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X Corp. v. Center for Countering Digital Hate, INC. Court Filing, retrieved on March 25, 2024 is part of . You can jump to any part in this filing . This part is 8 of 19. HackerNoon’s Legal PDF Series here 2. “Arising from” In addition, X Corp.’s claims arise from protected conduct. To determine whether a claim or claims arise from protected activity, courts are to look to “the conduct that constitutes the specific act of wrongdoing challenged by the plaintiff.” Jordan-Benel v. Universal City Studios, Inc., 859 F.3d 1184, 1190 (9th Cir. 2017). “A defendant in an ordinary private dispute cannot take advantage of the antiSLAPP statute simply because the complaint contains some references to speech or petitioning activity by the defendant.” Sansoe v. Ford Motor Co., 668 Fed. Appx. 718, 719 (9th Cir. 2016) (quoting People ex rel. Fire Ins. Exch. v. Anapol, 211 Cal. App. 4th 809 (2012)). In addition, “the mere fact an action was filed after protected activity took place does not mean it arose from that activity.” City of Cotati v. Cashman, 29 Cal. 4th 69, 76– 77 (2002). In Jordan-Benel, the plaintiff was a screenwriter who alleged that defendant production companies’ failure to compensate and credit him for a script constituted a breach of contract. Id. at 1187, 1189. The defendants brought an anti-SLAPP motion, arguing that the contract claim arose from their free-speech activity of producing a film. Id. at 1190. The Ninth Circuit agreed with the plaintiff, concluding that the specific wrongful act that gave rise to the claim was the failure to pay. Id. The court explained that even if the cause of action was triggered by protected activity—the release of the film—that does not mean that the action arose from it: “even if a defendant engages in free speech activity that is relevant to a claim, that does not necessarily mean such activity is the basis for the claim.” Id.; see also Martinez v. Metabolife Internat., Inc., 113 Cal. App. 4th 181, 187 (2003) (“[W]hen the allegations referring to arguably protected activity are only incidental to a cause of action based essentially on nonprotected activity, collateral allusions to protected activity should not subject the cause of action to the anti-SLAPP statute.”). X Corp. argues that just as the production of the film was not the specific act that gave rise to the claim in Jordan-Benel, CCDH’s publication of its articles and reports is not the specific act of wrongdoing at issue here. See Opp’n at 10–11 (“CCDH’s alleged ‘speech’ is not the wrong complained of—its wanton breach of contract and illegal access of data are.”). But even accepting that the conduct that forms the specific wrongdoing in the state law claims is CCDH’s illegal access of X Corp. data, that conduct (scraping the X platform and accessing the Brandwatch data using ECF’s login credentials) is newsgathering—and claims based on newsgathering arise from protected activity. See Iloh, 94 Cal. App. 5th at 956–57. It is also just not true that the complaint is only about data collection. See Reply at 3 (arguing that X Corp.’s contention that its “claims arise from ‘illegal access of data,’ as opposed to speech,” is the “artifice” at “the foundation of [this] whole case.”) (quoting Opp’n at 10). It is impossible to read the complaint and not conclude that X Corp. is far more concerned about CCDH’s speech than it is its data collection methods. In its first breath, the complaint alleges that CCDH cherry-picks data in order to produce reports and articles as part of a “scare campaign” in which it falsely claims statistical support for the position that the X platform “is overwhelmed with harmful content” in order “to drive advertisers from the X platform.” See FAC ¶ 1. Of course, there can be no false claim without communication. Indeed, the complaint is littered with allegations emphasizing CCDH’s communicative use of the acquired data. See, e.g., id. ¶¶ 17–20 (reports/articles are based on “flawed ‘research’ methodologies,” which “present an extremely distorted picture of what is actually being discussed and debated” on the X platform, in order to “silence” speech with which CCDH disagrees); id. ¶ 43 (CCDH “used limited, selective, and incomplete data from that source . . . that CCDH then presented out of context in a false and misleading manner in purported ‘research’ reports and articles.”), id. ¶ 56 (“CCDH’s reports and articles . . . have attracted attention in the press, with media outlets repeating CCDH’s incorrect assertions that hate speech is increasing on X.”). X Corp. is correct that it has not brought a claim for defamation. See Opp’n at 10; FAC. It insists that that choice demonstrates that it is not really complaining about CCDH’s speech. Opp’n at 10. CCDH argues that X Corp.’s decision not to include a defamation claim is evidence that X Corp. “cannot allege that the CCDH Defendants said anything knowingly false, nor does it wish to invite discovery on the truth about the content on its platform.” MTD&S at 2; see also ACLU Br. at 1 (“X Corp. attempts to disguise a nonviable defamation claim as a breach of contract claim to retaliate against a nonprofit that provided the public with information critical of X Corp.”). Whatever X Corp. could or could not allege, it plainly chose not to bring a defamation claim.[10] As the Court commented at the motion hearing, that choice was significant. Tr. of 2/29/24 Hearing at 62:6–10. It is apparent to the Court that X Corp. wishes to have it both ways—to be spared the burdens of pleading a defamation claim, while bemoaning the harm to its reputation, and seeking punishing damages[11] based on reputational harm. For the purposes of the anti-SLAPP motion, what X Corp. calls its claims is not actually important. The California Supreme Court has held “that the anti-SLAPP statute should be broadly construed.” Martinez, 113 Cal. App. 4th at 187 (citing Equilon Enters. v. Consumer Cause, Inc., 29 Cal. 4th 53, 60 n.3 (2002)). Critically, “a plaintiff cannot avoid operation of the anti-SLAPP statute by attempting, through artifices of pleading, to characterize an action as a ‘garden variety breach of contract [or] fraud claim’ when in fact the liability claim is based on protected speech or conduct.” Id. at 188 (quoting Navellier, 29 Cal. 4th at 90–92); see also Baral v. Schnitt, 1 Cal. 5th 376, 393 (2016) (“courts may rule on plaintiffs’ specific claims of protected activity, rather than reward artful pleading”); Navellier, 29 Cal. 4th at 92 (“conduct alleged to constitute breach of contract may also come within constitutionally protected speech or petitioning. The anti-SLAPP statute’s definitional focus in not the form of the plaintiff’s cause of action[.]”) Collondrez v. City of Rio Vista, 61 Cal. App. 5th 1039 (2021), is a recent example of a court disregarding the name of a claim to assess its content. In that case, a former police officer brought suit for breach of contract and intentional interference with prospective economic advantage because his former employer disclosed information from his personnel file without giving him notice as required by contract. Id. at 1044–46. The court held that the claims nonetheless arose from protected speech, explaining that “we disregard [a claim’s] label and instead examine its gravamen.” Id. at 1051, 1048 (cleaned up). It then concluded that “the harmful act at the heart of the complaint, the act that allegedly cost [the plaintiff] his [new job] and resulted