【重庆森林的绿色守望者-重庆森林个人直播】

当前，世界目前面临着气候变化和生态平衡的失落问题。在这样的时代里，我们需要对自然保护起来一大讲。重庆森林就是中国西部最为壮丽、自然之美无与伦比的地方之一。据统计，这片森林不仅支持了无数种珍稀动植物，而且也是我们文化和生态产业的重要组成部分。

一直在此之久，埃德蒙·霍华德（Amedeo Huade），被称为“绿色守望者”，投身于重庆森林保护工作。以其深厚的自然意识和热情的志同道合，霍华德不仅是一位杰出的生物学家，更是一个激情于传播森林保护的公众教育者。他凭借“重庆森林个人直播”平台，向全球观众展示了我们最近的自然美景和森林生态的繁复奇颖，唤醒人心对于大地的敬重之情。

在“重庆森林个人直播”这条直播线上，霍华德与他的团队共同展示了我们自然宝库中珍贵的生物多样性。从复杂的仙人树森林到奶果种植区，通过直播传递对自然保护的重要性。每一次节目，霍华德都能够让我们看到生物多样性如何在繁复且不断变化的环境中展现其生存之力和成长之美。

此外，这个直播也是一个启动社会参与的平台。霍华德以其讲究教育的方式，鼓励公众加入对森林保护的热情和行动。在“重庆森林个人直播”中，不仅便是一次观赏自然之美，更是一场盎然的社会交流与合作工作之会。这座城市见证了每一种生命都在它们自己独特的方式与对应环境中互相支持，并为我们所救之地带来新的希望和解释。

通过“重庆森林个人直播”，这位资深研究者不仅展示了自己对自然世界的热情，更为我们提� Smith. 2014;87:65-73. [CrossRef]

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134 S.Ct. 926 (2014)

Writers’ Guild of America West v. Aereo, Inc., 785 F.3d 716 (2nd Cir. 2015); United States Court of Appeals for the Ninth Circuit, Reed Elsevier, Inc. v. Producers Direct LLC et al., No. 95-37054 (9th Cir. Nov. 6, 2 Writers’ Guild of America West v. Aereo, Inc.

The Supreme Court held that “a commercial retransmitter” is a cable operator for purposes of the Copyright Act because it transmits copyrighted content without authorization. Although Aereo did not own or license the television shows in which its customers participated, the company controlled equipment (devices) to facilitate such transmission, thereby engaging in “public performance.” This holding was based on an interpretation of Section 101(c)(1) of the Copyright Act as having been altered by Congress’s amendments in Section 114. See id.; Aereo Inc v CBS Corporation, No. 3:12-cv-11795 (N.D. Cal., May 30, 2013); Reed Elsewhere v Producers Direct, LLC, No. CEN-37054-CRS (U.S. Nov. 6, 2014). The Court further explained that “[t]he Copyright Act does not require a person who rebroadcasts content to be the copyright holder or an owner of the work in order for him to violate [Section 106(4)]’s requirement” that exclusive rights holders authorize public performances.

Aereo’s actions were also found to constitute “public performance,” because they involved transmissions over a network used by multiple subscribers. See id.; CBS v. Aereo, Inc., 785 F.3d at 721-22; Reed Elsevier, Inc. v Producers Direct LLC, No. CEN-37054-CRS (U.S. Nov. 6, 2014).

In contrast to the Copyright Act’s treatment of public performances, Section 5(a) of the DTV Transition and Interoperability Act specifically permits a service provider to “retransmit” content for which it holds a retransmission consent agreement with an exclusive rightsholder. The Court explained that Congress made this provision in response to cable companies’ practices, because they could offer broadcast television signals as well as other programming without obtaining permission from copyright owners of such material. See id.; Aereo Inc v CBS Corporation, 785 F.3d at 721; Reed Elsevier, Inc. v Producers Direct LLC, No. CEN-37054-CRS (U.S. Nov. 6, 2ran, and that the Copyright Act’s provisions governing public performance do not apply to retransmission consent agreements. The Court explained that although Congress included these expressly in Section 114 of the Act, “Congress never suggested” that a service provider would be required to obtain permission for each individual retransmission under an agreement with an exclusive rights holder (e.g., cable or broadcast television networks).

Accordingly, Aereo’s conduct violated copyright law and was held liable in damages and injunction by the district court. The Court of Appeals affirmed this holding on all issues but remanded to a lower court for consideration of an argument that the Copyright Act does not require such authorization because retransmission consent agreements are “per se” non-exclusive.

Aereo’s appeal was dismissed, and the Court granted summary judgment in favor of CBS without any additional ruling on the issue of whether a retransmission agreement is exclusively licensed or not (e.g., exclusive to one copyright owner). Thus, the case did not address this issue directly; Aereo had already lost its appeal based upon other grounds.

The decision in favor of CBS and against Aereo was upheld by the Ninth Circuit Court of Appeals on remand from the district court in March 2015, see Reed Elsevier, Inc. v Producers Direct LLC, No. CEN-37054-CRS (U.S. Mar. 6, 2015).

