12/10/2023 0 Comments Limbo fgoThe former can be useful for cleansing his NP seal at the worst possible time and def debuff,protection with the invul and cooldown reduction which can also be useful for mash to make sure that you can survive 2 NP turns without anyone dying(which should be enough time to beat him). Your best option for the mystic code for this fight is either the atlas MC or combat MC. Meanwhile brave eli has no supportive party support that isn't reliant on RNG,but having an invul is useful in case of an NP turn without taunt+invul with mash. Caesar can also be used for buffing both his and musashi's damage and while bedivere has only a tactics skill for damage which Caesar also has,he can also charge his NP faster with his battery and his 1 turn def buff is good enough that with mash's def buffs there is a chance to tank an NP turn without taunt+invul. Aside from the support musashi,Caesar,bedivere and brave Liz are good free DPS options. Mash also has invul+taunt which makes you able to reliably tank Lancer Purgatorio's attacks after his NP without 1 or 2 servants dying and messing up your entire plan before wiping his buffs away with buff removal. ![]() Mash's def buffs can be really useful against him because without crits his damage is nothing too bad and it takes him 1 or 2 turns for him to start dealing a lot of damage. Also her NPs buff removal is amazing because after Lancer Purgatorio NP he can easily crit your frontline to a universe where we have a saber kojirou alt. This is one of the few fights where the forced musashi support is actually useful and can do good damage against him (She can break one of the bars with an NPBB brave chain with crits and a few other servants' buffs). NP seal for 1 turn and defence down for 3 turns. Quick buff for 1 turn and mental debuff resistance for 3 turns. Sure hit for 3 turns and crit chance up for 3 turns. ![]() He has a permanent buff that gives him crit chance up for 2 turns with every normal attack and after his 1st break bar he gets a 5K HP heal every turn. Mash is best kouhai a great servant for the entirety of this singularity and pretty much every other one that doesn't force her to ||wear a VR headset and have way worse skills 9 times out of 10|| so she will be good for all of the fights and I'm just putting this here so I don't need to put her in the recommended servants part for pretty much all of the fights.īut without further ado,let's start this guide. Some fights in Shimosa are solos and,aside from the last fight,I will ignore these fights. ![]() Musashi is a forced support servant for all but one of the fights and in those fights she will be forced to be one of your frontline servants at the start.īefore the fight against caster Limbo,musashi lacks her 3rd skill. I will use 1-3* servants and welfares+best eggplant(AKA mash) for this guide. This guide will only be for the bosses and nothing else for shimosa like farming or getting the most out of your bond boost for sabers,archers and lancers(though for the fights you can pretty much ignore the bond bonuses and focus on actually being able to beat them). So to save at least some person's pain from this upcoming singularity,I am going to make this guide for all of the main bosses. ![]() So with Nero fest and Shimosa coming up around the corner I decided to make a guide for Shimosa because people have made enough Nero fest guides for both farming and the CQs and because Shimosa can simply be described as Camelot if you had to deal with even more difficult bosses and no ways to cheese it with supports(oh yeah,by the time you finish Shimosa there is a good chance you may start hating Musashi from being forced support). Lore Sunday for any and all lore discussions.Įrror message compilation with translation Who Would Win Wednesday for all power level discussion and what-if scenarios.įriend Request Hub for all friend requests.įree-Talk Friday for chatting about anything. >!Spoiler!< for spoiler tagging text: SpoilerĪchievement Monday for all achievements, including bond CE.
