Identify and assess the significance of three factors that contributed to American westward movement Essay Example for Free

Identify and assess the significance of three factors that contributed to American westward movement Essay This could be dismissed as ‘the grass is always greener’. There were however a number of factors involved. These included the search for precious metal, the possibility of obtaining land and the expansion of the railways. Although usually described as a move west, it was to some extent also a move south as in the case of those seeking gold and silver in Californian mines as a result of the accidental finding of gold by James Marshall in 1848 as described by Steve Weigand on the web page ‘The California Gold Rush, an era remembered. Land was seen as a form of wealth and the majority of those who migrated to America did so in the hope of obtaining land to farm. Under British rule Europeans had been restricted in their settlement to the area east of the Appalachians, but after the Revolutionary War this inhibition was removed and so people streamed south and west. Later, with the coming of the railways, markets in the north could be served from further west. This allowed the great expansion of cities such as New York and Chicago. see more:which was a factor that led to the scientific revolution In the years immediately before the American Civil War in the 1860’s the railways had built up into quite a network serving the eastern states, but afterwards they gradually spread over the rest of the country. This meant that people no longer had to spend many weeks of hardship in order to reach their destination and so the tiny townships already established by earlier settlers were quickly expanded new comers seeking for themselves and their families a better life. The Irish potato famine of the 1840’s as described on the History Place web page, ‘The Blight Begins’ led to many immigrants from that country, the majority would not have been city folk, so it is perhaps natural that some migrated to the western states where they saw at least some hope for their future, just like all the other migrants.

