Tips For Using Toefl Essay Samples

Tips For Using Toefl Essay SamplesToefl essay samples are excellent ways to practice writing your essay and get familiar with the software. Each has a different writing style and while some focus on one subject at a time, others have many to choose from.Toefl essay samples that focus on topics such as the animals, the earth, physics, biology, culture, and history are going to be more interesting than those that focus on various subjects with varying interest. For instance, the topic of culture is going to be much more interesting than a topic like science.Some types of essay samples may seem really easy, while other essays are more challenging and others are less. These are all great tools to learn about how to write a better essay. If you are not sure how to find one that suits your style, make sure to do a little research and find out which tools are right for you.As you read through some of the Toefl essay samples and see what they have to offer, you will soon discover how useful the software can be. This way you can be sure to do your best and use the best methods to achieve the kind of essay you want. The essays will have to flow well and you want to be sure to follow the steps that are included in the tool.After you are ready to begin writing the paper, you can go over the tips for using the software. Most students find that these tips will be very helpful to ensure that the paper flows as well as possible. If you take some time to think about the style and structure of your essay before you begin writing, this will allow you to have a better understanding of how the essay should be written.Finally, you should note that all of the essay samples come with tips for improving the essay itself. Make sure that you keep these in mind as you move forward with the essay and they will help you gain more insight into how to better write the essay.Make sure that you know and follow the specific rules for each type of essay sample so that you will be able to start wr iting on the proper topics. They are all different and they have different styles. With so many to choose from, it can sometimes be hard to know what to choose.If you do not know what to do, it may be a good idea to see the tutorial for the different types of essay samples that you can choose from. This way you will be able to find out what other people are saying and how they came up with the choices they did.

Sample EOC Ohio Essay Topics

<h1>Sample EOC Ohio Essay Topics</h1><p>When you are pondering composing an example of Ohio exposition, there are a couple of things you should consider. This article subject will be utilized to exhibit your abilities and experience to potential managers. This will assist with deciding whether you will be hired.</p><p></p><p>The first thing you have to consider is the setting for your eoc. Is it to get acknowledged or to make yourself stick out? Is it your senior year of secondary school? A later time period would be school and the way toward applying for a job.</p><p></p><p>Each singular school will have distinctive application positions. Understudies frequently change their application to locate the best fit. Before you present your application, ensure it's as of now finished and as of now submitted. On the off chance that you have something to add or need to peruse increasingly material on a particular point, right now is an ideal opportunity to do so.</p><p></p><p>In option to getting acknowledged or making yourself stick out, it's essential to keep your evaluation level up with the changing educational plan necessities. A regular eoc educational program will incorporate an AP course in school, a GED, and conceivably a college course. These will all effect your qualification and ought to be taken into consideration.</p><p></p><p>Being arranged for an eoc is significant. After the last cutoff time, remember these issues. In case you're uncertain of what to expound on, start off with the educational plan prerequisites, go from there.</p><p></p><p>When you choose to go after an eoc, the rundown of test eoc Ohio paper themes is very huge. These are given by the college itself and can be discovered on the web. A smart thought is discover a site with these and take a gander at every one. Discover the subjects that are critical to you, which are free, and begin on them today.</p><p></p><p>There are such a large number of interesting points when composing an eoc. Realizing what is generally essential to you will assist you with having an incredible final product. Remember these couple of things and your eoc Ohio article will say a lot about you.</p>