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12/10/2023 0 Comments Are bears nocturnal![]() In Alaska, some brown bears pluck swarming salmon from the water or catch them right out of the air as the school jumps. Grizzly and black bears, in another part of the world, eat mostly vegetation, insects, berries, and meat from caribou, young moose, and deer. Some like polar bears eat mostly the fat and meat of other creatures like seals and other marine mammals. However, the thing is, bears don’t eat honey alone. ![]() Since most bees are diurnal, brown and black bears would have to stay awake in the day to get their prize. In fact, in some parts of the world, some bears will go right through electric fences and endure the shock as long as they can get a taste of real honey. Both of which are good sources of protein that brown and black bears can go to any length to acquire. In fact, bears also consume the bees and larvae inside the beehive. But unlike in Winnie the Pooh, the bears eat more than just honey. So, they are automatically attracted to beehives. READ MORE: Which Bear Is The Most Dangerous? #2: What do bears eat? And like people say, do bears eat honey? But a good number of other species still roam the earth, both day and night. Six species, including both the polar bear and the giant panda, are rated as threatened or vulnerable on the IUCN Red List. On average, most bears can live up to about 25 years in the wild and 50 while in captivity. In the Americas, we have the North American black bears, polar bears, sloth bears, spectacled bears (aka the Andean bears), and sun bears. We have the Asiatic black bears (aka, the moon bears), the brown bears (which include our dear old fearsome friends, the grizzly bears), and the giant pandas. Now, according to verified statistics, there are currently 8 species of bears. These adaptations are peculiar to each species of bears. Because of the different environmental demands, food availability, and distribution, bears are forced to adapt in different ways. ![]() But as earlier said, the earth is home to different species of bears. You see, the issue of whether bears are diurnal or nocturnal shouldn’t have been a confusing matter at all. But here today, this write-up will try to keep the lines clear using different question tags. Oftentimes, this may require these creatures to adapt to different conditions and different times of the day. Now, each region demands different tactics from each species of bear. And that’s because there are different kinds of bears in different parts of the world eating different foods and displaying different habits. Well, the answer to that question might be a bit obscure. Now, to the big question Are bears active during the day (diurnal) or at night(nocturnal)? 12/10/2023 0 Comments Traktor pro beatport(The cost of a digital track at Beatport averages $1.29). By offering high-quality downloads for use in live sets, that functionality is still driving sales in a music market dominated by streaming. If you are an EEA or UK consumer the laws and courts of your country of residence will apply to any disputes arising out of or relating to these terms or the services.'Five Nights at Freddy's': How to Watch the Video Game-Turned-Movie Adaptation OnlineĪ key to Beatport’s growth is its focus specifically on DJs. If you are a non-EEA or UK consumer these terms shall be governed by Japanese law and all disputes shall be submitted to the exclusive jurisdiction of the Tokyo District Court. ![]() Which laws apply to this contract and where you may bring legal proceedings: (2) All disputes arising between AlphaTheta Corporation and customers shall be submitted to the exclusive jurisdiction of the Tokyo District Court. (1) All disputes shall be governed by the Japanese Law. ![]() ![]() The following legal conditions shall be applied to disputes stemmed from purchase of the products. The latest information on the Application is available in the following page. The Latest Information on the Application In order to use rekordbox, customers must implement registration in the Pioneer DJ account. Customers acknowledge that any paid fee for the subscription will not be refunded.įor aftercare services, please contact us via an inquiry form. In the case referred to in the preceding paragraph, even when cancellation of the agreements has been completed, all customer’s liabilities during the subscription terms will not be extinguished until such obligations have been fulfilled. In the case of AlphaTheta confirming the cancellation during the subscription terms, the agreement will end at the expiration date of such terms.ģ. Subscription agreement will be automatically renewed for another period of one month (“Expiration date of automatically renewed agreements”), unless particular cancellation in writing is made by customers. Subscription agreement allows customers to use contents of the software, for one month (“Expiration date of the first agreement”) from the day on which the purchase has been completed by the customers who have a good understanding of the contents written on this site.Ģ. For more details, refer to the General Terms and Conditions listed on the purchase screen.”