The Strategies of Ryanair

The Strategies of Ryanair Ryanair Holdings is Europes leading low-fare scheduled passenger airline, carrying roughly 34 million passengers per year, across 19 countries (Ryanair, 2006). The company operates short-haul, point-to-point routes between Ireland, the UK and Continental Europe, and the companys leading market position provides the company with the ability to leverage its market position to further expand its operating network: a key part of its current operating strategy. However, the predicted decline in the domestic European air travel market (Global Market Information Database, 2005) is likely to decrease the demand for the companys services and thus harm its resultant revenues, and so the other key aspect of the organisations strategy is to reduce its exposure to these external threats. (Johnson et al, 2005). Hence this work aims to examine the interplay between these two strategies, critically analysing both their current, and potential future, success. Leveraging market position to drive revenue Ryanair has the leading market share on most of scheduled routes between Ireland and provincial cities in the UK, carrying approximately 43% of all scheduled passenger traffic between Dublin and London. Additionally, the company has more than 45% market share on scheduled routes from Dublin, which include London, Manchester, Glasgow and Edinburgh, and London, which include Venice, Rome, Milan, Hamburg, Valencia and Gothenburg, as of January 2005. (Datamonitor, 2005) Ryanair has also been voted as the airline with the best punctuality highest frequency which, combined with the companys leading market position, provides the company with the ability to leverage its market position to further expand its operating network. Ryanair has also been reporting strong revenue growth since fiscal 1999, and the company reported revenues of 1336.6 million Euros during the fiscal year ended March 2005, an increase of 24.4% over 2004. (Ryanair, 2006) The increase was primarily attributable to an increase in passenger volumes, which increased by 19% over 2004, and the companys revenues increased at a compound annual growth rate of approximately 28.6% from 1999 to 2005, despite the overall fall in air travel during that period (Global Market Information Database, 2005). Additionaly, Ryanairs net income increased at a compounded annual growth rate of 29.1% from 1999 to 2005. Thus, the companys strong consistent financial strength provides its operations with financial stability and the ability to fund its expansion strategies. Ryanair thus has an extremely strong and aggressive business strategy, which is focused on its objective to firmly establish itself as Europes leading low-fares scheduled passenger airline. The company offers low fares designed to stimulate demand, particularly from fare conscious leisure and business travellers. (Ryanair, 2006) The company favours secondary airports, as they are generally less congested than major airports and can be expected to provide higher rates of on-time departures: the company can thus achieve faster turnaround times and fewer terminal delays and gain competitive handling costs. (Datamonitor, 2005) The strategy has enabled the company to have a better on time performance record, than its bigger competitors. In addition, Ryanair enters into agreements with third party contractors to handle passenger and aircraft handling, ticketing and other services, and the company fixes its contracts on competitive terms by negotiating multi-year contracts, at prices that a re fixed or subject only to periodic increases linked to inflation. Ryanairs strong business strategy thus enables the company to synchronize its operational strategies in accordance with the market requirements, thereby enabling the company to maintain a cost effective business strategy. Hedging against external threats. Crude oil prices are at an all time high: in March 2005, light crude oil prices climbed to $55.40 per barrel after peaking at $56.1 per barrel. Additionally, jet kerosene prices have increased by over 80% from 2004. In order to protect their operations from significant volatility, airlines have fairly robust hedging positions, as the volatility in oil price and availability of jet fuel significantly affects operations. Although its European competitors have traditionally been sufficiently well hedged against volatile oil prices, Ryanair has always been unhedged. As of April 2005 the company was not covered by any hedging protection against oil prices however, as of November 2005, Ryanair hedged 90% of its estimated demand for the second half of its fiscal year, at prices corresponding with oil averaging $49 per barrel. Part of the carriers strategy is now to build hedges forward, and its financial prowess means it has the cash position to succeed. (Fiorino, 2005) The companys revenues are also highly dependent upon revenues from the UK and Irish market: historically the company has generated over 50% of total revenues from the UK. For fiscal 2003 and 2004, passengers on Ryanairs routes between Ireland and the UK accounted for 35.9% and 28.6% of total passenger revenues respectively, with Dublin and London accounting for approximately 13.4% and 10.7%, respectively. Additionally, total passenger revenues, and the Dublin-London route accounted for approximately 7.6% and 6.0%, respectively. (Datamonitor, 2005) The companys dependence on Ireland and the UK, could significantly impact the companys revenues due to regional factors, and thus although Ryanair is also attempting to increase its market share as a whole, it is specifically attempting to do this into more diverse areas, such as Eastern Europe, in an attempt to reduce its exposure to the demand changes in the UK and Irish market. Conclusion Ryanairs primary business strategy has always been to fly as many passengers at as low a cost as possible (Ryanair, 2006). Despite the fact that passenger numbers are generally not increasingly significantly (Global Market Information Database, 2005) and the fact that Ryanair has been forced to divert some of its resources to hedging, due to market conditions (Fiorino, 2005), this strategy still forms the core of the airlines business model, and is often viewed as the companys core competence (Johnson et al, 2005) Given that revenues, profits and passenger numbers have soared over the past few years, despite the uncertainty in the external environment (Datamonitor, 2005), this analysis concludes that, not only are Ryanairs current strategies hugely successful, but they will continue to be for the foreseeable future.