The Do This, Get That Guide On G.e.d Essay Topics

<h1>The Do This, Get That Guide On G.e.d Essay Topics </h1> <p>Begin each section by expressing the significant point that you might want to talk about. Set forth plainly, you can choose to begin in the inside or anyplace you wish to start. The sentence is linguistically right as it's composed. These sentences could be utilized with a comma between. </p> <h2>The New Angle On G.e.d Essay Topics Just Released </h2> <p>These themes are for the most part about general points which don't expect you to be a pro on any zone. On the other hand, you can look for paper points on the web. Second, you can without much of a stretch pick the subjects you should study and you may consider them in any request that you might want. Try not to show up through the points before you select. </p> <h2> G.e.d Essay Topics - Overview </h2> <p>When viewing our video exercises, it will be less complex for you to take notes. Remember, you're need to help your essential thought with models from the perusing. The shorter the exercise, the less difficult it is to recall what you've realized. You probably won't have the option to stick point the exact theme that you will talk about, yet visit composing can upgrade your capacities. </p> <p>Writing an exposition for the abstract piece of the GED (General Education Development) test should be simple, as it's much similar to composing some other sort of article for your group. Utilize real practice inquiries to obtain a sense for those sorts of inquiries posed. A Psychology Today article states utilizing visuals in learning diminishes the time you should consider, improves your understanding of the issue, and can assist you with holding data with less Mental Health Challenges. This substance isn't supported or acknowledged by ACE or GED Testing Service.</p> <p>You never get another opportunity to make an early introduction will give your perusers with their early introductions of your contention, your composing style your entire paper will be a response to this inquiry, and your presentation is the underlying advance. You don't should be great, yet you need so as to respond to the inquiry in paper structure. You're not given a decision with respect to what kind of paper you will compose. There's quite often a legitimate answer, however it may be trying to find. </p> <p>They spread a wide assortment of themes, so we might want to assist you with focusing on the ones which are really remembered for the test. At long last, utilize your pencil on numerous decision and simplified things to dispose of answer decisions which are plainly wrong. At that point you may contrast the remainder of the appropriate responses with get the right one. With the measure of the recordings going from 2 minutes to 16 minutes every, it will be less complex to contemplate and hold what you have realized. </p> <p>We give a lot of awesome GED exposition recommendations for guests and clients. As you could skip up ahead and bounce directly into your underlying free attempt at the GED Practice Test, we prescribe delaying a second to get your orientation so you can make without a doubt the most out of each endeavor. One of the most troublesome territories of the GED to prepare for is the composing segment. </p> <h2> Type of G.e.d Essay Topics </h2> <p>Most people bomb the test simply because they don't comprehend what things to concentrate in order to pass. At whatever point you do as such, reproduce the conditions of the genuine test with the goal that you own a feeling of the environmental factors. Be that as it may, loads of individuals despite everything wind up stress all the more concerning this segment of test. There's in every case heaps of discussion about whether an individual can take the GED test on the web. </p> <h2> The Secret to G.e.d Essay Topics </h2> <p>A ll three of the most significant HSE tests give test prompts and sections. Include whatever definitions, clarifications or models you need to add substance to each passage. You should offer explicit proof from the sections and clarify the connection between the proof and your essential thought. Peruse the two entries cautiously. </p> <p>They're likewise a methods for keeping your psyche dynamic as you read. There are a great deal of things you're ready to expound on! Luckily, there are strategies to make this part basic for you. As a general rule, much of the time you can pick any theme you like and, for example, expound on your future desires and profession yearnings. </p> <h2> Get the Scoop on G.e.d Essay Topics Before You're Too Late</h2> <p>You ought to comprehend what you will focus on. As you realize what focuses you should address, composing ought to be to some degree clear. Moreover, you need to get at any rate 145 focuses on every single subject. Include a couple of center sections, where you talk about explicit focuses in your essential thought. </p> <p>This is a fairly basic inquiry among understudies. In most of cases understudies are totally allowed to settle on any theme they like. Nonetheless, it's not exactly as simple as it would appear. CA understudies get an aggregate of 425 minutes to finish the entirety of the test. </p> <h2> The Secret to G.e.d Essay Topics </h2> <p>Mastering exposition composing takes a considerable amount of training and perusing. Being pushed while it may get your concentration far from the assignment and influence the nature of your exposition. On the off chance that you understand that you are adhered with respect to composing a paper, demand someone's help that will assist you with continuing through composing an article. Turning into a magnificent essayist is fundamentally a years-in length game-plan. </p> <p>Pick the online GED cla sses you wish to join in. Assuming there is any chance of this happening, your test prep ought to include papers scored by methods for an educator. You should pick the test for an authority GED testing office. Once more, while our free GED Practice Test will give you the opportunity to get acquainted with the materials, you shouldn't tally exclusively on it to achieve a high score. </p> <p>The supreme most significant aspect of this strategy is to ensure your postulation explanation and supporting focuses bode well! Remember, you're being decided on how well you're ready to sort out and express your case. You'll give proof from the entry together with from your comprehension and experience. Your reaction ought to be sorted out, with a beginning, center, and end. </p>