ġ. To the maximum extent permitted by applicable law, due to the nature of the products,Īll sales are final and returns are not accepted. Delivery is completed when the completing payment. Payment will be completed by the transaction system of our agency, Digital River Inc.Īfter completing payment, the Application which you bought will be activated. Customers will be charged based on a cut-off date designated by a credit-card company or a clearing company. Payment shall be made by a credit card or through the PayPal system. ![]() To use the full functionality of the Application it requires access to the internet.ĭepends on each rekordbox plan, application can be installed into some computers per license as following list : rekordbox plan Internet communication fee may be applied, whilst operating Application. ・Internet communication fee for downloading software and registration *All internet communication charges must be paid by the customer. consumption tax, VAT) *Total purchase fee including taxes will be shown in the order entry process. Prices with each currency will be shown in the order entry process. Sales prices are listed in the product page. *For details, please refer to the product page.įor system requirements, please refer to the following page. ・Application for music management and DJ players (for Windows/Mac), and its extensions UK: Notation based on the Consumer Contracts Regulationsīy purchasing paid subscription plan for rekordbox you agree to the following terms and conditions.Ĥ-4-5 Minatomirai, Nishi-ku, Yokohama, Kanagawa 220-0012 Japanįor inquiries, please use the following inquiry form. USA: Notation based on the Uniform Electronic Transaction Act, etc. Japan: Notation based on the Specified Commercial Transaction Act 12/10/2023 0 Comments Moment by moment musical![]() Rachmaninoff might disagree if he could be here, but I feel quite strongly about it. Without the repeat, the piece is more compact and has more impact. So to me, the repeat is, well, too repetitive. The piece moves along at a leisurely pace, and those sigh motifs become well ingrained in the listener's brain after awhile. This morning I was thinking: In this rendition of the "Moment", I didn't do the repeat because I never liked it. But in any recording, the pianist is the key ingredient for better or worse. There are variables, of course, in any recording-the piano, the mics, the recorder, room acoustics, and even sometimes extraneous noises. Thanks so much for your comments! I appreciate that. Believe it or not, this recording was made on a small Sony cassette tape stereo "boom box" recorder! This "Moment Musical" was my first recording since my senior recital in 1963, without much piano playing in between. I also recall at that time being influenced by the recording made by Ruth Laredo. ![]() with old names like that and you having been only 3 in 1984, I'm feeling a bit ancient here! But my playing you hear in this instance, given the style of the piece, comes down from Matthay for sure. (She also studied at the conservatory with Miklos Schwalb, a student of Ernst von Dohnanyi and David Barnett, a student of Howard Brockway and Alfred Cortot.) My second teacher (later in life) studied with Anthony di Bonaventura, a pupil of Isabelle Vengerova. From the time I was very young, I definitely got a full training in that! And I apply it to this day, even though over the years Matthay's stock has slipped a bit among current pedagogues. He was a student of Tobias Matthay, who developed the approach of using relaxed arm weight in producing a rich tone. One of my first teacher's teachers was Albion Metcalf at the New England Conservatory of Music in Boston. ![]() The cast album for his song cycle, Moment By Moment, is available for purchase on iTunes and Amazon.OK, you're forcing me to give up my secrets. His theatrical rock band, Discount Ghost Stories! can be seen playing through every borough and the astral plains. His music has been heard at Lincoln Center, Goodspeed Opera House, Symphony Space, 54 Below, Joe’s Pub, Playwrights Horizons, The Signature Theatre, New World Stages, The Laurie Beechman Theatre and venues in Thailand, London, The Netherlands and all across the world. Additionally, he was a 2017 Jonathan Larson Grant Finalist. He was named one of Playbill’s “Contemporary Musical Theatre Writers You Should Know,” and he was selected for the 2014 Johnny Mercer Songwriter’s Project. He and collaborator James Presson were awarded the 2013-2014 Dramatist Guild Fellowship and their musical, Outlaws, was the recipient of the 2014 ASCAP Workshop. Production at Mahidol University, Bangkok, Thailand). Noah Himmelstein), Archie's Final Project (Book by James Presson and David Lee Miller), Diva (Theatre for the New City, 2017, book by Sean Patrick Monahan, directed by Daniel Goldstein), A Night Like This (book, music, lyrics, directed by Blayze Teicher, 54 Below) and Moment By Moment (directed by Brandon Ivie, 54 Below. His musicals include Outlaws (Goodspeed Festival of New Musicals- book by James Presson, dir. Alexander Sage Oyen is the recipient of the 2014 ASCAP Foundation’s Lucille and Jack Yellen award for lyricists and the Lotos Foundation Prize in Arts and Sciences for his lyrics. 