in other economic and emotional harm, is the publication of his personnel information.” Id. at 1049. Here, even though X Corp. did not include a cause of action explicitly premised on CCDH’s speech, as in Collondrez, speech is a harmful act at the heart of the complaint. X Corp. insists that that is not so, arguing that “CCDH’s actions caused harm independent of any alleged protected activities.” Opp’n at 11. It asserts that “[i]f CCDH carried out all the same illegal activities, but stopped just short of publishing the February 9, 2023 report, X Corp. would maintain the very same valid claims against it.” Opp’n at 11; see also id. at 11–12 (citing Kovalenko v. Kirkland & Ellis LLP, No. 22-cv-5990-HSG, 2023 WL 5444728, at *3 (N.D. Cal. Aug. 23, 2023) (“The question is whether the challenged allegations ‘supply a necessary element’ of a claim.”)). The Court disagrees— and not because it is impossible to imagine that X Corp. would have been motivated to bring suit had CCDH not spoken. Each of the state law causes of action—breach of contract, intentional interference with contractual relations, and inducing breach of contract—require as an element a showing of damages. See Oasis W. Realty, LLC v. Goldman, 250 P.3d 1115, 1121 (Cal. 2011) (“the elements of a cause of action for breach of contract are (1) the existence of the contract, (2) plaintiff’s performance or excuse for nonperformance, (3) defendant’s breach, and (4) the resulting damages to the plaintiff.”) (citing Reichert v. General Ins. Co., 68 Cal. 2d 822, 830 (1968)); United Nat’l Maint., Inc. v. San Diego Convention Ctr., Inc., 766 F.3d 1002, 1006 (9th Cir. 2014) (“the elements for the tort of intentional interference with contractual relations are ‘(1) a valid contract between plaintiff and a third party; (2) defendant’s knowledge of this contract; (3) defendant’s intentional acts designed to induce a breach or disruption of the contractual relationship; (4) actual breach or disruption of the contractual relationship; and (5) resulting damage.’”) (quoting Pac. Gas & Elec. Co. v. Bear Stearns & Co., 50 Cal.3d 1118 (1990)); Shamblin v. Berge, 166 Cal. App. 3d 118, 122–23 (1985) (inducement to breach a contract “requires that a plaintiff prove: ‘(1) he had a valid and existing contract [with a third party]; (2) . . . defendant had knowledge of the contract and intended to induce its breach; (3) the contract was in fact breached by the contracting party; (4) the breach was caused by . . . defendant’s unjustified or wrongful conduct; and (5) . . . damage[s] [were suffered as a result].’”) (quoting Dryden v. TriValley Growers, 65 Cal. App. 3d 990, 995 (1977)). X Corp.’s many allegations about CCDH’s speech do more than add color to a complaint about data collection—they are not “incidental to a cause of action based essentially on nonprotected activity.” See Martinez, 113 Cal. App. 4th at 187. Instead, the allegations about CCDH’s misleading publications provide the only support for X Corp.’s contention that it has been harmed. See FAC ¶ 78 (breach of contract claim: alleging that CCDH “mischaracterized the data . . . in efforts to claim X is overwhelmed with harmful conduct, and support CCDH’s call to companies to stop advertising on X. . . . As a direct and proximate result of CCDH’s breaches of the ToS in scraping X, X has suffered monetary and other damages in the amount of at least tens of millions of dollars”); ¶¶ 92– 93 (intentional interference claim: alleging that Defendants “intended for CCDH to mischaracterize the data regarding X in the various reports and articles . . . to support Defendants’ demands for companies to stop advertising on X” and that “[a]s a direct and proximate result of Defendants intentionally interfering with the Brandwatch Agreements . . . X Corp. has suffered monetary and other damages of at least tens of millions of dollars”); ¶¶ 98–99 (inducing breach of contract claim: alleging that “X Corp. was harmed and suffered damages as a result of Defendants’ conduct when companies paused or refrained from advertising on X, in direct response to CCDH’s reports and articles” and that “[a]s a direct and proximate result of Defendants inducing Brandwatch to breach the Brandwatch Agreements . . . X Corp. has suffered monetary and other damages in the amount of at least tens of millions of dollars.”). The “at least tens of millions of dollars” that X Corp. seeks as damages in each of those claims is entirely based on the allegation that companies paused paid advertising on the X platform in response to CCDH’s “allegations against X Corp. and X regarding hate speech and other types of content on X.” See id. ¶ 70. As CCDH says, “X Corp. alleges no damages that it could possibly trace to the CCDH Defendants if they had never spoken at all.” Reply at 3. Indeed, X Corp. even conceded at the motion hearing that it had not alleged damages that would have been incurred if CCDH “had scraped and discarded the information,” or scraped “and never issued a report, or scraped and never told anybody about it.” See Tr. of 2/29/24 Hearing at 7:22–8:3. The element of damages in each state law claim therefore arises entirely from CCDH’s speech. See Bonni v. St. Joseph Health Sys., 491 P.3d 1058, 1069–70 (Cal. 2021) (“a claim is subject to an anti-SLAPP motion to strike if its elements arise from protected activity.”). Accordingly, the state law claims arise from CCDH’s actions—its newsgathering and writing of reports/articles—in furtherance of CCDH’s free speech rights. Continue Reading . Here [10] At the motion hearing, X Corp. asserted that it was “not trying to avoid defamation” and claimed to have “pleaded falsity” in paragraph 50 of the complaint. Tr. of 2/29/24 Hearing at 59:20–23. In fact, paragraph 50 did not allege falsity, or actual malice, though it used the word “incorrect.” See FAC ¶ 50 (“incorrect implications . . . that hate speech viewed on X is on the rise” and “incorrect assertions that X Corp. ‘doesn’t care about hate speech’”). When the Court asked X Corp. why it had not brought a defamation claim, it responded rather weakly that “to us, this is a contract and intentional tort case,” and “we simply did not bring it.” Tr. of 2/29/24 Hearing at 60:1–12; see also id. at 60:21–22 (“That’s not necessarily to say we would want to amend to bring a defamation claim.”). [11] If there is any question about the “punishing” part, X Corp. filed a similar suit, not before this Court, in November of 2023 against Media Matters, another non-profit media watchdog, for “reporting on ads from major brands appearing next to neo-Nazi content.” PPP Br. at 10. Prior to doing so, Musk threatened a “thermonuclear lawsuit” against Media Matters. Id. (quoting Elon Musk (@elonmusk), X (Nov. 18, 2023, 2:01 AM), https://twitter.com/elonmusk/status/1725771191644758037 [https://perma.cc/K8SZM33S]). Musk’s post also claimed, remarkably, that the lawsuit was furthering X Corp.’s efforts “to protect[] free speech.” See Elon Musk (@elonmusk), X (Nov. 18, 2023, 2:01 AM), https://twitter.com/elonmusk/status/1725771191644758037 [https://perma.cc/K8SZM33S]. About HackerNoon Legal PDF Series: We bring you the most important technical and insightful public domain court case filings. This court case retrieved on March 25, 2024, from is part of the public domain. The court-created documents are works of the federal government, and under copyright law, are automatically placed in the public domain and may be shared without legal restriction. storage.courtlistener