Funny Persuasive Research Paper Topics

Funny Persuasive Research Paper TopicsWhen you find yourself confronted with a seemingly endless number of appealing and interesting topics for a persuasive research paper, it can be difficult to choose the ones that will have the most impact. In this article, I will share with you some of the most common and humorous persuasion research paper topics.When you think about it, howling pack mongrels seem to be everywhere. They show up in newspapers, they show up on television and even in your neighborhood. If you've been hearing them, you've probably seen them too. So, what are they?Pack mongrels are products of evolution. While looking for new species to populate their world, animals such as wolves and coyotes have looked for new species to prey on. The result has been packs of carnivores that prey on other packs of carnivores. These packs of carnivores, called packs, include all the people you know and many you don't. This makes us a pack.The question is, do these pack mongrels mean a nything? Of course not! However, they have a lot of interesting features that fascinate us. For example, when these animals kill, they often make a series of killing moves. Then they go right back to eating.This must be why they get eaten. But even if they weren't pack carnivores, what are these 'pack' things? Just like humans, these animals are part of a group. But unlike humans, they get together in groups of several hundred or thousands, and their members live in villages. So their food comes from hunting other humans, not from plants or animals.Some say that they are part of a human herd. Others say that they are human freaks. But even if they aren't part of a herd, this doesn't mean that they are not a part of the human race.Many say that pack mongrels may be the most intelligent species of humans. Indeed, they are. The most intelligent of these carnivores understand that when a human builds a fire, he is doing something that creates food. He sees that as a form of expression, even if he doesn't understand why.So are pack mongrels really more intelligent than humans? Maybe not. But they sure are hilarious. That's what makes them so interesting.

Essay Topics for Prince and Pauper

Essay Topics for Prince and PauperAre you looking for essay topics for Prince and Pauper? There are a few different tips to remember. First, there are several different styles and there is no 'one' way to write a piece. But, it is important to understand that essay topics are broken down into different categories.And, that breaks down into a lot of choices. This can be confusing. Consider some of the suggestions below to help you make the right decision.You can look at certain topics that are similar to a love story. It can be very close to your own life, but you have been single most of your life. So, look at your story and see if you can use that as a base for your essay. Maybe you are a married person who has been single since the time you were a child. That is a perfect example of a love story.The penultimate point is that these stories should be about someone you really love. It is not about a friend or a family member. And, this doesn't mean you don't have to love them as well. You just want to see your story and what drives it. That can help you understand your own journey with Prince and Pauper. For instance, if you think you might love them more than any other person, you can say that.Some essay topics could be about education. Consider you being a stay at home mom, who is looking for a job. You may have to go back to school if you are looking to get another job. You may have chosen to go back to school because you have completed a course.Many times, you will be asked to start studying for your college degree. Or, you may have found a field that you want to learn more about. Perhaps, you have decided to take a class in this field. Again, a love story can be your base for this topic.These are all great options to consider when you are looking for essay topics. Just keep in mind that this will depend on what is really going on in your life. Consider all of your options, and don't be afraid to change things around if you are having second thoughts.