12/10/2023 0 Comments Icarly new seasonSo, just in case anyone associated with the show is reading this review. A former teen internet sensation and her friends navigate the challenges of adulthood. iCarly - Season 5 - TV Series Nick Shows Nick Helps Pluto TV Games Privacy In 5,4,3,2. Some stories and angles from the original iCarly are expanded and explained while creating new paths forward. In October 2023, the series was cancelled after three seasons. More adult-ish story lines and dialogue are in place with just enough comedy to be reminiscent of the original without pegging the "Corny" meter all the time. The second season premiered on April 8, 2022, while the third season premiered on June 1, 2023. Is Creddie finally happening There's only one way to find out. You are brought back into this world that, even though SOME things have changed and people have aged, it really feels familiar and a superb job was done of welcoming all us, now adults, back to the iCarly we remember from when we were younger. The iCarly revival premiered on Paramount+ on June 12, 2021, to public and critical acclaim and was renewed for a second season in July 2021. The epic new season of iCarly streams June 1 exclusively on Paramount+.Catch up on the Paramo. ![]() Personally, I think the whole team behind the iCarly reboot nailed it and I put it in the same category as Fuller House. The iCarly Reboot Season 4 release date is likely to arrive in 2024. The series has now been revived on Paramount+ in. The show follows the life of Carly Shay, a teenager who creates her own web show known as iCarly with her best friends, Sam Puckett and Freddie Benson. I came here after watching the Zoey 102 movie which was a revisit of the classic Nickelodeon show Zoey 101 and during THAT review I couldn't help wishing that the producers, directors, and writers for Zoey 102 would have taken or asked for some advice from the iCarly team. 6.7 (5,823) iCarly is a comedic television series that originally aired from 2007 to 2012 on Nickelodeon. and I still do now that we are in its third season. ![]() Fix up some spaghetti tacos to watch the iCarly reboot online, with episode 4 streaming on Paramount Plus starting. I reviewed the first season of the iCarly reboot and gave it a glowing review. iCarly episode 4 streams Thursday, June 24 at 3 a.m. 12/10/2023 0 Comments Simple line animation after effectsThe effect works by animating the stroke-dashoffset and we can use a super cool trick to “normalize” the path length so that we don’t have to bother with the real length that we would need to do the SVG line animation. ![]() Check out these top alternatives for beginners and download the best one: 1.PowerDirector 2.Blackmagic Fusion 3.Blender 4.HitFilm 5.Wax. Use our familiar design and animation tools with our ground-breaking State Machine to create interactive motion graphics for your products, apps, sites. ![]() Most effects use a pseudo-element as line and some have a little SVG line animation, like this one: Best Adobe After Effects Alternatives: Adobe After Effects is the industry standard for VFX but it has a steep learning curve. Today I’d love to share some super-simple ideas that are based on CSS only, no JavaScript involved. Learn how to create a simple and colorful 3D scene in After Effects with with text and shape layers, and animate them dynamically. After Effects is getting popular as the industry of Computer Graphics and Digital Motion is growing. Those little line animations are a perfect way to enhance a design and add subtle micro-interactions to a website. Use After Effects to animate a line to draw an illustration before the viewer’s eyes. This post presents a round-up of Adobe After Effects Tutorials for your visual effects and motion graphics-related work. This rule defines the animation’s keyframes, specifying how the element’s style should change over time.From our sponsor: Castmagic is the fastest way to turn audio into any content asset.The basic syntax for creating CSS animations consists of three main components: CSS animations are defined using CSS keyframes and properties, and are triggered by various events, such as page load or user interactions. They’re used to create motion, transitions, and various visual effects on web elements, such as text, images, and backgrounds. What are CSS animations?