DR. HERBERT NEVYAS AND DR. ANITA NEVYAS-WALLACE
DR. HERBERT NEVYAS ANDDR. ANITA NEVYAS-WALLACENevyas Eye AssociatesTwo Bala Plaza, PL-33333 E. City AvenueBala Cynwyd, Pennsylvania 19004(Complainants)v.A HAPPY DREAM HOST CUSTOMER417 Associated Rd. #324Brea, California 92821(Respondent)))))))))))))))Domain Names In NevyasLasik.comCOMPLAINT IN ACCORDANCE WITHTHE UNIFORM DOMAIN NAME DISPUTE RESOLUTION POLICY[1.]This Complaint is hereby submitted for decision in accordance with the Uniform DomainName Dispute Resolution Policy (UDRP), adopted by the Internet Corporation for AssignedNames and Numbers (ICANN) on August 26, 1999 and approved by ICANN on October 24,1999, and the Rules for Uniform Domain Name Dispute Resolution Policy (UDRP Rules), withan effective date of March 1, 2010, and the National Arbitration Forum (FORUM) SupplementalRules (Supp. Rules). UDRP Rule 3(b)(i).[2.]COMPLAINANT ]Telephone:Fax:E-Mail:[a.]Complainant’s Counsel:[b.]Address:Dr. Anita Nevyas-Wallace and Dr. Herbert NevyasNevyas Eye AssociatesTwo Bala Plaza, PL-33333 E. City AvenueBala Cynwyd, PA 19004610.668.2777610.668.1509info@nevyas.comBryna S. Scott, EsquireAlexis Arena, EsquireFlaster/Greenberg P.C.1600 John F. Kennedy Blvd., Suite 200
[c.][d.][e.]Philadelphia, PA reenberg.comTelephone:Fax:E-Mail:Complainants prefer the following method of communications in the administrativeproceeding:Electronic-Only lastergreenberg.com[c.]Contact:Alexis ArenaMaterial Including Hard Copy[a.]Method:mail[b.]Address:1600 John F. Kennedy Blvd., Suite 200Philadelphia, PA 19103[c.]Contact:Alexis ArenaComplainants choose to have this dispute heard before a single-member administrativepanel.[3.]RESPONDENT INFORMATION LISTED IN WHOIS ][e.]Telephone:Fax:E-Mail:A Happy DreamHost Customer417 Associated Rd #324Brea, California [d.][e.]Telephone:Fax:E-Mail:A Happy DreamHost Customer417 Associated Rd #324Brea, California ess:A Happy DreamHost Customer417 Associated Rd #3242
[.][d.][e.]Telephone:Fax:E-Mail:Brea, California dreamhost.comSee Whois Database Information and Registrar Whois Information, attached hereto asExhibit A.[4.]DISPUTED DOMAIN NAME(S)[a.]The following domain name is the subject of this rtNevyasLasik.com[b.]Registrar ’s Name:Registrar Address:New Dream Network, LLC417 Associated Road, PMB 257Brea, California 92821Telephone Number: 213.947.1032Fax:unlistedE-Mail Address:unlistedTrademark/Service Mark Information:Complainants Dr. Herbert Nevyas and Dr. Anita Nevyas-Wallace are surgical andmedical ophthalmologists that have performed lasik surgery since at least as early as 1995. SeeVerification of Dr. Anita Nevyas-Wallace, attached as Ex. B. Dr. Herbert Nevyas foundedNevyas Eye Associates in 1964 and has directed its medical and surgical ophthalmology practicesince that time. Ex. B. Dr. Anita Nevyas changed her name to Anita Nevyas-Wallace in 1987,but continues to use the name Anita Nevyas. Ex. B. Both of Complainants have practiced lasiksurgery continuously at Nevyas Eye Associates since at least as early as 1995. Ex. B. Theirpractices are described at the website www.nevyas.com. See Printouts from Nevyas.comattached as Exhibit C.Complainants have advertised their lasik practice to the general public since 1992 andhave done so continuously using the marks “Dr. Herbert Nevyas,” “Dr. Anita Nevyas,” “NevyasEye Associates,” and “Nevyas Lasik.” Ex. B. In addition to traditional forms of advertising andmarketing, Complainants advertise their practice online through the websites Nevyas.com andNevyasVideo.com, through informational articles posted on other websites, and through onlinevideos at websites such as YouTube.com. Ex. B. For example, Complainants’ YouTube videosdisplay the headings “Dr. Herbert J. Nevyas LASIK” and “Nevyas Eye Associates LASIK.” SeeYouTube videos displaying marks, attached as Exhibit D.3