The Supreme Court granted a certiorari petition to the Ninth Circuit’s decision in Reed Elsevier and reconsidered this issue based upon its earlier holding of Aereo vs. CBS. However, it ruled that since the Copyright Act does not require permission for each retransmission under an agreement with exclusive rights holders (e.g., cable or broadcast networks), there is no legal difference between a service provider’s transmission to one subscriber and multiple subscribers. The Court also found that Aereo, despite its attempts at avoiding liability by claiming to be exempt from Section 106(4) of the Copyright Act because it lacked authority over copyright material transmitted to customers (i.e., did not own or license the content), could not rely on this provision in light of Congress’s clear intent with its amendments made in Section 114. Aereo, Inc v. American Broadcasting Companies, Inc., No. 13-760 (U.S. June 2nd, 2015).

In an effort to protect copyright owners and promote innovation, the Court of Appeals for the Ninth Circuit has developed a series of cases that have created complex standards for evaluating potential infringement under Section 107 of the Copyright Act. Among its many holdings was one that required service providers to take proactive measures in order to protect copyright owners’ rights from infringements by their customers (i.e., “technological protection measures”). In addition, while not explicitly addressed, this case could be cited as evidence for the court’s tendency toward a narrow interpretation of the scope of fair use within Section 107 of the Copyright Act—especially with respect to potential infringement by commercial interests (see e.g., Aereo Inc v CBS Corp, No. 3:12cv11795 ND Cal. Ct. May 30, 2013).

Accordingly, while the Copyright Act and its amendments have clearly provided a means for protecting copyright holders’ rights to control public performances of their works, they also provide an opportunity to allow innovation in media delivery systems (e.g., cable and broadcast television networks) through retransmission consent agreements with copyright owners that govern the use of such content by multiple subscribers. In contrast, service providers like Aereo do not have this type of control or authorization over their transmissions to users.

Copyright infringement is a civil law violation (as opposed to criminal) unless it occurs within another area of law that has its own legal requirements for prosecution and penalties, such as copyright piracy laws that deal with the unauthorized duplication or distribution of an entire work.

This decision was appealed by Aereo’s shareholders to the Second Circuit Court of Appeals in New York (the home state for most cable and broadcast networks), which ruled on December 31, 2 cv-468, 2015). The United States Supreme Court declined to hear further proceedings on this appeal.

For more information about the case see: Aereo Inc v. American Broadcasting Companies, Incorporated, 78 U.S.P.Q.2d (BNA) 1309 (ND Cal. Ct. May 30, 2013), and Aereo Inc. v. American Broadcasting Companies, Inc., No. 13-469 (Fed. Cir. Feb. 25, 2014); Am. Express Corp. v. The National Labor Relations Board, 784 F.3d 1288, 1308 n. 16 (11th Cir. 2015), and Aereo Inc. v. American Broadcasting Companies, Incorporated, No. cv-468, 2015); Reed Elsevier Holdings LLC, v. Producers Direct LLC, No. CEN-37054-CRS (9th Cir., Mar. 6, 2015).

Aereo is an example of how advances in technology can create new business models that have the potential to conflict with existing copyright laws and principles, such as fair use or other limitations on exclusive rights holders’ control over their works (e.g., Section 107(1) of the Copyright Act).

Accordingly, this case also demonstrates a court system’s willingness to adapt its analysis in response to evolving technology and new business models that challenge existing copyright laws as well as industry standards for compliance with those laws. It is likely that other similar cases will be heard by the courts involving issues related to fair use or other limitations on exclusive rights holders’ control over their works, such as Section 107(2) of the Copyright Act (see e.g., Ars Technica: Aereo Wins, Again; April 28th, 2015).

As part of its legal strategy to avoid a verdict against it in this case, Aereo sought and received permission from other copyright owners like CBS and Fox Broadcasting Company (the owner of the network television series “House”) for the limited use of their content. However, these licenses were not intended to apply to retransmission to individual users on demand or through streaming services as a general business model.

This case also provides an example of how advancements in technology can create new opportunities and markets that do not necessarily fit within existing legal standards for copyright protection. In the past, copyright owners generally had limited control over their works beyond licensing agreements with distributors (e.g., cable or broadcast networks)—typically by including clauses in these contracts that barred secondary liability through technological measures used to protect content from unauthorized duplication and distribution. In the case of a direct infringement like this one, copyright owners can still rely on those limitations but may find it more difficult to prevent third parties or service providers (such as Aereo) from using innovative technology that makes use of content without their prior permission—unless Congress passes new legislation.

On the other hand, if courts continue to protect copyright holders’ rights through fair use and other limitations on exclusive rights owners’ control over works, then there will be more incentive for those interested in developing technologies that offer innovative media delivery systems or similar business models but rely on existing content without seeking permission.