Does Society Prohibit Mothers From Higher Education

Does Society Prohibit Mothers from Higher Education? A Review of The Literature In a society that requires higher levels of education in order to survive financially in current economic times, women are experiencing an increased field of setbacks in the academic world. As opportunity in western civilization has finally presented itself to women, it is young women who are beginning to face opposition of college success due to the call of motherhood. This literature review aids in considering whether the three previously mentioned approaches will offer a desirable outcome for solving the decrease in motherhood dropout. Who is at risk for dropping out early? What is keeping young mothers from school? How can mothers be encouraged back to school? College drop out rates are increasing to an all time high by unexpected pregnancy, due to financial drain caused by child care, tuition, and transportation. In order to experience a decrease in motherhood dropout, colleges must institute scholarships for young mothers, on-campus child care, and free transportation to and from school. Who Is At Risk For Dropping Out Early? â€Å"61% of students who have a child dropout of school[...] and The National Campaign’s Andrea Kane points out that the majority of unplanned pregnancies actually happen to women in their 20s, not teenagers† (Gault, etc, 2014 ). Research from The National Campaign states that women who are at the prime age for college education are in fact the very women who areShow MoreRelatedFeminism : Women And Women1316 Words   |  6 Pagesâ€Å"I need feminism because my mother prays that I marry a successful man more than she prays that I become successful† (Unknown). According to Merriam-Webster’s dictionary, feminism is the belief that women and men should have equal rights and opportunities. The feminist revolution has come a long way, yet women are still being viewed as beneath men. Unfortunately, we are still living in a male dominated society. The work that is done by a man is still being seen as more significant and worthwhileRead MoreThe Aid For Families With Dependent Children Organization914 Words   |  4 Pagesorganization claims to be a resource that offers money to mothers who are in need of assistance. Society believes that mothers who use this resource are reliant on the system and are unwilling to find employment to become independent. Those who invoke this premise could be no further from the truth. Substantial evidence proves that single mothers who use this system do not have sufficient means to support themselves and their children. For this reason, mothers are forced to find additional provisions that willRead MoreIs Abortion A Bad Thing? Essay1488 Words   |  6 Pagesorganization support, the pseudonym Jane Roy (JaneRoe) McCaw lie to himself by the wicked violation of conception, and the implementation of the state to prohibit abortion laws Dallas County Attorney General Henry Wade (HenryWade) to court. During the trial, the case aroused widespread concern, and ultimately detonated the American society life right ( pro-life) and choice (pro-choice) of the overall controversy..On June 17, the federal court in Texas made a ruling in support of McCowie, butRead MoreOvercoming Marginalization1408 Words   |  6 PagesToni Cade Bambara, talks about a group of young children learn a lesson from Miss Moore who receive education and has sense of responsibility for those children. Most of those of children are poor and marginalized. In â€Å"class in America†, the author, Gregogy Mantsios, explores that there are many unfair exist in America among different classes. However Miss Moore also mentioned that â€Å"It does not have to be that way. In our society, there is no denying that family background, income, race, gender andRead MoreTeenage Pregnancy And Teen Pregnancy1546 Words   |  7 Pages15 to 19 in rural counties was 43 per 1,000, nearly one-third higher than the rate for metropolitan counties (33 per 1,000), says a released report. Teenagers see the world in a different way than adults; their perception is sharper and they are more prone to engage in activities that don’t conform to society’s norms. Americans commonly believe that educational, social, medical, and economic difficulties experienced by adolescent mothers and their children are the consequences of teenage childbearingRead MoreAmerica Is The Land Of The Free Essay1403 Words   |  6 PagesIn recent years racial and socioeconomic differences have grown more prevalent in our society, and many wonder why. Growing up in Ethiopia, the concept of race was never popular or significant, as there was little to no racial diversity. Coming from a country where I did not even look at the color of my skin to a place where the only thing people saw was my color, astonished me. Living in the United States and learning about slavery in middle school, I thought of it as something that was long goneRead MoreAbortion And Its Effect On Society1272 Word s   |  6 PagesIn society today, abortion takes place on a daily basis. Abortions have been a subject of medical, lawful, religious, and moral intrigue for a long time. As a legislative issue in the United States, abortion has been acknowledged and subsequently managed for many years. In the mid 1800s, every state that had developed at the time had also created some form of abortion law. To this day, 60% of abortion laws we face today were enacted in that period (Hardin, 1969). However, even before these restrictiveRead MoreHinduism Essay791 Words   |  4 PagesShiva, the destroyer; and Sakti, the Mother of Goddesses, also known as Parvati, Mahalakshmi, Durga or Kali. In the past there were more than just these three listed above but over time they have lost influence over the religion and left just these three as the main religious influences in the Hindu religion. By Sanatana Dharma having different sets of beliefs it sets it apart from other religious groups and makes it a n on-uniting religion. Sanatana Dharma does not force one set of beliefs on anyRead MoreEducation in the United States is Falling Behind1436 Words   |  6 PagesEducation is an integral part of society, School helps children learn social norms as well as teach them to be successful adults. The school systems in United States, however are failing their students. In the world as a whole, the United States is quickly falling behind other countries in important math and reading scores. The United States ranked thirtieth in math on a global scale and twentieth in literacy. This is even more true in more urban, lower socio-economic areas in the United StatesRead MoreArab Women Experience Discrimination1317 Words   |  5 PagesArab women are always being criticized by other societies as if they are slaves or servants. Actually, this perspective does not prevail on all Arab women as it depends on their social class and their level of education too. It is true that a high percentage of Arab women are treated by men or by their countries’ government with inequality, unlike men. I completely agree that some of them are experiencing discrimination, although few improvements had occurred since the past decades. Some of this