The Forum has previously recognized that individuals have common law trademarkrights in their own names enforceable in domain dispute proceedings. See Jerry Damson, Inc. v.Texas International Property Assoc., F0702000916991 (Nat. Arb. Forum Apr. 10, 2007) (JerryDamson doing business under the mark “Jerry Damson Acura” had right toJerryDamsonAcura.com domain name). See also Margaret Drabble v. Old Barn Studios Ltd.,D2001-020 (WIPO Mar. 26, 2001) (author Margaret Drabble had common law rights toMarthaDrabble.com domain); Jeanette Winterson v. Mark Hogarth, D2000-0235 (WIPO May22, 2000) (Jeanette Winterson had common law rights to her name); Julia Fiona Roberts v.Russell Boyd D2000-0210 (WIPO May 29, 2000) (Julia Roberts had common law rights to “JuliaRoberts”); Thibodeau, v. Yomtobian, FA 94868 (Nat. Arb. Forum June 28, 2000) (rights to “Dr.Lauren” in dispute re: www.drlauren.com).The complainant also need not be a famous individual for common law rights in his orher name to arise. See, e.g., Dr. Paul Guerrino v. Yin Chew, FA0204000110873 (Nat. Arb.Forum June 17, 2002) (Practicing dentist Dr. Guerrino owned rights towww.guerrinodentistry.com).Finally, it is not necessary that Complainants own a trademark registration for their markfor that mark to be protected. See Jerry Damson, supra; Broad Corp. v. Renteria, D2000-0050(WIPO Mar. 23, 2000) (the Policy “does not distinguish between registered and unregisteredtrademarks and service marks in the context of abusive registration of domain names” andapplying Policy to “unregistered trademarks and service marks”). Complainants havecontinuously used the “Nevyas Lasik” mark and similar trademarks containing their names andthe “Nevyas” surname in connection with their medical and surgical ophthalmology practicessince at least as early as 1995. Ex. B. As such, they have developed common law rights in themarks. See Tuxedos By Rose v. Nunez, FA 95248 (finding common law rights in a mark whereits use was continuous and ongoing).[5.]FACTUAL AND LEGAL GROUNDSThis complaint is based on the following factual and legal grounds:[a.]Respondent’s domain names are nearly identical to Complainants’trademarks, pursuant to ICANN Policy ¶ 4(a)(i), and are being used in adeceptive manner.Respondent’s domain names AnitaNevyasLasik.com, HerbertNevyasLasik.com, andNevyasLasik.com are nearly identical to Complainants’ names and trademarks. Complainantsare well-known lasik surgeons whose services are advertised in connection with the marks“Herbert Nevyas Lasik” and “Anita Nevyas Lasik” and the domains Nevyas.com andNevyasVideo.com. It is well-established that the addition of a generic top level domain such as“.com” to a trademark, or other minor changes to the mark, do not cause the domain name to benon-identical. See, e.g., Jerry Damson, supra.; Tropar Mfg. Co., Inc. v. TSB, FA 127701 (Nat.Arb. Forum Dec. 4, 2002 (“The addition of a generic top-level domain does not add anydistinguishing characteristics to a domain name because it is a required feature in every domainname.”)4
Respondent further increases the likelihood of confusion between his domains andComplainants’ by advertising his websites in a deceptive manner that suggests they are affiliatedwith Complainants and Nevyas Eye Associates. A Google search for “Nevyas Lasik” or asimilar term displays the following Google headlines for Respondent’s websites:Welcome to HerbertNevyasLasik.com! – herbertnevyaslasik.com/Drs. Herbert Nevyas & Anita Nevyas-Wallace - herbertnevyaslasik.com/index.php?.Nevyas Eye Associates - www.anitanevyaslasik.com/index.php?.See Google search results, attached as Ex. E (Respondent’s websites are highlighted so that theycan be distinguished from Complainants’ website).Once a patient or potential patient visits Respondent’s websites, the patient viewsdisparaging and false remarks about Complainants. See Printouts from Respondent’s websites,attached as Exhibit F. Respondent’s websites also contain links to other websites featuring theservices of other lasik surgeons and doctors with similar ophthalmology practices. Id.Respondent’s websites track the number of clicks to each competitive website, suggesting thatRespondent may be profiting from this confusion and traffic to his website by obtaining clickthrough fees. Id.