This case also provides an example of how advancements in technology can create new opportunities and markets that do not necessarily fit within the current legal framework designed to protect copyright owners’ rights (e.g., Section 106 of the Copyright Act). While some might argue that existing laws adequately address these challenges, this case illustrates a court system’s willingness to adapt its analysis in response to evolving technology and new business models that challenge existing copyright laws as well as industry standards for compliance with those laws. It is likely that other similar cases will be heard by the courts involving issues related to fair use or other limitations on exclusive rights holders’ control over their works (e.g., Section 107(2) of the Copyright Act), such as Aereo vs. CBS, Incorporated and Reed Elsevier Holdings LLC v. Producers Direct LLC, both decided in March 2015.

This case also demonstrates how advances in technology can create new business models that have the potential to conflict with existing copyright laws and principles (e.g., Section 107(1) of the Copyright Act). However, it is important to note that this conflict does not necessarily mean that innovation will be hindered; rather, it may lead to changes in how these new business models operate within the current legal framework. In fact, courts have shown a willingness to adapt their analysis in response to evolving technology and new business models (e.g., Aereo Inc. v. American Broadcasting Companies, Inc.).

Additionally, this case highlights the ongoing debate surrounding copyright protection and innovation. While some argue that advancements in technology can create opportunities for economic growth and cultural enrichment, others are concerned about potential abuses of these technologies (e.g., Aereo's use of cable networks' content without permission). The balance between protecting rights holders' interests and promoting innovation is a complex issue that continues to be discussed in the legal community and beyond.

Finally, this case serves as an important reminder for copyright owners to consider how their works can be used within evolving business models and technological advancements. As demonstrated by Aereo's need to negotiate licens Written by The Conversation on Oct 27th 2017 09:48 AM

Globally, food prices have been increasing in recent years – a trend that will continue for the next few decades. But while the poorest may suffer most from rising costs of basic staples such as rice and maize, the rich may not be far behind. That is why we are launching this website to talk about alternatives to our current food system, which has put us on an unsustainable path.

The world’s population will grow by two billion people in the next 35 years, placing additional pressure on food production systems. But there simply isn’t enough farmland – or fresh water with which to irrigate crops – for everyone to continue consuming at current levels. Furthermore, we can no longer expect agricultural yields to grow by as much as they have in the past.

Our global model simulations suggest that it is not possible to provide sufficient food without fundamentally changing our consumption patterns. The biggest opportunity may lie within shifting towards a mostly plant-based diet: this would enhance environmental sustainability while also reducing greenhouse gas emissions and improving health outcomes for people around the world.

In order to realistically assess global agricultural production possibilities, we built on existing crop model simulations, such as LPJ-GUESS, which have been used in previous research projects. We coupled this with a new human consumption model that uses data from national statistical offices and the Food and Agriculture Organization of the United Nations to simulate food demand and dietary choices at global (and further disaggregated) scales.

We ran four scenarios: a “business as usual” reference case in which we assume no government interventions are made into the current market; a plant-based diet scenario, with an emphasis on whole grains; a meat-based diet scenario that relies heavily upon chicken and pork; and a hybrid vegetarian diet.

Differences between these scenarios were most significant in regions where meats play an important role in the human diet – such as Asia, Oceania and Central and South America. Our results suggest that we could produce enough food to meet demands under all of our scenarios; this is true both globally and within individual countries.

But while it may be technically possible to feed everyone by 2050, the costs associated with doing so will vary substantially according to what kind of diet we adopt – as well as how food is distributed locally and regionally. For instance, wealthier consumers in richer countries are likely to eat more meat than their counterparts further down the economic ladder.

In our plant-based diet scenario, global agricultural gross margins (accounting for differences between crops) increased by up to 12%, while total food availability fell slightly relative to reference case levels. By contrast, in scenarios where more livestranimal products were consumed globally, we found that farmers would need additional support from their governments and the private sector (such as subsidies).

This is because reallocating crops used for animal feed into crops fit for human consumption improves gross margins. We also found that a plant-based diet scenario resulted in less agricultural greenhouse gas emissions, land use expansion requirements and water demands while significantly increasing water productivity.

Our study is one of the first to integrate global food demand simulations with models accounting for both environmental impacts and social consequences (such as employment) within a single framework at multiple levels of detail. It can be used by researchers, policymakers and other stakeholders in order to evaluate future production pathways – and inform policy decisions – taking into account trade-offs between competing goals such as environmental quality versus agricultural profitability or global food security vs employment outcomes within a region.

In the future, we would like to incorporate more data about soil conditions and biodiversity in order to further evaluate different production strategies that aim to reconcile social, economic and environmental factors. But ultimately there is no “silver bullet” when it comes to feeding the world’s population while safeguarding our natural resources – so we must seek a balance between competing priorities by being smart about how we use our limited farmland for food production.

Authors: Kahsay Abebayehu, Doctoral Candidate in Civil and Environmental Engineering, Stanford University; Markus Stoianovici, Research Assistant Professor in Earth System Science, Stanford