In-court identification Essay Example for Free

In-court identification Essay In a criminal prosecution, the positive identification of the accused would most likely result in conviction. The likelihood that the defense would contest or suppress in-court identification by prosecution witnesses is therefore high. Over the years, our courts have formulated rules regarding the propriety of suppressing in-court identification by witnesses. The accuracy of eyewitness identification depends on factors personal to the witness such as: (1) perception; (2) memory; (3) communication; and (4) candor. (Moses, 2001) However, the suppression of in-court identification testimony largely depends upon the admissibility of the out-of-court identification, which preceded it. Such admissibility can be challenged principally on two grounds: first, that it violated the right to counsel of the accused under the Sixth Amendment or, second, that it violated due process. For purposes of this paper, the former will not be discussed since what is involved in the issue at hand is a photographic identification and therefore the accused cannot invoke his right to counsel, be it pre-indictment or post-indictment, since there is no adversarial confrontation involved. (United States vs. Ash, 1973) The case most applicable is Manson vs. Brathwaite, 432 U. S. 98 (1977). The facts of the case are: Glover, a trained undercover state police officer purchased heroin from a seller through the open doorway of an apartment while standing for two or three minutes within two feet of the seller in a hallway illuminated by natural light. A few minutes later Glover described the seller to another police officer as being a colored man, approximately five feet eleven inches tall, dark complexion, black hair, short Afro style, and having high cheekbones, and of heavy build. The other police officer, suspecting from the description that respondent might be the seller, left a police photograph of respondent at the office of Glover, who viewed it two days later and identified it as the picture of the seller. (Manson vs. Brathwaite, 1977) The court identified two issues. First, whether the police used an impermissibly suggestive procedure in obtaining the out-of-court identification. Second, whether, under all the circumstances, that suggestive procedure gave rise to a substantial likelihood of â€Å"irreparable misidentification. † (Manson vs. Brathwaite, 1977) As to the first inquiry, the court held that the photographic identification was â€Å"impermissibly suggestive† and â€Å"unnecessarily so. † (Manson vs. Brathwaite, 1977) However, the court ultimately ruled in favor of the admissibility of the photographic identification and did not take a per se exclusion route as what happened in the case of Stovall vs.Deno, 388 U. S. 293 (1967), which declared that the evidence of an out-of-court identification is inadmissible if the evidence revealed that the out-of-court confrontation was so unnecessarily suggestive and conducive to irreparable mistaken identification that he was denied due process of law. The court declared that â€Å"reliability is the linchpin in determining the admissibility of identification testimony† (Manson vs. Brathwaite, 1977) The Court relied upon several factors, the â€Å"Biggers factors† (George, 2005, p. 9), that provide the basis in determining whether the witness had a picture of the perpetrator in his or her mind before the police suggestiveness occurred: 1) the amount of time or opportunity to view the suspect during the crime; 2) the witness’s degree of attention while viewing the suspect (casual observer or victim); 3) the accuracy of the description given prior to the identification procedure; 4) the witness’ level of certainty; and 5) the time between the offense and the identification. (Neil vs. Biggers, 1972) In the issue at hand before us, it must be determined: first, whether or not the photographic identification procedure was â€Å"impermissibly suggestive† and â€Å"unnecessarily so†; second, whether or not the â€Å"totality of the circumstances† (Manson vs. Brathwaite, 1977) would show that the identification made was indeed reliable. First, it is submitted that the out-of-court identification by the tellers are impermissibly suggestive and unnecessarily so. According to the cases of Manson v. Brathwaite, 432 U. S. 98 (1977) and Mason v. United States, 414 F. 2d 1176 (D. C. Cir.1969), showing a single photograph is highly suggestive and the suggestivity is unnecessary unless there are compelling circumstances which would show otherwise. The act of the police officer in showing to one of the tellers the photograph of the defendant is considered unnecessarily suggestive as laid down by jurisprudence. The inquiry therefore which needs to be addressed is, whether or not the out-of-court identification by the tellers is reliable, regardless of the impermissible and unnecessary suggestive procedure conducted by the police