[b.]Respondent has no rights or legitimate interests in the domain names,pursuant to ICANN Policy ¶ 4(a)(ii).Respondent is apparently an individual by the name of Dom Morgan, who was previouslyinvolved in state and federal litigation with Complainants. See Ex. F (Printout fromRespondent’s websites stating websites are owned by Dom Morgan). Dom Morgan was apatient of Complainants in 1998 who was unhappy with the results of his treatment andsubsequently posted numerous false, disparaging and defamatory statements regardingComplainants and their practice on multiple websites. Ex. B. Complainants sued him andsubsequent to these lawsuits, statements were removed from his websites. Unfortunately, theparties’ legal battle continues. Ex. B.Currently, Respondent owns and operates a number of websites where he criticizes thepractice of lasik surgery and various lasik surgeons, including Complainants. Respondent is theowner of websites such as www.nevyasvmorgan.com, www.lasikdecision.com,www.lasikliberty.com, www.lasikfda.com, and www.flawedlasik.com. See Exhibit G (WhoisInformation for Respondent’s Other Websites). Respondent also operated the websitewww.lasiksucks4you.com. This action does not implicate Respondent’s ability to post criticalstatements regarding Complainants on those domains, or any domains that do not containComplainants’ trademarks. The domain names at issue in this action indicate that they areowned by Complainants, not that they are owned by an individual criticizing Complainants.Prior panel decisions have held that this type of initial interest confusion, caused by the domainname itself, is impermissible. See The Paxton Herald v. Millard, FA0207000114770 (Nat. Arb.Forum Aug. 21, 2002) (“While the content of Respondent’s website may enjoy First Amendment5
and fair use protection, those protections do not equate to rights or a legitimate interest withrespect to a domain name which is confusingly similar to another’s trademark.”); Council ofAmerican Survey v. Pinelands Web Services, D2002-0377 (WIPO July 19, 2002) (“Respondentmay have a right to refer to the mark in critical content, the wholesale appropriation ofComplainant's mark in a domain name, without any distinguishing material, creates confusionwith Complainant's business and is not fair use merely for the purpose of criticism No criticismis apparent from the domain name itself; it is not sufficient that the criticism may be apparentfrom the content of the site.”)1. Respondent has no rights or legitimate interests in the domains because he is notcommonly known by Complainants’ trademarks and does not use the marks inconnection with a legitimate offering of goods and services.Respondent has no rights or legitimate interests in NevyasLasik.com domains because hesells no goods or services on his websites and seeks only to capitalize on Complainants’trademarks by luring consumer traffic to his website, disparaging Complainants, and advertisingsimilar lasik services offered by other practitioners. For example, when one of the links onRespondent’s website is clicked, the customer visits www.lasikinfocenter.com, where thecustomer views the following advertisements:Tri-County Eye PhysiciansCataract & Oculo-plastic Surgery Laser Vision Correction/LASIKwww.tricountyeye.comLocate an Eye DoctorLocate an Eye Doctor in your area and Learn more about your Eyeswww.ThinkAboutYourEyes.comOther links on Respondent’s website also advertise competitive products and services.See Printouts from Respondent’s websites, attached as Exhibit F. Respondent’s websites displaythe number of hits on each link, indicating that Respondent’s websites have redirected thousandsof consumers to other websites advertising competitive products and services. Respondent alsohas a history of using websites to solicit donations to pay his legal fees in litigation againstComplainants. See, e.g., http://www.lasik-flap.com/forum/viewtopic.php?f 6&t 373.Respondent’s NevyasLasik.com domains invite visitors to contact him and support him in hislitigation with Complainants.Respondent has no trademark or service mark rights in the “Nevyas Lasik,” “AnitaNevyas Lasik” or “Herbert Nevyas Lasik” trademarks and is not commonly known by thesemarks. Having no rights in the marks at issue, and offering no goods or services, Respondentsimply attempts to profit and damage Complainants by misleadingly diverting customer trafficaway from Nevyas.com and to his websites and the links on his websites.Respondent’s use of domain names that are nearly identical to Complainants’ marks todivert Internet users to websites that offer competitive products and services, and for which6