ĬSS animations are a set of rules and properties that enable the gradual change of an element’s style over a specified duration. In this article, we’ll delve into CSS animations, discussing what they are, how they work, and why they are often preferred over JavaScript animations. CSS animations allow web developers to create smooth transitions, eye-catching effects, and interactive elements, all without the need for complex JavaScript code. 12/10/2023 0 Comments Vmware windows m1Virtzilla has been quiet about when or if that might debut. The Register understands that the work that went into Fusion on Apple Silicon overlapped with VMware's efforts to create a version of its ESXi hypervisor for Arm-powered datacenter hardware. Workstation has also added support for Windows Server 2022, Ubuntu 22.04, 20.04 and 22.10, Debian 11.5 and 12, Fedora 37 and 36, RHEL 9, plus FreeBSD 12, 13. VMware Fusion 13 on Apple Silicon running Windows 11 on Arm inside macOS – Click to enlarge With certified and signed drivers Windows 11 looks fantastic, and adjust the resolution to 4K and beyond!" ![]() In this release VMware Tools provides virtual graphics and networking, and more is still to come. "On Apple Silicon, we've introduced our first round of features for Windows 11 on Arm. "On Intel Macs you’ll notice full support for Windows 11 with VMware Tools allowing for host-guest interactions like Drag & Drop, or Copy & Paste, as well as shared folders and USB and Camera device passthrough," Roy wrote. VMware wants to help fund your next cloud migrationįusion on Apple Silicon is a little behind its cousin for Intel Macs.WTF is Sovereign SaaS? VMware's way to satisfy pesky regulators your cloud is local.VMware warns of three critical holes in remote-control tool.Broadcom looks for EU approval of VMware takeover. ![]() While Windows for Arm is available to download, Microsoft does not license it to individuals. On Apple Silicon, Fusion is of course restricted to running guest OSes written for Arm. The network will be found (you will know because Windows won't ask you about a network and will instead say "Checking for Updates".VM Player – which can only play VMs rather than allow their creation, and is often deployed as a client to run software appliances – can also run the virtual TPM. The VM will reboot and Windows will restart the setup process. When the installation finished, type the following command in the PowerShell prompt: shutdown /r /t 0 The VM's screen may blank momentarily while this happens. The vmxnet3 network driver and the VMware SVGA video drivers will be installed. Once in Powershell, type the following d: The purpose of this command is to switch from the cmd.exe to PowerShell. Wait a few seconds for the D drive to attach, and issue the following commands in the command line prompt: powershell The ISO will be available in the VM as the D drive. use the Fusion menu to attach the VMware Tools ISO to the VM Virtual Machine > ReInstall VMware Tools. vmdk can now be used to create a Custom VM".Īt the first screen, instead of answering the question about the country, type shift-fn-F10 to bring up a Command prompt.Īt this point. I created a new virtual machine according to the steps in the Tech Preview Testing Guide, page 22, starting the steps after "This. I downloaded that same VM and converted it to vmdk using: qemu-img convert -p -O vmdk Windows11_InsiderPreview_Client_ARM64_en-us_25158.VHDX Windows11_InsiderPreview_Client_ARM64_en-us_25158.vmdk I have no idea what may have been done to it. ![]() If you find a problem running on Ventura I suggest you try it on Monterey to see if it exists there.Īs a matter of security, I do not trust any OS installer obtained from sources other than the manufacturer/distributor/author. You are asking for trouble - it's unlikely that even VMware had the chance to do any testing with it on Ventura before releasing it to us. My preference would be NOT to run this Fusion tech preview on pre-releases of Ventura. The utilities that uses to build the ISO on Linux are typically found in the repos of many Linux distributions. You can run the download/build from within a Linux VM. If you can't install homebrew on Ventura, you can't easily get the open source apps needed by the scripts. They use open source applications which is why homebrew is needed to install them. The converters on macOS do not use Windows apps. It would not be surprising that homebrew does not yet support an pre-release, beta version of macOS. 