 pixels screen in portrait view). the problem is that when I load the controller, the screen becomes black as you can see from the image... http://desmond.imageshack.us/Himg211/scaled.php?server=211&filename=schermata092456187alle1.png&res=landing this is the code: MFMessageComposeViewController *picker = [[MFMessageComposeViewController alloc] init]; picker.messageComposeDelegate = self; picker.recipients = [NSArray arrayWithObject:@"123456789"]; // your recipient number or self for testing picker.body = @"test"; [self presentModalViewController:picker animated:YES];

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• How to Create a Multiple Question ?

  - by user537422

  Hi Guys, I need to retrieve 6 questions from a plist and check the answer if is correct from the plist itself?? i will use a QR code scanner api to scan for answer, the api will covert to a string and read from the plist to check if the answer is correct... is there any tutorial or references for me to look @ ?? In my plist there is: question ~ Dictionary with the following strings: NumberOfOption ~ which define if the question is a multiple choice or a QR code question Question ~ question itself Answer ~ Answer itself Option 1 ~ 4 ~ if it is a multiple choice question Thanks in advance for answering my questions, i appreciated it cheers Desmond

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• Learn About Oracle’s Strategy for a Simple, Modern User Experience at OpenWorld 2012

  - by Applications User Experience

  By Kathy Miedema, Oracle Applications User Experience If you’re interested in what the best possible user experience looks like, you’ll want to hear what Oracle’s Applications User Experience team is planning for OpenWorld 2012, Sept. 30-Oct. 4 in San Francisco. This year, we will talk Fusion, Fusion, Fusion. We were among the first to show Oracle Fusion Applications in the last couple of years, and we’ll be showing it again this year so you can see what Oracle is planning for the next generation of enterprise applications. Attend our sessions to learn more about the user experience strategy in which Oracle is investing. Simplicity is the driving force behind the demos that we are unveiling now, which you can see at OpenWorld. We want to create opportunities for productivity and efficiency, and deliver enterprise data across devices to help you do your work in the way best suited to your job and needs, said Jeremy Ashley, Vice President, Oracle Applications User Experience. You can see the new look for Fusion Applications at a general session led by Ashley at 3:30 p.m. on Wednesday, Oct. 3. You’ll also have the chance to learn more about tailoring in Oracle Fusion Applications, and gain a new understanding of the investment in the user experience behind Fusion Applications at our sessions (see session information below). Inside the Oracle Applications User Experience team’s on-site lab at Oracle OpenWorld 2011. Head to the demogrounds to see new demos from the Applications User Experience team, including the new look for Fusion Applications and what we’re building for mobile platforms. Take a spin on our eye tracker, a very cool tool that we use to research the usability of a particular design. Visit the Usable Apps OpenWorld page to find out where our demopods will be located. We are also recruiting participants for our on-site lab, in which we gather feedback on new user experience designs, and taking reservations for a charter bus that will bring you to Oracle headquarters for a lab tour Thursday, Oct. 4, or Friday, Oct. 5. Tours leave at 10 a.m. and 1:45 p.m. from the Moscone Center in San Francisco. You’ll see more of our newest designs at the lab tour, and some of our research tools in action. Can’t participate in a customer feedback session or take a lab tour this time around? Visit Usable Apps to participate or book a tour another time. For more information on any OpenWorld sessions, check the content catalog – also available at www.oracle.com/openworld. For information on Applications User Experience (Apps UX) sessions and activities, go to the Usable Apps OpenWorld page. APPS UX OPENWORLD SESSIONS Oracle’s Roadmap to a Simple, Modern User Experience Presenter: Jeremy Ashley, Vice President Applications User Experience, Oracle; with Debra Lilley, Fujitsu Consulting; Basheer Khan, Innowave; and Edward Roske, InterRelSession ID: CON9467Date: Wednesday, Oct. 3 Time: 3:30 - 4:30 p.m.Location: Moscone West - 3002/3004 Jeremy Ashley Oracle Fusion Applications: Transforming Insight into Action Presenters: Killian Evers and Kristin Desmond, OracleSession ID: CON8718Date: Thursday, Oct. 4Time: 11:15 a.m. - 12:15 p.m.Location: Moscone West - 2008 “FRIENDS OF UX” OPENWORLD SESSIONS Sessions by the Oracle Usability Advisory Board (OUAB) members: Advances in Oracle Enterprise Governance, Risk, and Compliance Manager  Presenters: Koen Delaure, KPMG Advisory NV, and Oracle Usability Advisory Board member; Russell Stohr, Oracle Session ID: CON9389Date: Tuesday, Oct. 2Time: 1:15 - 2:15 p.m.Location: Palace Hotel - Concert Optimize Oracle E-Busines Suite Procure-to-Pay: Cut Inefficiences/Fraud with Oracle GRC Apps Presenters: Koen Delaure, KPMG Advisory NV, and Solveig Wagner, Seadrill Management AS, both Oracle Usability Advisory Board members; and Swarnali Bag, OracleSession ID: CON9401Date: Monday, Oct. 1Time: 12:15 - 1:15 p.m.Location: Intercontinental - Sutter Showcase of JD Edwards EnterpriseOne Mobility Presenters: Jon Wells, Westmoreland Coal Co., Oracle Usability Advisory Board member; Rob Mills and Liz Davson, Town of Oakville; Keith Sholes and Louise Farner, Oracle Session ID: CON9123Date: Tuesday, Oct. 2Time: 1:15 - 2:15 p.m.Location: InterContinental - Grand Ballroom B Sessions by the Fusion User Experience Adovcates (FXA) Usability and Features of Oracle Fusion Applications, Built upon Oracle Fusion Middleware Presenters: Debra Lilley, Fujitsu Consulting and Oracle Usability Advisory Board member; John King, King Training ResourcesSession ID: UGF10371Date: Sunday, Sept. 30Time: 11 a.m. - 11:45 a.m. Location: Moscone West – 2010 Ten Things to Love About Oracle Fusion Project Portfolio Management  Presenter: Floyd Teter, EiS TechnologiesSession ID: CON6021Date: Tuesday, Oct. 2Time: 10:15 - 11:15 a.m.Location: Moscone West – 2003