Competition Law Cartel Provisions

Question: Discuss about theCompetition Lawfor Cartel Provisions. Answer: The Competition and Consumer Act, 2010[1] is the legislative vehicle in Australia for the competition law. This law seeks to promote competition, along with fair trading, in addition to providing the necessary protection to the consumers[2]. Part IV of this act relates to the restrictive trade practices and provides provisions which are aimed at deterring such practices by the companies, which can be deemed as anti-competitive, or in other words, which restrict the free competition. Division 1 of this part contains the provisions regarding the cartel conduct[3]. The price fixing provision, as well as, the exclusionary provisions, before 2009, were subjected to civil penalty sanctions and were prohibited per se. but the Dawson review recommended that the criminal sanctions should be introduced for the cartel conduct[4]. This very recommendation was implemented in 2009 in the quoted division of the act. These provisions are in line with the recommendations of OECD (Organization for Economic Co-operation and Development) and the overseas practices[5]. In the matter of Australian Competition and Consumer Commission v Australian Safeway Stores Pty Ltd (No 2)[6], it was held that cartel provision is such an element or an aspect of the contract, understanding or an arrangement which had the ability to bring out the intended results. And so, this act prohibits any such arrangement amongst the competitors, which can result in or which are in the form of price fixation, restriction of outputs in the production or supply chains, rig bids, and the division of market through allocation or territories, customers or suppliers[7]. Since July 24th 2009, Division 1 of Part IV of the Competition and Consumer Act, 2010 has prohibited cartel conduct. Cartel conduct is treated as a criminal offence as it is prohibited civilly[8]. Earlier for this prohibited the definition of price fixing covered under Section 45A Trade Practices Act 1974 had to be relied upon, but it has been repealed. Section 44ZZRD of the Competition and Consumer Act covers the definition of cartel conduct and covers 4 kinds of activities. These are price fixing (as had been earlier covered in the now repealed section 45A), bid rigging, market division, and restricting outputs[9]. Such provisions are included so that the consumers are protected and at the same time, fair competition prevails. The cartels have been made illegal as they cheat the other businesses and the consumers, and along with this they restrict healthy economic growth[10]. This is done by increasing the prices for both the businesses and consumers by inflating the capital and input costs artificially, across the chain of supply, and this includes the cost of buildings, interest, and rent of equipment[11]. The other ways in which this is done include: Locking up the resources by interfering with the normal supply, so as to demand forces. By doing so, the other operators effectively lock out from access to the distribution channels and resources. Reducing the investment as the cartels block new entrants, which could invest in jobs, opportunities or economic growth. By dominating the markets, plus by confining the goods, as well as, the services, the cartels destroy the other business, and to such an extent that the well-run and honest organizations could not survive. Reducing the innovations, as well as, choices through the protection of own members which are inefficient and who do not have to compete, and as a result of this, they do not invest in any kind of research and development. By increasing the taxes and reducing series through the targeting of public sector or by taking the additional costs which are paid by the consumers in form of taxes and rates By negating the confidence of the consumer over the entire industry, which includes the creation of bad consumer sentiment towards the compliant organizations, which do not undertake cartel activities. Through rigging bids in public infrastructure projects to decrease the infrastructure, which results in the inflation of costs, and consequently reduces the capacity of the public sector to make investments in the beneficial projects[12]. Division 1 contains the primary prohibit on such cartel conduct in sections 44ZZRA - 44ZZRV in Australia. Section 44ZZRD provides the four forms of activities, as highlighted earlier. Such conduct has been prohibited where given effect or made in to a contract, understanding or an arrangement, in addition to the involvement of two or more parties, which are competitors. Regarding the price fixation, the provision has to be for the purpose or having the effect of fixation of price. And the rest of the conduct relates to the requisite purpose[13]. The Federal Court in the case of ACCC v Leahy Petroleum Pty Ltd[14] viewed that the following elements have to be present in a contract, understanding or an