The Function Of Food Ordering Online

The Function Of Food Ordering Online Food ordering online is becoming a norm for restaurants which offer takeout and delivery orders. Food ordering online is designed as it is cost effective yet an efficient system to satisfy the restaurants needs. The system is also designed for its ultimate flexibility and performance. The customers will be able to access into the company existing website and browse at their menu and select and place their orders on what they desire. Once they have completed their order, the system will either email or fax the customers order to the restaurant. The online ordering system also enables customers to order days beforehand and the system will execute the order at the specified time. The system has been built to handle large amounts of traffic simultaneously to prevent a system overload. This system is also flexible in a way, whereby customers are able to place online orders quickly, with just a click comparing to the tradition where orders were taken through the phone. More time and cost will be saved ordering online as a phone bill is charged according to the time the phone is on the line. The system was used intended to meet the requirements of all of the clients. With the online order system, the company could save on labour cost as less people are needed in operating the website, instead of people operating a restaurant. With the internet, there will be fewer errors on the orders or miscommunication amongst the customers and the person taking orders. Besides, it provides timely service. The software examines all food orders prior to the completion and corrects human errors. Also, with this system, the registration of online guests is utilized to create valuable marketing campaigns. Internet database Online ordering is easy and convenient yet they have more to improve on their online ordering system. It is good that online ordering system has linked the customers information with the database of the system which facilitates the ordering of customers. In addition, customers information could be tracked easily from their database rapidly if they are regular customers. Advantage With the escort in of the 21st century, many people have found out that it is basically easier to purchase items online. This depends on the consumers preferences. Some people feel unsecure buying items online because they cannot have physical touch or sight with the items they wish to buy. In this case, some people prefer to have the pizza straight from the oven when it is served. Online purchasing provides additional customer service. They not only provide goods, but also provide extra services, such as delivery to the destination that they have requested for. Online purchasing eliminates order taking errors. Customers can view the entire menu and all special offers via official website though online. The system records customers orders when purchasing has taken place. Extra services for example like estimated delivery and carryout times are provided to customers. When ordering via online, even during a busy period such as lunch or dinner time, customers would not have a problem in contacting them and placing their orders. The customers just need to order via online and the system will automatically generate and put it on queue. Online ordering records and stores past records of orders made and allows the customers to view them anytime during their online ordering session. These records will store at the database. The biggest advantage to ordering online, that the customer can save a lot of time and effort. Customers can choose to complete their orders within seconds or take their time and finish when they want. There are no time limits for them to complete their orders, thus, customers can take up any amount of time to order. Instead of planning out time in daily schedule to go out and make a purchase, the consumer can instead go to the web-site when they have a free moment at work or at home late at night, and look up the product that the customers are considering to purchase. They view the full menu and can order any combination of food while the prices are displayed and calculated as they go. It is much easier to make large and complex orders online because they have the ability to be patient, consider their options, and calculate different pricing schemes. Consequently, a customer can use that to their advantage and only do businesses with sites that will help put their transactions through quickly and thoroughly. Addition to that, the advantage of online purchasing is the ability to look at products late at night. Even though the stores have closed for the night, customers can place orders for the next day while the web-site still remains available to make purchases. This means that even after a long day at work, and coming home to deal with the family, the customer still have time left to go online and look for the product they want to purchase. The Internet is there is open 24 hours 7 days, and is always willing to wait for customer to come make a purchase. By going online, the customer do not have to worry about the hassles, such as when they decide that it is time to check out, they do not have to waste the extra time queuing in line. By ordering online, the customer can also take advantage of deals that are only offered to online customers, and often find products that wouldnt be available at a walk in store and special offers are given to online customers. In addition, online ordering increases customer visiting the Dominos Pizza official website. It also gains customer satisfaction and loyalty throughout the company. Due to its convenience of online purchasing service, customer purchase frequency also may increase . The company eliminated or reduced labor costs associated with manual order taking due to technology computerize replaced labor usage. For the Domino Pizza Company, the online ordering system accepts both online and traditional coupons to attract more customers. Customers who order on the web tend to order more because they have a menu in front of them. Robert Mackay, Dominos Pizza Marketing Director Customers who order online are proven to order more per order because they dont feel rushed while purchasing, as they often do over the phone. An Online Ordering website guarantees that the message, promotions and add-on offers are communicated to the customers and rely less on employees. Also, time is saved by not having to key the order into the Point Of Sale System. Between that, fewer mistakes occur during online ordering pizza. Online Ordering provides the perfect solution for office lunch orders. Orders can be collected around the office and one person can enter the orders into the website without the hassle of calling it in. They can take their time and get it right. There are several ways in which online food ordering from a restaurant may occur. A restaurant can have its own website with easy features for placing an order for pick-up or delivery. Some add a third option of being able to make reservations. Instead of calling for a delivery, people just access the Internet, head to the restaurant site and make their order. In financial factor, online ordering system increase the efficiency and cost effectiveness of the ordering operations. For the advertisement, it can create easily or upload promotions to the online ordering site. For instance, this system can increase the customers guest check automatically by customer email by suggesting upcoming sells for additional products. Online ordering increases in sales of goods in the Domino Pizza Company. Disadvantages The trend of shopping online, especially ordering pizza online has gradually been significant in the last decade and online sellers are expected to have improvements on the volume of sales after website features and services altered. There is no doubt that the customers can find great deals online and so many different products which may not be even available in regular stores. By the way, there are certain disadvantages of online ordering. Normally when we shop from a regular store, we can go directly to a sales person face-to-face to enquire and clarify our doubts regarding the food we ordering. It is possible that customers would have a wrong idea of what the products and services is about as the customers and the employee cannot deal face-to-face for a clear explanation. The chances of mishandling the package are volatile. There is a possibility that shipping abroad will damage the presentation of the food that customers ordered and the customer realize it after opening it when the package was delivered and that the person delivering it has already left as food could be very fragile. Another disadvantage is that a lot of companies which sells online state that customers have to pay for the shipping and delivery charges depending on the weight of the product the customer orders. Only a few companies with websites offer free shipping services while some companies provides free shipping services only if the customer has a total purchase of prices exceeding a certain amount. The shipment fee charged often is one of the reasons that customers would not like to order goods online as it is more expensive and does not guarantee that the goods delivered will be in good shape. However, a company must consider on the target market they would like to focus on promoting their products and services to. The elderly are most unlikely to order goods online due to their knowledge of operating a computer. Therefore, if the target market includes the elderly, a traditional service has to be provided to them. Online connectivity issues are the greatest disadvantage for online ordering. The customers add items in online shopping cart, enter information and press submit. The confirmation screen might time out when the internet has an unstable connection. The online customers would not know whether the order has been made or not while reloading the page may cause several billing or several orders. Moreover, customers may also make human errors, such as ordering the incorrect item. This can occur when the customer attempts to place an order. The customer may have accidentally clicked on the wrong item while placing their orders through the website. Even if the consumer clicks on the correct product and provides an accurate product number there may still be mistake made in the ordering process if there are options associated with the item. This problem can be rather disturbing because the consumer will get agitated when the incorrect item is received and therefore, loses customers loyalty towards the company. Another disadvantage is that purchasing online would mean that personal information has to be given to the company when purchasing is taken place. Some companies take advantage of this feature. By purchasing on the Internet, the customer would have to take the risk of having their information taken by online companies and misused. Though this is a very rare occurrence, it is more likely to happen online, than in person. To avoid personal information from being exposed, customers would usually look for a trustable company to purchase goods from. More often, what people dislike about online purchasing is that delivery services are only restricted to certain areas. As a result, people living in rural areas are at a disadvantage whereby they will need to go to the destination whereby the company is able to deliver.