officer a few day after their statements were noted. It is submitted that the out-of-court identification by the tellers are not reliable for the following reasons. First, there are no facts which suggest the amount of time or opportunity the tellers had in viewing the suspect during the commission of the robbery nor the witnesses’ degree of attention while viewing the suspect. Second, the level of certainty of the tellers as to the identity of the accused is highly contentious. That one of the tellers called up the police station and identified the defendant as the robber is not reliable because of the fact that she had seen a report on television the previous night regarding the arrest of the defendant. Such circumstance can be regarded as â€Å"suggestive. † Her â€Å"belief† that the arrested person is the robber is not a sufficient indicia of reliability and certainty on the part of the witness. Also, the identification by the other teller of the defendant as the robber by pointing to a picture of him in a newspaper article about the arrest is suggestive and highly suspect for the same reason. Moreover, the police officer conducting the investigation could have tested the assertions of the witnesses by conducting a line-up or photographic array identification subsequent to the taking of statements. But he did not. It is therefore concluded that the in-court identification by the witnesses should be suppressed for being made under impermissible and unnecessary suggestive procedure and for being unreliable considering the totality of all circumstances. WORKS CITED: George, A. (March, 2005). â€Å"That’s the man who did it! † Identification Evidence Under the 5th and 6th Amendments. † Retrieved November 2, 2006, from http://www.fd. org/pdf_lib/Due%20Process%20Under%205th%20Amendment. pdf Moses, R. (2001). Misidentification: The Caprices of Eyewitness Testimony in Criminal Cases. Retrieved November 2, 2006, from http://www. criminaldefense. homestead. com/eyewitnessmisidentification. html Motions to Suppress Eyewitness Identification Testimony. Retrieved November 2, 2006, from http://www. pdsdc. org/Cpi/CH_21. pdf. LEGAL SOURCES: Manson vs. Brathwaite, 432 U. S. 98 (1977). Mason v. United States, 414 F. 2d 1176 (D. C. Cir. 1969). Neil vs. Biggers, 409 U. S. 188 (1972). Stovall vs. Deno, 388 U. S. 293 (1967). United States vs. Ash, 413 U. S. 300 (1973).

Medicine During the Civil War Essay -- essays research papers fc

Medicine During the Civil War 1861-1865   Ã‚  Ã‚  Ã‚  Ã‚  When Walt Whitman wrote that he believed the â€Å"real war† would never get into the books, this is the side he was talking about (Belferman 1996). Yet, it is important that we remember and recall the medical side of the conflict too, as horrible and terrifying as it was (Adams 1952). Long before doctors and people knew anything about bacteria and what caused disease was the time of Civil War medicine. Doctors during the Civil War (always referred to as â€Å"surgeons†) were incredibly unprepared. Most surgeons had as little as two years of medical school because very few pursued further education. At that time, Harvard Medical School did not even own a single stethoscope or microscope until well after the war. Most Civil War surgeons had never treated a gun shot wound because they were accustomed to treating minor head colds and sore throats. Many had never performed surgery or even held a scalpel. Medical boards let extremely unqualified students practice medicine due to much needed help for wounded soldiers on the battlefield. â€Å"Some ten thousand surgeons served in the Union and about four thousand served in the Southern Confederacy (Cunningham 1958).†   Ã‚  Ã‚  Ã‚  Ã‚  By far, the deadliest thing that faced the Civil War soldier was disease and infection. For every soldier who died in battle, two died of disease (Cunningham 1958). Among the long list of terminal and fatal diseases that plagued the battlefield as well as the operating table and hospitals were dysentery (a severe form of diarrhea which was very common among the soldiers), measles, small pox, malaria, pneumonia, and â€Å"camp itch† which was caused by skin disease and insects. Malaria was usually brought on by camping in damp areas, where mosquitos were prone to. There were many factors that came into play which explained why disease spread so rapidly. Among the explanations were as follows: inadequate physicals before entering the Army, the fact many troops came from rural areas, neglect of camp hygiene, insects and rodents in the area, exposure to other infected individuals, lack of clothing and shoes, and poor conditions of food and water. Many unqualifi ed recruits entered the Army and diseases cruelly weeded out those who should have been excluded by physical exams prior to recruiting (Shildt 1986).   