X Files Lawsuit Against Center for Countering Digital Hate, Alleging Speech Suppression Tactics 

The American auto industry finds itself on potentially shaky ground, as a significant and historic labor movement gains momentum. On September 15, automotive production came to a screeching halt at three major facilities located in Michigan, Ohio, and Missouri. Details on the Strike This stoppage is due to nearly 13,000 members of the United Auto Workers (UAW) union deciding to down tools and walk off the job. Notably, this marks the inaugural occasion in U.S. history where the UAW has simultaneously initiated strikes against the "Big Three" automakers: Ford, General Motors, and Stellantis. Stellantis, it should be noted, isn't just a single brand. It encompasses a portfolio of 14 different automotive brands, which includes household names like Chrysler, Dodge, and Jeep. This wave of strikes was prompted by the expiration of union contracts for a vast number of UAW members, totaling approximately 150,000, who work for the Big Three. These contracts ran out on September 14. According to the details of this now-expired agreement, full-time autoworkers would start with an hourly wage of $18. This rate could climb to a peak of $32 per hour, but only after they have dedicated eight years to the job. Several pressing questions emerge in the wake of these developments. What is the Biden administration’s proposed plan to navigate or potentially mitigate this labor dispute? It remains crucial for the authorities to address this swiftly, given the immense economic implications of a prolonged strike and the negative consequences it can have on the livelihoods of thousands of workers. CBS that Ford Motor said it had temporarily laid off 600 non-striking workers at its assembly plant in Wayne, Michigan, only hours after other employees at the facility had walked off the job early Friday. reported UAW President Shawn Fain visited the Wayne plant Friday and said the strike will continue until Ford, GM, and Stellantis (which owns Chrysler, Dodge, Jeep, and RAM, along with foreign brands such as Peugeot and Open) lift worker wages and improve job security. Interestingly, in August, the Biden administration billions in grants and loans to help the auto industry transition to making electric vehicles — while retaining union workers for the new jobs, announced as reported by Michigan Radio. The $15.5 billion program is expected to be administered by the Department of Energy. Car companies that have a long history in auto manufacturing with an existing union workforce, will get preference for some of the money. That could mean the Detroit Three would have an application advantage over car makers in southern states with non-unionized workforces. While the immediate effects of the strike seem detrimental, it's possible that some sectors or entities might find an advantage. Who stands to benefit from this labor unrest? With traditional automakers facing such disruptions, does this present an opportunity for the Electric Vehicle (EV) market to capture a larger share? Could this strike inadvertently propel the EV industry to the forefront of the American automotive sector? The UAW strike is not just about immediate labor concerns. Beneath the surface, there's a deeper undercurrent of unease about the impending shift towards EVs and its potential implications for the labor market. By virtue of having fewer parts than their traditional internal combustion counterparts, EVs inherently demand less manual labor, potentially leading to significant job cuts. Moreover, the geographic distribution of these emerging EV industries raises eyebrows. A substantial portion of the new plants dedicated to EV manufacturing is sprouting in the southern states, where the climate is not particularly friendly towards labor unions. Companies like Tesla and several Asian EV manufacturers, while pioneering in the field, are criticized for not compensating their workforce adequately. The relatively lower wage structure in these firms stands in sharp contrast to what unionized workers in traditional automakers earn. Recognizing the tidal wave of change coming, the UAW sees this juncture as crucial. It's not just about immediate wages or working conditions; it's about setting a precedent for the future of American EV manufacturing. The union aims to ensure that as the EV industry flourishes, the workforce isn't sidelined but rather receives a just portion of the burgeoning profits. Parallel to this labor-management dispute runs a broader political narrative. There's an ongoing tug-of-war between factions advocating a rapid shift to EVs to curb carbon emissions and those championing the rights of fossil fuels. Some argue for a more laissez-faire approach, proposing that market forces alone should dictate the speed of this automotive evolution. What Happens Next? Amidst this complicated and layered saga, the Biden administration has come under scrutiny. The question arises: What steps is the current government taking to mediate and guide this transformation? As we stand on the cusp of an automotive revolution, the choices made now will undoubtedly influence the trajectory of the U.S. auto industry for decades. The intersection of labor rights, technological advancements, and environmental concerns promises a difficult road ahead, and we will need to come together to navigate it. Only time will tell how these events will unfold and shape the future of the American automotive landscape. Until then, let us hope everyone keeps their jobs.