tom :: essays research papers

The Prince What is Machiavelli's view of human nature? While reading The Prince, I have come to a conclusion that Machiavelli demonstrates a view of governing a state that is so different from that of humanists of his time thought. The humanists of Machiavelli's time believed that an individual had a lot to offer to the well being of the state and should be able to help in whatever way necessary. Humanists also believed that an individual grew to maturity through participation in the state and understanding in what was taking place in the state. Machiavelli strongly promoted a secular society and felt morality was not necessary but in fact stood in the way of an effectively governed principality. Machiavelli believes the ruling Prince should be the sole authority determining every aspect of the state and put in effect a policy which would serve his best interests. These interests dealt with gaining and expanding his political power. In other words, he felt the best and appropriate w ay to live was how the prince wanted us to live. Just to point this out (so I get the whole 2.5 this time) Machiavelli did not feel that a Prince should mistreat the citizens. Machiavelli goes on to talk about honor and how one can gain such an element (hanging out with me and Derek will help out, but then again, we weren't around during that time). He suggests that a prince must be readily willing to deceive the citizens, afterall, he is the head honcho. Machiavelli also brings up the point that a prince must also deceive those who attempt to make him feel good (Maybe because they were trying to take advantage of him). As I stated previously, he promotes a secular form of politics. His views were to the benefit of the prince, in helping him maintain power rather than to serve to the well being of the citizens.