Ã‚  &... .... The many men and women, North and South, who served in the hospital and sanitary services during the war were proud of their achievements (Adams 1861-1865). The morbidity and mortality rates of both armies showed marked improvement over those of other 19th century wars. The physicians and sanitarians held down the disease fatalities to levels that their generation considered more than reasonable. It was a gruesome business for doctors and patients alike; yet without the doctors and nurses in blue and gray, much of the young manhood of America at mid century might not have survived for the work of rebuilding. (Adams 1861-1865) Works Cited Adams, George W. Doctors In Blue,†Medical History of the Union† Baton Rouge:University of Louisiana Press, 1952 Belferman, Mary â€Å"On Surgery’s Cutting Edge in the Civil War† The Washington Post, June 13, 1996 Cunningham, H.H. Doctors in Gray, Baton Rouge: University of Louisiana Press, 1958 Coco, Gregory A. A Strange and Blighted Land-Gettysburg, The Aftermath, 1995 Schildt, John W. Hunter Homes McGuire:Doctor in Gray, 1986 Adams, George W. â€Å"Fighting for Time† The National Historical Society’s-The Image of War 1861-1865 Volume IV

Cbs Tells Sodastream to Revise Brand-Bashing Super Bowl Essay

Every year, the Super Bowl attracts some of the best and most high-priced advertising in the world. But it also lures a horde of publicity-seekers claiming their commercials have been censored or rejected by the host network. In nearly all cases, the complaining marketers never really had a shot at the Super Bowl, thanks to shoddy production values, truly objectionable content and, more often than not, the inability to pony up more than $3 million for an ad. And it’s a common occurrence for the network to ask event sponsors to tweak or edit the content for a variety of reasons (which also can yield a PR bonanza if a sponsor cries foul — just ask serial offender GoDaddy.com). But SodaStream, a mainstream advertiser that some time ago purchased a spot in the game’s fourth quarter, said this wasn’t a PR gambit. So what’s the issue? The content of its planned commercial seemed to have concerned CBS because it was a direct hit at two other Super Bowl spo nsors and heavy network TV advertisers: Coke and Pepsi SodaStream, which sells home soda-making machines, has already run afoul of authorities in the U.K. for a Bogusky-crafted spot indicating its product is more environmentally friendly than established sodas; the spot shows branded bottles and cans of soft drinks exploding into thin air. For the Super Bowl, it hoped to up the ante with a spot depicting truck drivers clad in clothing with Coca-Cola and Pepsi marks on them, according to Ilan Nacasch, SodaStream’s chief marketing officer. â€Å"We really tried to comply with the standards† set by CBS, he said. At the same time, he added, â€Å"We were taking it to a new level, and that’s the level where they apparently judged to be going too far.† Interestingly enough, Pepsi has scored big points with viewers over the years by showing Super Bowl ads with Coke deliverymen abandoning their employer wholesale for a sip of a Pepsi drink. Of course, Pepsi (and, for that matter, Coke) buys multiple ads in the Super Bowl each year, as well as spends millions of dollars on other broadcast-TV advertising. Another Super Bowl sponsor, Anheuser-Busch InBev with Pepsi this year for in-store displays and promotions. A CBS spokeswoman said network executives declined to comment. â€Å"Bummed,† Mr. Bogusky, famous for his work at CP&B still in the game with an older spot we tweaked.†

Lidls Marketing Strategy Example For Free - Free Essay Example

Sample details Pages: 8 Words: 2437 Downloads: 8 Date added: 2017/06/26 Category Marketing Essay Type Case study Did you like this example? Introduction Lidls history begins in the 1930s, when their first store was created in Germany acting as a grocery wholesaler. Since then, Lidl has now become one of the largest grocery retailers in Europe, with over 600 stores operating in the UK, and thousands based across Europe (Butler, 2014). Although the amount of stores that Lidl have in operation is staggering, it is made even more amazing by the fact they only expanded out of Germany 20 years ago (Lidl, 2015). Don’t waste time! Our writers will create an original "Lidls Marketing Strategy Example For Free" essay for you Create order This rapid expansion has made them one of the most dominant and feared competitors in the UK grocery market, with major grocery retailers constantly trying to minimise Lidls portion of market share. Although Lidls market share in the UK is still relatively small, with them acquiring 3.5% at the beginning of 2015, they are one of the fastest growing grocery retailers. Whilst many supermarkets are losing their market share, Lidls was increased by a stagger 15.1% from 3.1% to 3.5% (FT, 2015). Figure 1 highlights the variation in market share, and how much market share each supermarket currently holds. As previously mentioned, although Lidl have a relatively low market share, they are currently one of the fastest growing retailers