Is America’s Auto Industry in Trouble?

“Improved productivity means less human sweat, not more,” - Henry Ford, Founder, Ford Motor Company Whenever you decide to start your business, there might be several apprehensions surrounding you. There is hope for success, fear for failure, and confusion regarding the management of business functions. One of the reasons why most Americans (74%) back out from the idea of starting their own business is because of , but at the same time, 1/3rd of businesses also start with . lack of funding less than $5,000 But the eye-opening revelation here is that about 47% of the would-be entrepreneurs back out from the idea of starting a business because of lack of access to business tools and 46% of them are likely to start a business if they had better knowledge about business tools. If you are one of those aspiring entrepreneurs who are unable to start their business or struggling to manage one due to limited knowledge about business tools, this article will serve as a useful guide for you. You will learn about the concept of SaaS and beginner-friendly SaaS tools for e-commerce startups. Let us begin with the basics. What is SaaS? SaaS is an acronym for Software as a Service that provides specific services via applications or through cloud computing over the internet. It is a type of web-based model maintained and updated by software developers over a secure cloud network. In layman’s terms, SaaS applications are software that offers you services to simplify and streamline complicated manual functions. In simpler words, it is a platform offering a productive replacement for critical, complicated, and time-consuming manual work. The best thing about SaaS is that you don’t have to install it on your desktop or computers, you can simply access it on the internet, eliminating the cost of purchase, maintenance, and upgrades, some of which are even completely free. Some of the common examples of SAAS are Amazon Web Services, Google Workspace, and Hubspot. The SaaS market is a booming industry whose value is projected to reach . $168.6 billion by 2025 All successful companies and businesses use SaaS to streamline their business functions and be easily integrated with the team. According to the 2020 State of SaasOps survey by SaaS applications make up to 70% of a company’s software use. BetterCloud, 5 Must-have SaaS Tools for E-commerce Start-ups Managing an e-commerce business, especially when you are just starting out is not an easy job. There seems to be a pile of activities that calls for your attention but you are not sure how to attend to them. There is inventory management, customer queries, marketing, and most stressful of all - sorting out your orders and shipping functions. The whole point of technology is to simplify work for human beings, and SaaS tools for startups do exactly the same. Here are some of the beginner-friendly SAAS tools to enhance productivity for your e-commerce small business along with some pros and cons. Shopify (for online e-commerce store) Subscription:  14-day free trial, 3 plans available is an online platform that helps you create and personalize your online store. Shopify stores are one of the best ways to launch your online business if you are just starting out and low on resources. Shopify It offers you a platform to buy, sell, ship, and promote your products online with an easy interface that is beginner-friendly and affordable. From handcrafted goods to electronics, you decide what you want to sell. Launched in 2006, Shopify currently serves 176 countries and has over 1 million business users. Shopify offers 3 monthly plans starting from $29/month, making it suitable for businesses of all sizes to operate their online store without any hassles. As a new user, you  get a 14-day free trial. If you are satisfied with your experience you can go ahead to subscribe to one of the Shopify plans. Pros Low startup cost. Beginner-friendly and easy to use. Great for dropshipping. Attractive themes and templates for personalization. Cons Add ons can be costly. Transaction fees. Oberlo (for dropshipping and inventory management) Subscription- Free, Basic ($29.90 USD/month), Pro ($79.90/month) If the concept of dropshipping sounds appealing to you, say Hi to Oberlo. is a dropshipping tool and platform that allows you to import inventory online from your inventory supplier and sell it directly on your online store. You don’t have to own, store, maintain, or ship the inventory. The inventory supplier will ship the items directly to the customer. Oberlo Oberlo dropshipping offers a direct integration between the platforms Shopify and AliExpress. You can import the products from Ali Express and add them to your Shopify store with a simple chrome extension. The Oberlo Shopify integration is a smooth and hassle-free process, all you need is a stable internet connection. You are eligible for a 30-day free trial once you sign up and choose your plans according to your needs after you are satisfied with its utility. While not fully optimized for mobile and tablet functions, you can easily operate Oberlo on your laptop or computer. Pros Easy and secure product imports. Automated order processing and fulfillment. Easy product customization. Ample learning resources available. Cons Only compatible with Shopify and AliExpress. Restriction on some products without clarity on terms. Canva (for image editing and design) Subscription- Free Upgrades- Pro ($12.99/month or $119.99/year), Enterprise ($36/month) Managing your e-commerce business is not only about processing and shipping orders. One of the most crucial aspects here is how well you present your brand and products to your prospects. The human brain processes visual information and about . As such, there is no second-guessing the fact that  visual content can make or break your brand. 60,000 times faster than text 90% of information transmitted to the brain is visual But guess what? You don’t need to be a graphic designer or a photoshop expert to create your own product and marketing designs, online can save your day. It has a range of custom design templates available according to the need and specifications of various social media platforms. Canva You can design carousels, catalogs, and ads with a few creative uses of the features. Canva is adored by its users for its simplicity and uncomplicated nature. Canva is also fully optimized to operate from a mobile phone. All you have to do is download the Canva app and use it anywhere, anytime at your convenience. And the best part is it’s free for everyone! Of course, there are upgrades available but the free version seems to be working just fine. Pros Easy and simple to use Custom templates as per social media requirements. Supports many picture formats and storage Easy access to everyone Cons Limited free version Can’t create your own elements. You have to develop designs from the templates provided. Shipstation (for managing online orders and shipping functions) Subscription-30 days free trial, Multiple plans available. Shipping is hands down one of the most stressful functions you have to manage as an e-commerce vendor, and I don’t even need statistics to prove that. is a SaaS platform that helps you manage your shipping functions across various e-commerce platforms effectively. Shipstation lets you integrate with over 70 best-selling sites and  manage all your essential shipping orders through one platform. Shipstation You can easily administer your inventory, generate discounted shipping labels, and build banded shipping with the help of this SaaS application. Once you sign up, you are eligible for a 30-day free trial, and if you are satisfied with your experience you can go ahead and purchase their monthly plans. Their monthly plans range from $9/month for beginner-level entrepreneurs with up to 50 shipments per month to $159/month for growing businesses supporting up to 1000 shipments per month. It is a great platform for early-stage entrepreneurs and businesses who can’t afford to rent a warehouse or hire staff to support their shipping functions. Pros Easy to use. Excellent features and automation. Multiple integrations. Discounted shipping labels Cons It may require some time to understand the features Conflicting reviews regarding customer service. Grammarly (for error-free content writing) Subscription- Free Upgrades- Premium ($12/month), Business($12.50/month) is a great SaaS tool to ensure that you create grammatical-error-free, clear, and concise content. As an entrepreneur, you have to look into the most crucial aspect of your business which is marketing and content creation. Grammarly helps you to keep your content faultless, clear, and concise that is easily comprehensible to all. Grammarly Grammarly is free to use with limited features that check your grammar, spelling, punctuation, and detect your tone. You can upgrade to Grammarly premium for advanced writing features that help you pick the right delivery and create engaging content. Grammarly Business is for businesses wanting to enhance their team communication in a professional and clear manner. Plagiarism detection is also available in both upgrades. Pros Real-time grammar correction. Easy to use (only requires a chrome extension). Adequate free version for basic grammar correction. Customization ( select preferred language, add new words). Cons Does not guarantee 100% accuracy and correctness. Limited free version. Summing Up It is astounding to witness how far technology has come in substituting and simplifying manual work. Things that seemed impossible to comprehend 10 years back are now a reality. Starting your business today is a lot easier than a few years ago with an array of convenient and inexpensive business tools available at your disposal. You just have to know how to look for it. Good luck!