arrangement for it to exist, i.e., communication, consensus, and commitment. The most controversial is the last element, which is commitment, as it has resulted in a suggestion to expand the bar on the anti-competitive conduct to the concerted practices, but these do not include the direct cartel prohibitions. To be covered under the definition provided in the act of the cartel conduct, the contract, understanding or arrangement has to be amongst the parties, which is more than 2 in number, and who are in or are likely to be in competition, relating to the attainment or supply of the related services or goods. The courts held that the threshold limit was quite low in the matter of Norcast S.r.L v Bradken Limited[15]. Further at the first instance, the court held that the likeliness of being in competition could be taken to mean as likelihood that such is not distant, in the given circumstances. Recommendations were made by the Harper Panel regarding the threshold limit to be modified, so that the conditions of competition could be satisfied, only when the organizations are competing with each other or are likely to compete with each other. And in such a case, the likelihood has to be evaluated on the equilibrium of possibilities where it is is more probable in comparison to not[16]. Section 44ZZRF makes in an indictable offence to make a contract, understanding or arrangement which contains the provisions of cartel, and Section 44ZZRG lays down the same consequence for the contracts, understandings or arrangements which give such an effect. A fault element has to be established to constitute an offence, and this is defined as a belief or knowledge[17]. Under section 44ZZRH, an organization can be responsible for an unlawful act even when the other parties are such, which are not responsible unlawfully or who have been guilty or set free from the charges of offence, unless and until all the other parties to such an conformity have been found to be not guilty, and any guilt finding is or would be inconsistent with the acquittal[18]. The power to make a civil order against a person prosecuted against section 44ZZRGF or 44ZZRG is provided to the court under section 44ZZRI. In substance, the civil prohibition mirrors the criminal prohibition against the giving effect or making the cartel provision, as covered in sections 44ZZRK and 44ZZRJ, respectively. Though, for civil prohibitions, the fault element is not necessary to be proven[19]. By providing such provisions, which define and set out the criminal or civil liability upon the businesses, which are indulged in cartel conduct, the Division 1 of Part IV of the Competition and Consumer Act, 2010 promotes fair competition, and also protects the consumers. Australian Competition and Consumer Commission v Visy Holdings Pty Ltd (No 3)[20] is one of the cases which have highlighted the far reaching consequence of violation of the competition law, both in terms of damage to the reputation and the pecuniary losses. This was a landmark case in the history of cartel conduct. Also, this was a crucial case due to the record fine that was imposed over the breaching parties and the company. This case came to be known as example for the cartel conduct for a long time, in the history of price fixation by the cartels. The businesses have to be aware about the requirements of the competition law, along with the conduct which could be inferred as, or which could lead to a breach of the Trade Practices Act 1974[21]. In the matter of ACCC v Visy Holdings, a penalty of $ 36 million[22] was levied on the Visy Industries Holdings Pty Ltd (Visy), and two of its employees, Harry Debney and Rod Carroll, were awarded personal fines of $ 1.5 million and $ 500,000, respectively[23]. Around 90% of the corrugated fiber packaging market, whose worth was $ 1.8 billion - $2 billion for each year, was controlled through an agreement between Amcor and Visy[24]. It was alleged by the ACCC that from 2000 to 2004, a market sharing, as well as, price-fixation agreement was entered between Visy and Amcor, regarding the supply of the corrugated fiberboard packaging. The nominated executives of both the companies used to consult and coordinate the price rises and also colluded while negotiations for quotes took place for the consumers. When the big organizations wanted to negotiate the contracts again, the information was swapped amongst the two companies to make certain that the quote of the competitor was higher than the existent pricing structure[25]. When the Amcor management reported this conduct to the ACCC, only then this scheme was discovered. Further, Amcor was given the protection from any sort of action, for the help in bringing Visy down and stopping the cartel conduct. But, in the class actions which involved over 4500 businesses, both Visy, as well as, Amcor were asked to pay up $ 95 million by the Federal Court to the consumers. An agreement statement of fact was presented in the court, as