in the market. An analysis of Lidls current marketing strategy will be conducted, with particular emphasis on the 7 Ps of marketing. Furthermore, Porters Generic Strategies will be analysed in order to aid in the understanding of Lidls current strateg ies. This will then be concluded with a SWOT analysis, with recommendations being drawn up via the utilisation of a TOWS matrix. Marketing Strategy Analysis The five core concepts of marketing are; consumer needs/wants/demands, products and services, value/satisfaction/quality, exchanges/transactions/relationships and markets (Kotler, et al., 2008). One of the most efficient ways to analyse these factors is to conduct a marketing strategy analysis, which looks to explore the strategies an organisation utilises in order to grow and expand their market share. 7 Ps Analysis In order to successfully analyse Lidl marketing strategy, a 7 Ps analysis can be conducted, which seeks to analyse some very basic, but significant issues. Originally, the 7 Ps was only comprised of 4 Ps which aimed to address certain issues that would allow a firm to have a more developed understanding of their internal operations. The 4Ps are comprised of; product, price, place and promotion (CIM, 2009). However, due to the limited applicability of the 4 Ps, three more were added to form the 7Ps, which aims to encompass some service qualities the 4 Ps do not cover (Booms Bitner, 1981; Lusch, et al., 2007). Product (Quality, brand name, service line, warranty, capabilities, facilitating goods, tangible clues, price, personnel, physical environment and process of service delivery): Very solid brand name from being one of the cheapest supermarket retailers in the industry. Their main competition as a value supermarket is Aldi (Bosshart, 2006). The products sold in Lidl are often very similar to the goods sold in other supermarkets, such as Tesco or Asda. However, the main distinction would be the different brand names of the products in Lidl stores. Consumers could have a negative perception of the quality of Lidls products as they are sold for such a cheap price (Siro, et al., 2008). Price (Level, discounts and allowances, payment terms, customers own perceived value, quality/price interaction and differentiation): One of the key competitive advantages for Lidl is their clever pricing strategies. Lidl entered the market on the basis of being one of the most value-driven supermarkets in the industry (Dolgui Proth, 2010). All payments are made up before leaving the store at the check outs. As they offer goods at an incredibly cheap price, consumers may believe that the goods they sell are poor quality, however this is generally not the case (Siro, et al., 2008). Place (Location, accessibility, distribution channels and distribution coverage): Lidl have a plethora of stores across the UK and Europe. However, depending on the country, they operate in different segments of the supermarket industry, ranging from value to high-end goods (Butler, 2014). They have a variety of distribution hubs across the UK and Europe to ensure that stores are maintaining a constant level of stock (Brown, 2015). As their business model is to sell as many goods as possible in the shortest amount of time, ensuring stock levels are maintained is incredibly important. This means that it is imperative to have stores in reasonably close proximity to national distribution centres. Promotion (Advertisements, personal selling, sales promotion, publicity, personnel, physical environment, facilitating goods, tangible clues and process of service delivery): Lidl do not current have any loyalty schemes present in the UK, as they believe their pricing model is enough to incentivise consumers. Lidl often have in store promotions, but they do not discount their goods as highly as other retailers due to the low prices that already exist. People (Personnel training, discretion, commitment, incentives, appearance, interpersonal behaviour, attitudes and customer behaviour/degree of involvement): Employees are generally paid a very attractive salary, but have to work incredibly hard whilst on the job. The amount of items scanned is often used as a performance measurement indicator (Ruddick, 2015). High training standards to ensure employees can scan items fast enough and meet all customer needs. Consumers may feel that staff do not pay them enough attention as they are very rushed doing their job responsibilities. Process (Policies, procedures, mechanisation, employee discretion, customer involvement, customer direction and flow of activities): Primary process of Lidl is to purchase and sell as many goods as possible on a low-cost basis. Consumers are not very involved in any of the processes or procedures of Lidl, and would have little power over their business operations. Physical (Environment, furnishings, colour, layout, noise level, facilitating goods and tangible clues): The majority of Lidl stores are laid out in a