5 Essential SaaS Tools for Ecommerce Startups: Shopify, Oberlo, Canva, ShipStation, and Grammarly

The rapid growth of cryptocurrency is  unprecedented. In January of 2022, there were and a whopping total of 4.7 million NFTs in April of 2021. Today, 79% of international commerce value is the product of the top ten cryptocurrencies, and its influence is projected to augment. 8,000 cryptocurrencies Cryptocurrency theft is a valid concern, as schemes have risen from a total of $7.8 billion in 2020 to a mind-boggling total of $14 billion in 2021. Through a number of acquisition strategies, the security of your cryptocurrency has risen in value, and the need to secure it, in urgency. Merely 50% of U.S. adults affirm the security of cryptocurrency. Speaking to this with optimism, and trust that crypto security will improve, Tevor Maynard, the Head of Innovation at Lloyd's says, “as more money flows into the crypto asset market, losses from hacks are on the rise. Nevertheless, crypto companies have found ways to protect their digital assets from theft”. Henry Ford, the late business prisoner, industrialist, and founder of Ford Motor Company once said, “The best we can do is size up the chances, calculate the risks involved, estimate our ability to deal with them, and then make our plans with confidence”. Now, with the rise of cryptocurrency insurance, there's a new way of doing so, as the new form of financial backing offers insurance for businesses, caps that cater to your investment needs and protects insured assets against the traditional theft that threatens millions of Americans. There are three steps involved in obtaining insurance via cryptocurrency and NFTs. As with searching for traditional insurance companies, the process begins by familiarizing yourself with industry players and obtaining quotes from them. Next, your decision should be largely influenced by comparison of your coverage estimates, which will vary by provider based on your personal financial information. Then, choose a plan of protection, with fraud insurance, custody insurance, DeFi insurance, and exchange insurance being some of the innumerable umbrella options you can turn to for coverage. Choose the future of insurance, by putting your investments in the hand of , and in turn, invest in the financial of you. crypto insurance

Cryptocurrency Insurance Can Protect You Against Hacks [Infographic]