per which Visy had breached Section 45 of the Trade Practices Act knowingly by a collusion with Amcor, which was a competitor, so that the prices could be fixed in the supply industry of the cardboard boxes. According to the judge of the case, Justice Heerey, this was the most serious case which had been brought to the Court, sine the time price fixation had been specifically prohibited through the statute, which was duration of over 30 years[26]. Trade Practices Acts section 45 prohibited the corporations for arriving at or from giving the effect to any understanding which can be deemed as anti-competitive, as has been stated therein. The price fixation is specifically dealt in section 45A and provides that any provisions which is aimed at or which is expected to have such an effect of maintaining, fixing or controlling the prices, is to be considered as to having the purpose or having the effect of shrinking the competition in a substantial manner. In other words, once a fixation of price has been established, the test of lessening of competition in a substantial manner is satisfied, and there is no further need for any evidence[27]. After the penalty orders were handed down by the court against the employees of Visy and Visy itself, it was noted by the ACCC that for such cartel conduct, the maximum penalty can be 3 times the amount of benefit which was availed by the company which indulged in such conduct. And in case, such a value cannot be determined, then the amount shall be ten times the annual turnover of the corporate group indulged in cartel conduct[28]. Since this decision has been given by the court, a concern has been expressed by Graeme Samuel, the ACCC Chairman, regarding the class action which was subsequently launched by the consumers against Amcor and Visy. As per Samuel, the immunity policy was threatened due to the class action, which was specifically made for the party leaving a cartel, and which was Amcor in his case. He viewed that if the ones seeking protection have the surety of being hit by massive class action damages claim, due to their confession, then the amount of such disclosures would significantly decline[29]. The Trade Practices Act was replaced by the Competition and Consumer Act. And even under the new act, especially under the provisions stated under Part IV of Division 1 of this act, i.e., section 44ZZRF and 44ZZRG were breached in the case of Visy[30]. As highlighted earlier, Section 44ZZRF presents that a company commits an offence when such a company makes a contract or an arrangement or arrives at such understanding, and a cartel provision is contained in these, in addition to the presence of fault element of knowledge and belief, then it is a criminal offence[31]. In Visys case, the company had entered into a contract, which limited the competition substantially[32]. Visy had entered into a contract for market sharing and fixation of price with Amcor, for the supply of corrugated fiberboard packaging. Moreover, the cartel went for nearly 5 years, so the fault element was clearly present, as there was a clear knowledge of cartel conduct happening. Hence, even in the new act, Visy is guilty. And according to the quoted section, is liable to higher penalties, than the one which was awarded to it under the Trade Practices Act. So, Visy would have been liable to a fine not exceeding the higher of $10,000,000; or 3 times the value of total benefits determined by the court which have been attained by one or more individuals and are reasonably attributed to the commission; or in case the court is not able to decide upon the value of such benefits, than the 10% of the yearly turnover during the 12 months ending at the conclusion of month in which such an offence was undertaken by the corporation, or when such offence was begun[33]. Section 44ZZRG provides the provisions regarding an offence being committed by a corporation when such a corporation enters into a contract or an arrangement or arrives at such understanding which gives the effect to any cartel provision, in addition to the presence of fault element of knowledge and belief then it is a criminal offence. The penalty provisions remain the same as in section 44ZZRG[34]. The contract entered into between Visy and Amcor, also had the effect of considerably shrinking the competition, as they restricted the supply of goods and services. So, under both the acts, i.e., Competition and Consumer Act and its predecessor, the Trade Practices Act, the conduct of Visy in the case of ACCC v Visy Holdings, would be treated as a cartel conduct. And under both the acts, the provision of knowledge and belief, to establish the fault element is present. The only difference is that the new act is much more stringent and hence, the penalty levied on Visy for such a cartel conduct, would have been a lot higher than it was due to the applicability of the Trade and Practices Act. 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