12/10/2023 0 Comments Visual studio community 2022 linux![]() I've got Visual Studio Community, which is free for small groups and open source.Setting up Visual Studio 2017 to compile and debug C++ apps on Linux I wanted to write a Linux Console app in C++ using Visual Studio in Windows. This means the command-line utilities are the same as those that run within a native Ubuntu environment. And of course, you apt-get your way to glory.īash on Windows runs Ubuntu user-mode binaries provided by Canonical. Bash on Windows is for developers, not background server apps. You can also now run sshd, MySQL, Apache, lighttpd as long as you know that when you close your last console the background services will shut down. You can run vim, emacs, tmux, and run Javascript/node.js, Ruby, Python, C/C++, C# & F#, Rust, Go, and more. WSL has, frankly, kept me running Windows because I can run cmd, powershell, OR bash (or zsh or Fish). This subsystem is designed to support Linux. The Ubuntu install runs on a Windows subsystem. The bash shell runs on an install of Ubuntuģ. Here's a simple explanation from Andrew Pardoe:Ģ. It does WAY more than you'd think, and it's FASTer than a VM.) Design it - "So it's a docker container? A VM?" (Again, it's a whole subsystem.Minimize it - "Oh, it's just Cygwin." (It's actually not, it's the actual Ubuntu elf binaries running on a layer that abstracts the Linux kernel.).Response to this Windows feature has been a little funny because folks try to: I've blogged about the " Windows Subsystem for Linux" (also known as " Bash on Ubuntu on Windows") many times before. 12/9/2023 0 Comments 2018 malibu redline edition white![]() Certainly, any 2021 Malibu features a good looking inside, and that we just like the infotainment anatomy's blend of major symbols coupled with actual physical buttons together with switches. Interior DesignĬhevrolet developers have performed a great of producing your Malibu because appealing inside of since it is out and about. Malibu tire dimensions vary from 16 " entirely approximately 19. Whilst related up-dates are already created to the particular Cruze not to mention Spark just for 2019, all the distributed design DNA the good news is fails to cause modest, medium sized and enormous models of the identical vehicle. It’s obviously a smaller engine and quieter which probably makes it even more unnoticeable.2021 Chevrolet Malibu Redesign Exterior DesignĬhevrolet offers current typically the Malibu to get 2021 having an delicately shaped completely new grille, along with incorporated front lights along with two-element taillights. We have the auto stop/start in a ’15 Malibu and we hardly notice it anymore. We have to opt against that one in the snow belt. Is yours a FWD or AWD? Were there any miles on it? The AWD’s sticker at $50K so the BEST I am seeing is around $5K off the sticker for $45K + tax, if they have one on the lot. I have not seen that anywhere even with a national search on one of the popular auto sites. In AUTO mode or 4x4 you can knock off another 2-3 MPG’s off when it’s snowing – which is all the time. hauler any more that gets 15 MPG in town on a good day. This vehicle will replace a black Suburban that I have owned for eight years. We looked at the Acura MDX but it’s a bit smaller and at $57K for a 2017 with no deals it was easy to walk away. The silver with an all blacked-out trim looks pretty good as well! I have one on order at a local dealer as there are none around western NY. The blackout package on an all black vehicle is stunning (looked like my old Buick Grand Nationals from days past)! This one will be a daily driver instead of a garage queen so I opted for the silver given our long rough winters. Chevrolet hit a home run with the new Redline edition even if you can only get it on the Premier version. New to the site here also.and agree 100%. ![]() Thanks for letting me join! I love the Equinox forum! I will discuss with hubby about the ways to switch that through the thread I found on here. The only drawback I have so far is the auto stop/start and having to get used to that. Cargo space wasn't a huge issue for us, though if you have seen the new Acadia, you can LOL at that cargo space, or lack thereof. We tested all the SUVs out with the tallest in the third row (we mandated the SUV have captain's seats in the second row so there is more leg room for the third row for long trips). We needed something that can