In 2020 a large aspect of the landscape for modern application development changed. The result of an unexpected pandemic forced brick and mortar offices to close their doors and ask employees to perform their daily tasks remotely. This included teams of software engineers focused on creating, building, and enhancing the technology needs of their employer. Asking team members to work remotely for a short period of time or even a portion of a week is one thing. Instantly pivoting and asking everyone to plan to work remotely indefinitely is another. In fact, the downstream effects of this new requirement stuck into the heart of any team's biggest need ... intra-team communication. For the purpose of this article, I am going to narrow my focus to the very social aspect of peer reviews and focus on how to yield effective code reviews while working in a 100% remote situation. Code Reviews Explained So what is code review? According to Wikipedia, a code review is: " is a software quality assurance activity in which one or several people check a program mainly by viewing and reading parts of its source code, and they do so after implementation or as an interruption of implementation." Code review Code reviews are often referred to as peer reviews, pull-requests (PRs), and even a merge request. Regardless of the term used to define the process, the end result is the same - to ask another capable team member to review updates to the code base before pushing the changes to the next step of the development lifecycle. Level Setting Code Reviews Let there be no confusion, the goal of all code reviews should be to in the underlying application or service under review. Years ago the Ford Motor Company initiated the “Quality is Job 1” marketing slogan, which can be applied to code reviews. After all, no product owner wants to receive feature code that hasn’t been inspected from a quality perspective. maintain quality There are three additional benefits which often result in employment of code reviews: learning opportunity the feedback ladder software engineer analytics Learning Opportunity Code reviews should always be considered a for everyone involved. In most cases, the more senior reviewer will provide alternatives or suggestions which lead to improvements to source code and convey a lesson to the submitter. However, it is also common for the reviewer to gain knowledge as part of the process. In fact, it was in a code review that I learned the use of underscores is allowed in Java for setting static variables: learning opportunity private final long FIFTEEN_MILLION = _000_000; static 15 The Feedback Ladder The “Ladder of Feedback” was developed by ( ) and is a protocol or structure that establishes a culture of trust and support by sequencing feedback in an order that is constructive. applied this cognitive approach to code reviews and established the Feedback Ladder: Daniel Wilson Harvard Project Zero Netlify Understanding that no two developers solve problems exactly the same, code reviews can quickly become filled with suggestions that are less about code quality and code preference. While the suggestions may be valid, they do not resolve a negative situation with the code being reviewed. The Feedback Ladder approach allows reviewers to prefix suggestions with one of the following categorizations: [mountain] – code review blocked until comments are addressed [boulder] – blocking, but can be allowed to move forward (with a remediation plan) [rock] – not blocking, but future work is required (reference to ARM ticket in code) [pebble] – not blocking, requires future consideration [sand] – not blocking, “take it or leave it” Note: the original Netlify design by uses the mountain, boulder, pebble, sand, and dust categories, but I have had better success using the categories provided above. Leslie Cohn-Wein Software Engineer Analytics The code review process itself provides an opportunity to gain analytical information on software engineers participating in the lifecycle event. Such information can be helpful to justify decisions that need to be made as a result of periodic performance reviews. For the code reviewer who is consistently focused on following design standards and delivering quality, a manager can pull numerous examples to justify merit increases to upper management. Conversely, an individual who is not the best fit for the team can be exposed over time via the code review process. While this is a situation that no one desires to be in, having the documentation available does help management make the best decision for their organization – without asking peers to spend time compiling their thoughts. Code Reviews in a Remote-Driven World Since working remotely, I have seen the following flow produce positive results with respect to code reviews: Create – utilize git-based tooling to establish a new code review Document – go the extra mile to include detailed information to supplement the code review (including diagrams and video links) Collaborate – using screen share or team-based tool, walk through the details of the code review Adapt – make the necessary updates, based upon feedback (the Feedback Ladder) Merge – complete the code review process (upon approval) Communicate is at the center of this flow, meaning every step employs a communication strategy to not only keep the code review active, but as a mechanism to alert additional teams working on the same application or component. Some examples include: Send direct links to code review (instead of email)Announce when the code review has been approved and updates are availableProvide information regarding the code which has been approved Heroku Review Apps Feature The ecosystem includes a feature called “ ” that will execute the code in any GitHub pull request (a form of code review) in a complete, disposable Heroku app. Review apps each have a unique URL that can be shared, making them a great way to propose, test, and merge changes to your code base. Heroku Heroku Review apps The benefit to this approach is that the reviewer assigned to the code review can focus their efforts on the Heroku Review app running – saving them from having to stash in-progress changes in order to see a working version of the proposed source code. To utilize Heroku Review apps, simply navigate to the Deploy tab of the Heroku Dashboard: Upon following the steps documented , the Conversation tab in the GitHub pull request will show the Heroku Review app has been deployed: here This information is also available in the Heroku Dashboard in the Review Apps section of the application’s Pipeline page: Conclusion For me, 2020 was really no different than the last four years. I have been working exclusively in a 100% remote mode and even published the following articles on DZone: Code Reviews — What Really Matters? How Are Your Pull Requests? My current project is by far the most complicated project I have worked on in an IT career that started in early 1992. In addition to a complex need that is getting filled, there are eight agile teams working on the project with staff located not only in North America, but Europe and Asia as well. Considering the amount of progress that has been achieved in a fraction of the time that was required to create the original application, I feel strongly that our success is directly tied to the freedom of working remotely and being able to effectively communicate across vast geographical regions. This translates to highly successful code reviews using many of the suggestions provided above. The code review process is only as isolated as an individual desires – with technologies in place to ease any gaps that were introduced in 2020. I truly believe code reviews have only improved as a result of a 100% remote scenario. Have a really great day!