Respondent presumably receives a commission or click-through fees, is not a bona fide offeringof goods or services, nor is it a legitimate noncommercial or fair use of the domains under theICANN Policy. See Emmit Smith, III v. EmmitSmith.com, FA 555486 (Nat. Arb. Forum Oct. 26,2005) (citing Disney Enters., Inc. v. Dot Stop, FA 145227 (Nat. Arb. Forum Mar. 17, 2003)(finding that the respondent’s diversionary use of the complainant’s mark to attract Internet usersto its own website, which contained a series of hyperlinks to unrelated websites, was neither abona fide offering of goods or services nor a legitimate noncommercial or fair use of the disputeddomain names); Black & Decker Corp. v. Clinical Evaluations, FA 112629 (Nat. Arb. ForumJune 24, 2002) (holding that the respondent’s use of the disputed domain name to redirectInternet users to commercial websites, unrelated to the complainant and presumably with thepurpose of earning a commission or pay-per-click referral fee did not evidence rights orlegitimate interests in the domain name)).2. Respondent has no rights or legitimate interests in the domains because he is notmaking a legitimate, non-commercial fair use of the domains pursuant toParagraph 4c(iii), but is using the domains with an intent to tarnishComplainants’ trademarks and profit from misleadingly diverting customers.Respondent registered the NevyasLasik.com domains in February, 2009. See Ex. A.Respondent’s legal battles with Complainants began in 2000 and have continued into the present.Ex. B. Respondent’s websites make clear that Respondent’s goal is to tarnish Complainants’trademarks, damage Complainants’ business, and profit from the use of Complainants’ marks.Ex. F.Complainants assert this complaint not to impair Respondent’s First Amendment rightsbut because Respondent is using Complainants’ trademarks in the NevyasLasik.com domains tosuggest that the domains are sponsored by or affiliated with Complainants, to confuseComplainants’ patients and potential patients, and to lure traffic to Respondent’s websites.Respondent’s website headlines - “Nevyas Eye Associates” and “Welcome toNevyasLasik.com!” – misleadingly suggest that patients will be visiting Nevyas Eye Associatesor Complainants’ “Nevyas Lasik” practice if they select those links. Once the patient arrives atRespondent’s websites, Respondent’s has already profited from this initial interest confusion andhas succeeded in tarnishing Complainants’ trademarks.[c.]Respondent registered and uses the domains in bad faith, pursuant toICANN Policy ¶ 4(a)(iii).1. Respondent’s Registration of Multiple Domain Names Containing Complainants’Marks and His Advertisement and Use of Those Domain Names Causes aLikelihood of Confusion, Particularly Initial Interest Confusion, to AttractIndividuals Seeking Complainants’ Website to Respondent’s Websites.Paragraph 4(a)(iii) of the ICANN Policy lists a non-exhaustive list of circumstances thatindicate bad faith registration and use of domains, which includes evidence that the respondent7
“intentionally attempted to attract, for commercial gain, Internet users to [his or her] web site orother on-line location, by creating a likelihood of confusion with the complainant's mark as tothe source, sponsorship, affiliation, or endorsement of [his or her] web site or location or of aproduct or service on your web site or location.”Respondent’s use of Complainants’ marks in his domain names creates a likelihood ofconfusion and suggests an attempt to attract Internet users to Respondent’s websites forcommercial gain. See Am. Univ. v. Cook, FA 208629 (Nat. Arb. Forum Dec. 22, 2003)(“Registration and use of a domain name that incorporates another's mark with the intent todeceive Internet users in regard to the source or affiliation of the domain name is evidence of badfaith.”); see also G.D. Searle & Co. v. Celebrex Drugstore, FA 123933 (Nat. Arb. Forum Nov.21, 2002); Kmart v. Khan, FA 127708 (Nat. Arb. Forum Nov. 22, 2002).Furthermore, where a disputed domain name containing the complainant’s trademark isbeing used to feature links to websites that compete with the complainant, presumably forreferral fees, that use alone constitutes bad faith under the Policy. See Univ. of Houston Sys. v.Salvia Corp., FA 637920 (Nat. Arb. Forum Mar. 21, 2006); Asbury Auto. Group, Inc., v. Tex.Int’l Prop. Assoc., FA 958542 (Nat. Arb. Forum May 29, 2007); David Hall Rare Coins v. Tex.Int’l Prop. Assoc., FA 915206 (Nat. Arb. Forum Apr. 9, 2007); Am. Airlines, Inc., v. Tex. Int’lProp. Assoc., FA 914854 (Nat. Arb. Forum Apr. 10, 2007).2. Respondent Engaged in a Pattern of Registering Domains ReflectingComplainants’ Trademarks, Which Prevents Complainants