Analysis of Henrik Isbens A Dolls House :: A Dolls House Essays

Act I Analysis: Act I, in the tradition of the well made play in which the first act serves as an exposition, the second an event, and the third an unraveling (though Ibsen diverges from the traditional third act by presenting not an unraveling, but a discussion), establishes the tensions that explode later in the play. Ibsen sets up the Act by first introducing us to the central issue: Nora and her relation to the exterior world (Nora entering with her packages). Nora serves as a symbol for women of the time; women who were thought to be content with the luxuries of modern society with no thought or care of the world in which they lived. Indeed, there is some truth in this (the extent of this is debatable). As the play reveals, Nora does delight in material wealth, having been labeled a spendthrift from an early age. She projects the attitude that money is the key to happiness. By presenting this theme of the relationship between women and their surroundings at the beginning, Ibsen indicates to the reader that this is the most basic and important idea at work in the play. However, it is also clear that Nora's simplistic approach to the world is not entirely her fault. Torvald's treatment of Nora as a small helpless child only contributes to Nora's isolation from reality. Just as Nora relates to the exterior world primarily through material objects, Torvald relates to Nora as an object to be possessed. The question becomes who is more detached from reality? Though Torvald's attitude pervades every word he speaks to Nora, his objectification of her is most evident in his use of animal imagery. He refers to her as his little "lark" and "squirrel"†¹small harmless animals. Similarly, Torvald repeatedly calls Nora his "little one" or "little girl", maintaining the approach of a father rather than husband. Nora is fully dependent on Torvald, from money to diet (the macaroons); and, because she is so sheltered, her perception of the world is romanticized. Nora's skewed vision of the world is most evident in her interactions with Mrs. Linde. Whereas her old school friend is wizened and somber, Nora is impetuous. Her choice to tell Mrs. Linde about her secret seems to be more of a boast of a small child than a thoughtful adult; in fact, Nora only reveals her secret after being called a child by Mrs.

Initial response to Malcolm X and Black Rage Essay

In the essay, Cornel West tries to explain how Malcolm X’s â€Å"Black Rage† articulation wasn’t directed at white americans only, but also to black americans who view their lives and minds through what West describes as â€Å"White lenses†. West also claims that Malcolm X’s idea of â€Å"psychic conversation† would promote blacks to turn that rage to love and appreciation of their own culture and self worth. Another claim West mentions is that the idea of psychic conversation struck fear into black professionals, due to their constant surrounding of white social circles, but at the same time understand the idea precisely for the exact same reason. West compares these kind of individuals to Du Bois’s idea of â€Å"double consciousness†. Blacks living between their own live and whites, never settle in either, yet crave acceptance mainly from whites. ! West also believed that Malcolm X viewed black equality as a farfetched possibility due to the majority of white racists, and black victims of democracy. What interests me the most is that Malcolm X feared cultural hybridity even though he, himself, comes from a hybrid culture. But eventually Malcolm X began to slowly remove that fear after looking into the acceptance of humanity regardless of race, class, or gender in the Islamic regimes of Muslims in the Middle East. In the end of the essay, West thinks that future generations should take Malcolm X’s â€Å"black rage† and â€Å"psychic conversation† as an example of rejection to any sorts of inequality. I strongly agree with West’s idea to follow such examples in order to achieve change in human equality and acceptance.