Effective Code Reviews For Remote Teams

Many of us at some point have found that our computer had started acting weirdly. Computer viruses basically act like viruses and replicate.  They infect lots of files on a computer and also spread to another computer. There are viruses like Worms, Adware, Trojans, and Rootkits which are hard to detect and can give attackers control of the machine. Perhaps even more frightening viruses are ransomware attacks, where someone gets a hold of the data and sometimes sensitive data that makes you pay to get it back. Some of the known computer viruses are: 1. SQL Slammer / Sapphire This caused havoc in the USA in 2003 and cost about $1B. It affected the web servers which eventually lead to bank ATMs crashing. It messed with continental airlines, electronic ticketing and it blocked 27 million people from the internet with even Seattle's 911 services affected. explained Slammer used a software attack with the infected computers spreading the worm through the internet. It infected around 75,000 servers in just 10 minutes. It was then stopped by patches and antivirus software. The creator of this virus remains unknown. Wired 2. Melissa This virus was named after an exotic dancer. It began as an infected Word document posted on an alt.sex Usenet group and if that was opened it would send itself to 50 people on some other person's Microsoft Outlook email program. That might not sound too bad. But it created mayhem when emails were being sent at a rate that messed with companies and big corporations so much so that in 1999 Microsoft shut down incoming emails. According to a source email users would get a message as 'Here is that document you asked for and don't show it to anyone else'. There was also an attachment with it. And it cost  the governments, people, and companies all about $1.2B. 3. Anna Kournikova This virus was created by a young  20-year-old Dutch guy named Jan De Wit. He used an apparent photo of the good-looking tennis player, Anna Kournikova as bait where if you clicked that file then it created a viral visual basic script that means everyone in the address book will be forwarded the same thing. This affected millions of people which eventually overloaded the servers all over the world. According to a source the time after De Wit understood what the worm did he decided to turn himself into the police. He was lucky and got away with only 150 hours of community service. The virus was even in an episode of a sitcom named Friends. 4. Code Red These estimates on the damage caused by Code Red range in the billions of Webpages that were affected and suddenly got the message 'Welcome to worm comm hacked by Chinese Norian'. The malicious code was not saved as a file but is inserted into and then run directly from memory. It has been called one of the most sophisticated attacks ever that almost brought down the internet. Many websites ran on Microsoft Internet Information Server and was subject to this distributed denial-of-service attack which means the websites got overwhelmed with too much traffic that effectively brought them down. According to Scientific American, it might not have been China who was the culprit though. Many investigations were conducted, but the culprit remains unknown. 5. Conficker Conficker is said to be the most destructive worm of all time and cost those infected around $9B. This was discovered in 2008 and infected around fifteen million computers. It affected police departments in the UK as well as the military and messed with their operations. It infected Windows operating systems for a long time as it kept getting past antivirus software and patches. It was a mystery for security experts too, but they knew a machine infects other machines in the network. 6. ILOVEYOU This virus came as an email with the words 'I love you' in the subject line. It's spread fast because people open that attachment file and once they did that everyone else in that address book got the same email and apart from that it also deleted many JPEG and MP3 files. It reached around 45 million people in just a day. It became so huge that in 2000, Ford Motor Company shut down its email. It was almost the same as Melissa, but over here it sent a mail to all of your contacts and then deleted personal files too. Pentagon CIA and the British Parliament also shut down their emails. The virus was eventually linked to some young programmers in the Philippines and the cost of this virus was around $15B.

A Recap of Some of the Most Expensive and Destructive Computer Viruses at the Turn of the Century

Data Driven Being data-driven is one of the most essential prerequisite for any organisation to achieve the desired digital transformation. In this regard, firms have started treating their data as assets and adjusting their strategies to emphasise them. The bars were set high a decade before but the transformation process is slower than the expectation. Many proofs exist on the failures of modern enterprises going data driven. One such study is the findings of . NewVantage Partners’ 2019 Big Data and AI Executive Survey The survey comprised of several c-level technology and business executives representing large corporations such as American Express, Ford Motor, General Electric, General Motors, and Johnson & Johnson Though there are tremendous investments in big data and AI initiatives, the negativity constitutes more than 50% in all the above cases. The Three V’s Why are the enterprises failing to be data driven? It is because of the Three V’s effect - Volume, Variety & Velocity Volume: It is becoming difficult to handle the volume of ever-growing data produced and consumed within and outside the organisation. Every now and then organisations upgrade the storage and processing power to support the expected data volume. Variety: The variety of data produced by an enormous amount of sensors and applications are of mixed type - structured, semi-structured or unstructured. Many traditional and proprietary data platforms and tools are finding it difficult in onboarding these different types. Velocity: All these sensors and applications generate data at the speed of light. Extracting, transforming and loading them in real-time and delivering the analytics at the same speed seem to be a herculean task for many ETL tools. One Such SMB: One of our customers, who is a leader in Through-Channel Marketing Automation, segmented in the Small and Medium Sized enterprise category, wanted to become real-time data driven to compete on data analytics. They did not want to stay behind using traditional ETL tools in analysing old time data. Business Challenges: The enterprise’s product had well defined integrations by leveraging Pentaho (Kettle) ETL features, which pretty much supported their business for a decade. Later in the new data era, it started to receive different sets of expectations from the business. The end users of the business wanted to make decisions based on real-time data rather than near-real time/ old data. Analytics on Real-Time Data: Business developers heavily depended on the ETL developers for every customisation in the data pipeline - maybe it was complicated or less complicated. Not Business Developers Friendly: The number of cycles went through in delivering the data pipelines to production were huge as it involved end-to-end manual steps. Lack of Automation: Technical Challenges: The supported SaaS sources were - Google & Salesforce by , but the business demanded to have most of the social platforms as their data sources. Pentaho’s latest version 8.0 supports Realtime Streaming data but that is not targeted to receive stream from all the social platforms off the shelf. Instead it requires a couple of steps to be configured here and there by ETL developers. Ref - Multiple SaaS Channels: Pentaho stream-data-from-twitter-api-with-oauth-using-kettle Each APIs demand a different set of authentication mechanism. Though most of the platforms support either OAuth / OAuth 2, there were needs to have Basic Authentication as well. Support for Multiple Authentication protocols: The response of any streaming would be totally different from how it is stored for further processing. Apart from storing or doing any transformation, nothing more could be expected from ETL integration tool. But the below challenges were to be addressed. The selection of the fields from the response needs to be easily achieved and minimal transformation like datetime format, currency format change based on locale were also expected. Data Fields Selection & Transformation: Business developers should be able to create the pipeline without much effort for working with any of the social platforms. A simple drag and drop of components should allow creating any data pipeline. This tailor made data pipeline creator is not something supported out-of-the box by any of the data integration tools in the market. Business Developer Friendly: If a business developer wants to change a step in the pipeline - either by adding a filter or by removing a verification step, the process should like that be deployed into the respective environment for testing and delivered to production in no time. Time to Market: The Approach: We conducted day long workshops and design thinking sessions to understand the pain points of all the stakeholders - Product Managers, Business Developers and Data Engineers. The data points - functional and non-functional requirements were carefully collected and we have come up with a recommended solution of creating data pipelines dynamically by leveraging Spring Cloud Data Flow and it met the expectations! The Functional View The incoming realtime streams from various social platforms. Data Sources: Connectors of supporting various API  (SOAP, REST & Graph) & Authentication protocols (OAuth, OpenID, Basic) API Connector: Lists of all the attributes from the respective stream which can be chosen for processing further Metadata Picker: Customisation of the attributes by Formatting & applying transformation logic is done here. Data Formatter: The sink tables (GCP - Bigtable) where the data analytics queries get fired. DB Tables: Systems View Authentication & Authorisation The allowed users are from the GSuite (the enterprise’ Identity Provider) With the help of Cloud IAP, the access to the application is controlled. GCR with App or Task Images Container Repository of pre built images of applications/ tasks to be developed as Source, Processor & Sink. These images are templates, used for creating the components in any stream. The images could be of source, processor or sink type. These images would be accepting the configurable properties like endpoint URI, accessToken, Consumer Key and Consumer Secret etc...and pass them to the underlying applications/tasks so that they can consume/process/receive the data based on the type. Data Pipeline Creator UI To configure the data sources with respective authentication configurations To render the metadata for selection/ filtering To specify the data formatting per data source Data Pipeline Creator Service A containerised microservice exposing REST APIs used in the Data PipeLine Creator UI All the configurations  specific to a data pipeline - from the source to the destination are preserved in the metadata database to which this service has access to. This service abstracts out the Spring Cloud Data Flow services for the given needs as shown below Spring Cloud Data Flow Server The server responsible for creating a data pipeline (for the given configuration) per data source configuration and deploying in the Skipper Server as data streams It is configured with Kafka streams to support real time data processing. Mission Accomplished! The recommended solution has been implemented; the enterprise has done the end-to-end automation of continuously deploying the real time data services and pipelines into production without much help from ETL developers but by the business developers. The mission accomplished! Conclusion There are many reasons why any enterprise fails in achieving the goal to become data-driven. Irrespective of the number of excuses and failures, the amount of data continues to rise exponentially. According to the independent research firm , the growth in connected IoT devices is expected to generate 79.4 Zeta Bytes of Data in 2025. IDC It is just in 5 years and is really HUGE! So, it is time to be aware, nurture data and become a data driven enterprise.