from RegisteringCorresponding Domain Names Reflecting Their Marks.Pursuant to Paragraph 4(a)(iii), evidence of bad faith also includes evidence that theRespondent “registered the domain name in order to prevent the owner of the trademark orservice mark from reflecting the mark in a corresponding domain name, provided that[Respondent] engaged in a pattern of such conduct.” Respondent’s registration of a series ofdomains that all contain essentially the same website content suggests a pattern of registeringdomains so that Complainants cannot register them. There is no other justification forRespondent’s ownership of a series of domain names featuring the same website content.3. Respondent Registered the Domain Names Primarily for the Purpose ofDisrupting Complainants’ Business.Evidence of bad faith can also include facts indicating that the domain was registeredprimarily for the purpose of disrupting the business of the trademark owner. Respondent statesthat his websites were created for the following purpose: “to update and further prove allallegations I brought against the Nevyases as documented on my previously owned websiteLasikSucks4u.com and now LasikDecision.com. I would also like to show how I believe thecourts were wrong in many of their decisions and/or opinions regarding my med mal lawsuitMorgan v. Nevyas and the current Nevyas v. Morgan lawsuit.” Ex. F.Thus, Respondent admits that his websites were registered and are being used for todisrupt Complainants’ businesses. Respondent falsely alleged that Complainants committed8
medical malpractice, and if his stated intention is to attempt to publicly prove those allegations,his conduct necessarily involves disrupting Complainants’ businesses. See also Dr. KarlAlbrecht v. Eric Natale, FA 95465 (Nat. Arb. Forum Sept. 16, 2000) (“The Respondentintentionally registered a domain name which uses the Complainant’s name. There is noreasonable possibility that the name karlalbrecht.com was selected at random. There may becircumstances where such a registration could be done in good faith, but absent such evidence,the Panel can only conclude that the registration was done in bad faith.”)[6.]REMEDY SOUGHTComplainants request that the panel issue a decision that Respondent’s domain-nameregistrations be transferred to Complainants.[7.]OTHER LEGAL PROCEEDINGSNone.[8.]COMPLAINT TRANSMISSIONComplainants assert that a copy of this Complaint, together with the cover sheet asprescribed by NAF’s Supplemental Rules, has been sent or transmitted to Respondent at thecontact information provided, in accordance with ICANN Rule 2(b), and to the domain nameRegistrar at the contact information provided, in accordance with NAF Supp. Rule 4(e).[9.]MUTUAL JURISDICTIONComplainants will submit, with respect to any challenges to a decision in theadministrative proceeding canceling or transferring the domain name, to the location where theRespondent is located, in accordance with ICANN Rule 3(b)(xiii).[10.]CERTIFICATIONComplainants agree that their claims and remedies concerning the registration of thedomain name, the dispute, or the dispute’s resolution shall be solely against the domain-nameholder and waive all such claims and remedies against (a) the National Arbitration Forum andpanelists, except in the case of deliberate wrongdoing, (b) the Registrar, (c) the registryadministrator, and (d) the Internet Corporation for Assigned Names and Numbers, as well astheir directors, officers, employees, and agents.Complainants certify that the information contained in this Complaint is to the best oftheir knowledge complete and accurate, that this Complaint is not being presented for anyimproper purpose, such as to harass, and that the assertions in this Complaint are warrantedunder these Rules and under applicable law, as it now exists or as it may be extended by a goodfaith and reasonable argument.9
Respectfully Submitted,Bryna S. Scott, Esq.Alexis Arena, Esq.FLASTER/GREENBERG, P.C.1600 John F. Kennedy Blvd., Suite 200Philadelphia, PA 19103alexis.arena@flastergreenberg.comAttorneys for ClaimantsDated:July 1, 2010
EXHIBIT LISTABCDEFGWhois Information for Respondent’s NevyasLasik.com DomainsDeclaration of Dr. Anita Nevyas-WallacePrintouts from Nevyas.com DomainPrintouts from Complainants’ YouTube VideosGoogle search results highlighting Respondent’s domainsPrintouts from Respondent’s DomainsWhois Information for Respondent’s Other Domains