very linear and traditional manner. This is to aid consumers in finding their goods as soon as possible and having easy access to purchase and leave (Lidl, 2015). Lidl will often exhibit their brand colours, yellow and blue, throughout their stores or surrounding areas. This will help consumers know there is a Lidl nearby. Porters Generic Strategies Porter outlines four generic strategies; differentiation, cost leadership, differentiation focus and cost focus (Porter, 1980). From utilising the information gathered from the 7 Ps analysis, it becomes quickly apparent as to what strategy Lidl are currently pursuing. Lidl have a reliant focus on selling quality products at the cheapest cost possible. This would suggest that they are utilising a cost leadership strategy, and are implemented it with incredible effectiveness (Morschett, et al., 2006). However, in order to maintain their current rate of growth and expansion, Lidl may have to diversify from their current strategies in order to stay competitive and innovative within the UK grocery market. SWOT Analysis Based on the 7 Ps analysis, a SWOT analysis can be conducted in regards to Lidl. The SWOT analysis will help an organisation measure and understand the internal strengths and weaknesses, and the external opportunities and threats facing the firm. Being able to identify these elements will help an organisation to formulate and develop strategies which may build on the strengths, negate the weaknesses, exploit the opportunities or counter the threats (Dyson, 2004). Strengths (Simon, et al., 2010; Kumar Steenkamp, 2007): Strong business structure allows them to sell their products at an incredibly cheap price. Wide range of private labels gives them exclusivity and security. Has a huge amount of stores across the whole of the UK and Europe giving Lidl great exposure. Online presence that showcases the products they have and any deals they may be running. Weaknesses (FT, 2015; Siro, et al., 2008): Does not quite have the market share of the other big supermarkets in the UK, such as Tesco or Asda. Has not been able to spread their operations outside of Europe very successfully. As their products are so cheap consumers can often think that the quality is not good enough. Opportunities (Felsted, 2014): Potential to expand in the UK and acquire a higher share of the UK grocery market. Successfully expanding abroad can provide more funds to invest in the UK. Expand their website to actually accept orders and sell products. Threats (Poulter, 2014): If Lidl were to engage with a price war with other major grocery retailers then they could force competitors prices down. International expansion of other global brands would cause more competition. Aldi surpassing their market share and becoming the dominant discount grocery retailer. Recommendations Together with the SWOT analysis, a TOWS matrix can be utilised in order to develop strategies and recommendations for Lidl to acquire a greater market share of the UK grocery industry (Weihrich, 1982). Strengths Strong business structure allows them to sell their products at an incredibly cheap price. Wide range of private labels gives them exclusivity and security. Has a huge amount of stores across the whole of the UK and Europe giving Lidl great exposure. Online presence that showcases the products they have and any deals they may be running. Weaknesses Does not quite have the market share of the other big supermarkets in the UK, such as Tesco or Asda. Has not been able to spread their operations outside of Europe very successfully. As their products are so cheap consumers can often think that the quality is not good enough. Opportunities Potential to expand in the UK and acquire a higher share of the UK grocery market. Successfully expanding abroad can provide more funds to invest in the UK. Expand their website to actually accept orders and sell products. SO: Maxi-Maxi Funnel revenue back into the UK market by creating more stores across the UK. Introduction of new product ranges that cater to an upper-class demographic. Use strong online presence and staff training to expand their website with click collect or delivery services. WO: Mini-Maxi Cooperate with firms operating in the US or Asia to expand operations. Increased revenue could then be funnelled into UK development. Provide more information on their website about product details in order to enforce quality. Threats If Lidl were to engage with a price war with other major grocery retailers then they could force competitors prices down. International expansion of other global brands would cause more competition. Aldi surpassing their market share and becoming the dominant discount grocery retailer. ST: Maxi-Mini Lidls own range of private brands can be used to deter price wars and comparisons. Utilise the significant amount of exposure across the UK and Europe to construct barriers of entry for other low-cost grocery retailers. WT: Mini-Mini Avoid