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• A Bite With No Teeth&ndash;Demystifying Non-Compete Clauses

  - by D'Arcy Lussier

  *DISCLAIMER: I am not a lawyer and this post in no way should be considered legal advice. I’m also in Canada, so references made are to Canadian court cases. I received a signed letter the other day, a reminder from my previous employer about some clauses associated with my employment and entry into an employee stock purchase program. So since this is in effect for the next 12 months, I guess I’m not starting that new job tomorrow. I’m kidding of course. How outrageous, how presumptuous, pompous, and arrogant that a company – any company – would actually place these conditions upon an employee. And yet, this is not uncommon. Especially in the IT industry, we see time and again similar wording in our employment agreements. But…are these legal? Is there any teeth behind the threat of the bite? Luckily, the answer seems to be ‘No’. I want to highlight two cases that support this. The first is Lyons v. Multari. In a nutshell, Dentist hires younger Dentist to be an associate. In their short, handwritten agreement, a non-compete clause was written stating “Protective Covenant. 3 yrs. – 5mi” (meaning you can’t set up shop within 5 miles for 3 years). Well, the young dentist left and did start an oral surgery office within 5 miles and within 3 years. Off to court they go! The initial judge sided with the older dentist, but on appeal it was overturned. Feel free to read the transcript of the decision here, but let me highlight one portion from section [19]: The general rule in most common law jurisdictions is that non-competition clauses in employment contracts are void. The sections following [19] explain further, and discuss Elsley v. J.G. Collins Insurance Agency Ltd. and its impact on Canadian law in this regard. The second case is Winnipeg Livestock Sales Ltd. v. Plewman. Desmond Plewman is an auctioneer, and worked at Winnipeg Livestock Sales. Part of his employment agreement was that he could not work for a competitor for 18 months if he left the company. Well, he left, and took up an important role in a competing company. The case went to court and as with Lyons v. Multari, the initial judge found in favour of the plaintiffs. Also as in the first case, that was overturned on appeal. Again, read through the transcript of the decision, but consider section [28]: In other words, even though Plewman has a great deal of skill as an auctioneer, Winnipeg Livestock has no proprietary interest in his professional skill and experience, even if they were acquired during his time working for Winnipeg Livestock.  Thus, Winnipeg Livestock has the burden of establishing that it has a legitimate proprietary interest requiring protection.  On this key question there is little evidence before the Court.  The record discloses that part of Plewman’s job was to “mingle with the … crowd” and to telephone customers and prospective customers about future prospects for the sale of livestock.  It may seem reasonable to assume that Winnipeg Livestock has a legitimate proprietary interest in its customer connections; but there is no evidence to indicate that there is any significant degree of “customer loyalty” in the business, as opposed to customers making choices based on other considerations such as cost, availability and the like. So are there any incidents where a non-compete can actually be valid? Yes, and these are considered “exceptional” cases, meaning that the situation meets certain circumstances. Michael Carabash has a great blog series discussing the above mentioned cases as well as the difference between a non-compete and non-solicit agreement. He talks about the exceptional criteria: In summary, the authorities reveal that the following circumstances will generally be relevant in determining whether a case is an “exceptional” one so that a general non-competition clause will be found to be reasonable: - The length of service with the employer. - The amount of personal service to clients. - Whether the employee dealt with clients exclusively, or on a sustained or     recurring basis. - Whether the knowledge about the client which the employee gained was of a   confidential nature, or involved an intimate knowledge of the client’s   particular needs, preferences or idiosyncrasies. - Whether the nature of the employee’s work meant that the employee had   influence over clients in the sense that the clients relied upon the employee’s   advice, or trusted the employee. - If competition by the employee has already occurred, whether there is   evidence that clients have switched their custom to him, especially without   direct solicitation. - The nature of the business with respect to whether personal knowledge of   the clients’ confidential matters is required. - The nature of the business with respect to the strength of customer loyalty,   how clients are “won” and kept, and whether the clientele is a recurring one. - The community involved and whether there were clientele yet to be exploited   by anyone. I close this blog post with a final quote, one from Zvulony & Co’s blog post on this subject. Again, all of this is not official legal advice, but I think we can see what all these sources are pointing towards. To answer my earlier question, there’s no teeth behind the threat of the bite. In light of this list, and the decisions in Lyons and Orlan, it is reasonably certain that in most employment situations a non-competition clause will be ineffective in protecting an employer from a departing employee who wishes to compete in the same business. The Courts have been relatively consistent in their position that if a non-solicitation clause can protect an employer’s interests, then a non-competition clause is probably unreasonable. Employers (or their solicitors) should avoid the inclination to draft restrictive covenants in broad, catch-all language. Or in other words, when drafting a restrictive covenant – take only what you need! D

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