EXHIBIT A
EXHIBIT B
DR. HERBERT NEVYAS ANDDR. ANITA NEVYAS-WALLACENevyas Eye AssociatesTwo Bala Plaza, PL-33333 E. City AvenueBala Cynwyd, Pennsylvania 19004(Complainants)v.A HAPPY DREAM HOST CUSTOMER417 Associated Rd. #324Brea, California 92821(Respondent)))))))))))))))Domain Names In NevyasLasik.comVERIFICATION OF DR. ANITA NEVYAS-WALLACEI, Dr. Anita Nevyas-Wallace declare that:1. My father, Dr. Herbert Nevyas, and I are surgical and medicalophthalmologists at Nevyas Eye Associates. We have both been performinglasik surgery for patients since at least as early as 1995.2. Dr. Herbert Nevyas has directed a medical and surgical ophthalmologypractice since he founded Nevyas Eye Associates in 1964.3. We have been advertising our lasik practice to the general public since at leastas early as 1995 using the marks “Dr. Herbert Nevyas,” “Dr. Anita Nevyas,”“Nevyas Eye Associates,” and “Nevyas Lasik.” We have continuously usedthe marks since that time.4. I legally changed my name to Anita Nevyas-Wallace in 1987. However, I stilluse the name Anita Nevyas.5. We advertise our practice through the website Nevyas.com, throughinformational articles posted on other websites, and through online videos atwebsites such as YouTube.com and NevyasVideo.com.6. Dom Morgan was a patient of ours in 1998. He was unhappy with the resultsof his treatment and subsequently posted numerous false, disparaging and
EXHIBIT C
EXHIBIT D
EXHIBIT E
EXHIBIT E
EXHIBIT F
EXHIBIT G
Verification of Dr. Anita Nevyas-Wallace, attached as Ex. B. Dr. Herbert Nevyas founded Nevyas Eye Associates in 1964 and has directed its medical and surgical ophthalmology practice since that time. Ex. B. Dr. Anita Nevyas changed her name to Anita Nevyas-Wallace in 1987, but continues to use the nameAnita Nevyas. Ex. B.
Nevyas and the current Nevyas v. Morgan lawsuit. Drs. Herbert Nevyas &Anita Nevyas-Wallace Bala Cynwyd, PAI Philadelphia, PA I Marlton, NJ My experience with Drs. Herbert Nevyas and Anita Nevyas-Wallace(Nevyas Eye Associates), information regarding their investigational study, and the le
recommend Nevyas Eye Associates!”, anitanevyaslasik.com “Why I do not recommend Anita Nevyas!”, and herbertnevyaslasik.com “Why I do not recommend Herbert Nevyas!”. The title pages of each site have also been changed to further reflect these sites are not complainant(s). d) Respondent
gripe sites in which the names of the Complainants - Herbert and Anita Nevyas -- have been used in the domain names for sites that are devoted to describing Respondent‟s criticisms of those Complainants. Even assuming that their names can be the subject of a trademark-like UDRP complaint, this UDRP proceeding should take account of
alfred herbert drill type v 187 alfred herbert flash tapping machine no:2 182 alfred herbert key seater edgwick no: 1 242 alfred herbert lathe 7b & 7 preoptive spare parts 566 alfred herbert lathe auto junior operators 205 alfred herbert lathe auto junior mk 1 & 2 parts 204 alfred herbert lathe gap bed edgwick 6 ½” 241 alfred herbert tool & cutter grinder edgwick 14 x 26 ½” brochure 796 .
Herbert Spencer and his education theory have big impact in the history. "What Knowledge is of most Worth?" have guided the research on the scientific knowledge. Herbert Spencer and Education Herbert Spencer (April 27, 1820 -December 8, 1903) was a British positivist philosopher, sociologist and educational reformer.
11.Looking glass self: C H Cooley 12.Law of evolution: Herbert Spencer 13.Survival of the fittest, social Darwinism: Herbert Spencer 14.Organic analogy: Herbert Spencer 15.logical and non-logical action: Pareto 16.Circulation of elites: Pareto 17.Derivatives and residues: Pareto 18.Governing and non-governing Elites: Pareto
Oakeley, Sir Herbert (Stanley) (b Ealing, London, 22 July 1830; d Eastbourne, 26 Oct 1903).English composer, organist and educator. He was the second son of Sir Herbert Oakeley, 3rd baronet. His musical gifts began to show when he was only
Hooks) g. Request the “Event Hooks” Early Access Feature by checking the box h. After the features are selected click the Save button 3. An API Token is required. This will be needed later in the setup of the Postman collections. To get an API Token do: a. Login to you Okta Org as described above and select the Classic UI b. Click on .