engaging in price wars and competitive with major grocery retailers on a direct basis. Utilise extensive network in of operations in other European countries to bring new products to the UK. Based on the TOWS matrix, and the analysis of Lidls current market strategies, three recommendations can be laid that would help Lidl acquire a greater share of the UK grocery market. The three recommendations are; Extend the usability of their website to accept click collect orders or even delivery. This would expand their presence in the UK market. Develop and implement upper-class branded products in order to target a new demographic and compete with the major supermarket retailers on a more even environment. Construct firm barriers of entry to deter other organisations from entering the UK grocery market and potentially encroaching on Lidls market share. In order to stay competitive in the UK grocery industry, and continue to build upon their UK market share, Lidl should utilise the aforementioned strategies. Furthermore, this could result in them following a combination of generic strategies, as the introducing of upper-class brands, in combination with their current business structure, would suggest a differentiation strategy is in place. However, if Lidl pursue the adoption of other strategies, they must ensure that their current consumer base is not alienated, or they could end up losing market share. Furthermore, Lidl should continue to open more stores in the UK in order to expand their presence and accessibility, which will allow their operations to have similar exposure to the other major supermarket retailers. Bibliography Booms, B. H. Bitner, M. J., 1981. Marketing strategies and organization structures for service firms. In: Marketing of Services. Chicago: American Marketing Association, pp. 47-51. Bosshart, D., 2006. Cheap?: The Real Cost of Living in a Low Price, Low Wage World. London: Kogan Page Limited. Brown, G., 2015. Giant Lidl distribution hub to create 500 West Midlands jobs. [Online] Available at: https://www.birminghampost.co.uk/business/business-news/giant-lidl-distribution-hub-create-8883111 Butler, S., 2014. https://www.theguardian.com/business/2014/jun/27/lidl-launches-store-expansion-programme. [Online] Available at: https://www.theguardian.com/business/2014/jun/27/lidl-launches-store-expansion-programme CIM, 2009. Marketing and the 7Ps, s.l.: Chartered Institute of Marketing. Dolgui, A. Proth, J. M., 2010. Pricing strategies and models. Annual Reviews in Control, 34(1), pp. 101-110. Dyson, R. G., 2004. Strategic development and SWOT analysis at the University o f Warwick. European Journal of Operational Research, Volume 152, pp. 631-640. Felsted, A., 2014. Lidl expansion to crank up pressure on big stores. [Online] Available at: https://www.ft.com/cms/s/0/2465c426-fd53-11e3-bc93-00144feab7de.html#axzz3giD80B9c FT, 2015. Half of UK shoppers visited Lidl, Aldi over Xmas. [Online] Available at: https://www.ft.com/fastft/260632/half-of-uk-shoppers-visited-lidl-aldi-over-xmas Kotler, P., Armstrong, G. Saunders, J., 2008. Principles of Marketing. 5th ed. s.l.:Prentice Hall. Kumar, N. Steenkamp, J. B. E. M., 2007. Private Label Strategy: How to Meet the Store Brand Challenge. Cambridge: Harvard Business Press. Lidl, 2015. Customer orientated expansion. [Online] Available at: https://property.lidl.co.uk/cps/rde/xchg/lidl_uk/hs.xsl/5187.htm Lidl, 2015. https://www.lidl.co.uk/en/659.htm. [Online] Available at: https://www.lidl.co.uk/en/659.htm Lusch, R. F., Vargo, S. L. OBrien, M., 2007. Competing through service: Insights fr om service-dominant logic. Journal of Retailing, 83(1), pp. 5-18. Morschett, D., Swoboda, B. Schramm-Klein, H., 2006. Porter outlines four generic strategies; differentiation, cost leadership, differentiation focus and cost focus (Porter, 1980).. Journal of Retailing and Consumer Services, 13(4), pp. 275-287. Porter, M. E., 1980. Competitive Strategy. s.l.:Free Press. Poulter, S., 2014. Aldi and Lidl to force big four supermarkets into price war to stop stampede of customers to discount chains. [Online] Available at: https://www.dailymail.co.uk/news/article-2539064/Aldi-Lidl-force-big-four-supermarkets-price-war-stop-stampede-customers-discount-chains.html Ruddick, G., 2015. Supermarkets could increase prices to pay for living wage. [Online] Available at: https://www.telegraph.co.uk/finance/newsbysector/retailandconsumer/11736662/Supermarkets-could-increase-prices-to-pay-for-living-wage.html Simon, H., Gathen, A. V. D. Daus, P. W., 2010. Retail Pricing Higher Profi ts Through Improved Pricing Processes. In: Retailing in the 21st Century. Berlin: Springer Berlin Heidelberg, pp. 319-336. Siro, I., Kapolna, E., Kapolna, B. Lugasi, A., 2008. Functional food. Product development, marketing and consumer acceptanceà ¢Ã¢â€š ¬Ã¢â‚¬ A review. Appetite, 51(3), pp. 456-467. Weihrich, H., 1982. The TOWS Matrix A Tool for Situational Analysis, San Francisco: Long Range Planning .