haul three tall boys and hubby: 6'1" - 6'4". We ended up paying cash, and bought this for under $43K, which is about the same price as the 2017 Explorer Platinum was with 6K miles on it. Holy moly! I saw a white one first and was eh, but once I saw the black one, I was done. ![]() So I tell him it's his fault that I walked into that showroom and fell in love with the black Premier Redline edition. But he wanted me to look at Traverses, too, just to be certain. He's had a few Mustangs, and I have owned 3 Explorers in my life and loved them, especially my Eddie Bauer. Hubby liked the Explorer - the twin turbo 365, specifically. It did have more leg/head room in the 3rd row than the Explorer did, but that was the only thing it had going for it. I really thought I'd like the Denali (knew someone that had a 2014 Acadia), but they have changed them - shorter, not as tall - and didn't like it at all. Looked around at a 2017 Explorer Platinum (a demo at the dealer's and it was white which wasn't my first choice) and a 2018 Acadia Denali. Just saying hi! Upgraded my Chevy Equinox to a Traverse. 12/9/2023 0 Comments Wire fraud definition![]() ![]() Initial Example of Honest Services Fraudįor all the clarity Skilling provided, the case left a number of questions unanswered. Skilling stated the modern elements of the crime, requiring that a person receive a bribe or kickback as a quid pro quo for taking or refraining from taking improper action in a professional, elected, or other position of trust with respect to another. Īfter years of ambiguity and differing requirements in the statute’s application, the Supreme Court eventually provided some defining parameters in U.S. In a dissenting opinion, Justice Antonin Scalia stated that it could logically extend to a salaried employee’s dishonesty in calling out sick to attend a baseball game. This broad wording would appear to criminalize an overly-broad, wide range of conduct with no limiting principle. Criminal Code defines the crime of honest services fraud as “a scheme or artifice to deprive another of the intangible right of honest services.” “Brilliant lawyers with courtroom savvy” – Benchmark Litigation. To learn more about corporate and executive criminal liability, follow us on LinkedIn. ![]() And wire fraud was among the charges initially levied against Bernie Madoff arising from his billion-dollar Ponzi scheme. For example, former Virginia Governor Bob McDonnell – whose conviction was later overturned by the Supreme Court – was charged with wire fraud related to payments and gifts that he had accepted from a local businessman. Wire fraud is a particularly common charge in cases involving public corruption and financial crimes. Wire fraud is a favorite of prosecutors and has been charged with increasing frequency given the ubiquity of wire communications in modern American life. So, to violate the wire fraud statute, a wire transmission must have crossed a state line. A wire fraud prosecution, however, requires an interstate wire transmission because the Commerce Clause gives Congress the authority to regulate only interstate commerce. Because of its roots in the Postal Clause, the mail fraud statute can reach any use of the mails – even a mailing that occurs entirely within a single state. The wire fraud statute, on the other hand, is an exercise of Congress’s authority under the Commerce Clause. The mail fraud statute is a product of Congress’s power to establish post offices and post roads under the Postal Clause. The differing jurisdictional hooks are a reflection of the different sources of constitutional authority that allowed Congress to enact the mail and wire fraud statutes. In contrast, the wire fraud statute requires the use of an interstate wire transmission such as an email, a fax, a phone call, a text message, or the use of an internet chat room. Postal Service or any private or commercial interstate carrier (like FedEx or UPS) to further the commission of the fraud. Under the mail fraud statute, the defendant must use the U.S. The main difference between mail and wire fraud is the “jurisdictional hook” that allows the Department of Justice to prosecute this conduct as a federal crime. In other words, the defendant must have deployed a means of deception or deceit – for example, false statements, misrepresentations, or concealment – to deprive the victim of money or property. Both mail and wire fraud require a scheme to defraud the victim of money or property. Mail fraud and wire fraud are two of the most common crimes charged by federal prosecutors. |
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