Compete on Data Analytics using Spring Cloud Data Flow

How I Use Drag and Drop Programs to Help More People My name is Max Albert. I’m a full-stack web and iOS developer for Ford Motor Company. I’m also a freelance developer for hire. I love freelance development because it introduces me to new technologies, interesting projects, and different people. I also get to learn a lot about other styles of development and take that knowledge back to work. It’s not all smooth sailing though. One of my major pain points as a freelance developer is not being able to take on every project. I’m constantly connected to entrepreneurs, hobbyists, and businesspeople who want to build a simple mobile app. But unfortunately there isn’t enough time or budget at the end of the day. Furthermore, having to turn down projects is especially problematic because freelance development is seasonal. There are times where I’m flooded with work, and other times where it feels like there is no work at all. The best way to cultivate a steady freelance schedule is to consistently deliver for clients — which is impossible when you have to say no to some projects. Desperate for a solution, I turned to low code/no code drag and drop tools to increase the amount of work I could take on. It was the best decision I’ve made in my freelance career. Not only was I able to take on more work, I was also able to iterate quicker by rapidly developing “beta tests” and quickly implementing client feedback. Recently I chose to use to develop a basic survey app. Though the app itself was simple, the client wanted a few added bells and whistles: Thunkable A database to record the information (plus some workflow to allow the client to interface with that information) Text alerts when a user submitted the survey Security (only authorized users should be able to complete the survey) Identical applications for both iOS and Android Normally these extra features would’ve exponentially increased my estimate on development time — but Thunkable made development really easy by allowing me to record data using . Thunkable also has technology to handle account creation and security through . Airtable Firebase Best of all, I was able to export my app to Apple’s App Store and the Google Play Store seamlessly. Normally, coding these two applications in Swift and Java would’ve ran my client a couple thousand dollars in development time. Plus, it would’ve taken weeks in real life since I’m juggling other projects and a full-time job. But with drag and drop tools I was able to cut that time half, and deliver two apps in just a weekend. Don’t get me wrong, drag and drop platforms have limitations. Good old fashioned programming enables more complexity and deliberate design. That said, there are plenty of technical challenges that are much better served by drag and drop tools than by native coding--like the survey app I created for my client. Features like text alerts, updating a simple database, and account creation have already been programmed. There's no need to re-program these features. In my opinion, developers shouldn’t waste time reinventing the wheel. Many drag and drop tools can deliver the same functionality for freelance projects, but faster and cheaper. Developers might be embarrassed using drag & drop tools to build a mobile application for professional purposes. That’s a fair worry. At times it certainly felt juvenile to program my app using building blocks similar to . scratch But although I had some hangups about blocks, I never missed the code. In fact, it was nice to look at colorful blocks. They were whimsical and kept development lighthearted. Plus, it wasn’t a challenge to learn a new drag and drop tool like Thunkable. Themes like efficiency, reducing code duplication, and inheritance were all still available. More importantly, I find that clients and business people really don’t care how I build an app as long as the process is cost effective, timely, and delivers a professional product. Thinking back on my freelance projects, I believe the vast majority could have been completed with no code tools. Realizing this fact is also a good warning to freelance developers: drag and drop tools are getting good. Really good. I highly recommend trying out platforms like Thunkable for your next freelance development project. What feature(s) would you like to see drag and drop tools adopt? I’m curious to hear from you!

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