Case Study Situation Go Fast Essay

Situation Go Fast is a motorcycle manufacturer in the southern United States. Though sales have been steady, profits have declined because of increasing operational costs. The Board of Directors felt a fresh look at the operations side was needed. They developed a 5-year plan to increase operating efficiency and set out to find someone to lead the effort. Four months ago, GO FAST found what they saw as â€Å"the person† to be the new operations director and develop a new operational plan to reduce costs. Jill Jones had an outstanding reputation as operations director for a manufacturer of a closely related product. While she was located in a different state and was happy with her current job and lifestyle, she found the 5-year plan exciting. Besides, the offer was too tempting to refuse. Jill was offered the position, including a substantial increase in salary and benefits. She accepted the job, sold her home, and purchased a home near her new job. Her husband runs an in-home business and her children had adapted well to the new community and schools. She did not have a written contract, but was promised a great future with GO FAST and was given a salary of $90,000 per year. With the economic downturn, sales for this past year were the lowest in five years. The company needs to make drastic cost reductions or it could face bankruptcy. All senior managers agreed to a 25% pay cut. Several other high-paid positions will be eliminated. Among them is Jill Jones’ operations director position. Published by DECA Related Materials. Copyright  © by DECA Inc. No part of this publication may be reproduced for resale without written permission from the publisher. Printed in the United States of America. YOUR CHALLENGE The CFO has been asked by the board of directors to investigate GO FAST’S obligation to Jill Jones. You have been assigned the task of doing research. The board of directors assumes their agreement with Mrs. Jones is â€Å"terminable-at-will† based on the law in the state, and therefore GO FAST has no obligation to her. You will prepare recommendations to be presented to the chief financial officer (CFO). Since the decision is ultimately up to the CFO, your presentation should include, at a minimum: 1. How you expect Jill would react to the board’s hard-line approach. 2. Possible ways to deal with Mrs. Jones’ situation, including the positives and negatives of each. 3. Of these, you are to advise the CFO on the best course of action, and how to present it to Jill. While the financial challenges of the company are not a secret, Jill does not yet know that her position has been targeted for elimination. Your presentation to the CFO will begin in one hour. As part of your research you have pulled a copy of The Fair Debt Collections Practices Act, as well as cases related to this issue (see reference information provided). The information in THIS section is the result of research done specifically for this case situation, and has been given to you to help you prepare your recommendations within the allotted time. The judges will also receive this information, in addition to the Case Study Situation and Your Challenge as presented. BACKGROUND INFORMATION The following information provides background related to this situation. State Employment Law Under state law, employment generally is considered to be at will, terminable by either party at any time. This means that an employer may terminate an employee with or without just cause, in the absence of an agreement limiting the employee’s discharge to just cause or specifying the term of the employment. Even where an employer makes assurances seeming to mean job permanence, such assurances are generally considered mere statements of policy indicating only at-will employment. However, state courts have also held that employee personnel manual provisions, if they meet the requirements for formation of a unilateral contract, may become enforceable as part of a contract of employment. An agreement which includes a promise from one party but not from the other is called a unilateral contract. A unilateral contract is, for example, where an employer promises to pay a certain wage if an employee does a certain task for a certain period of time. The employee’s performance of that task for that time makes him or her entitled to the promised wages. The promise of employment on particular terms of unspecified duration, if presented in the form of an offer and accepted by the employee, will create a binding unilateral contract. These types of actions are referred to as â€Å"promissory estoppel† actions and they provide an exception to the employment-at-will doctrine. In order to constitute a contract, the employer’s personnel policy as set out in the personnel policy handbook must be more than a general statement of policy and must provide reasonably definite terms for a fact finder to interpret and apply in determining whether there has been a breach of the contract arising from that handbook. General statements of policy by an employer do not meet the contractual requirements of an offer. Employees frequently couple claims that certain oral representations constitute an enforceable agreement with assertions that certain actions by the employer create an implied contract to terminate only for good cause. For example, employees often contend that an employer has established a custom and practice such that employees are permitted to continue employment until retirement unless discharged for good and sufficient cause. Such an allegation does not meet the requirement of a definite offer. Similarly, an employer’s commendations and approval of the employee’s performance do not alter the employee’s at-will status. Severance pay is not required by legislation. Where it is provided by an employer or labor agreement, it must not be administrated in a discriminatory manner. Where it is provided, severance pay is considered wages in this state. The method of payment of severance pay may delay the employee’s eligibility for unemployment compensation benefits. Promissory Estoppel The state Supreme Court recognized that, despite the absence of a contract in fact, courts may imply the existence of a contract in law by utilizing the principle of promissory estoppel. The doctrine of promissory estoppel is applicable when: 1. A promise has been made; 2. The promissory reasonably expected to induce action of a definite and substantial character by the promise; 3. The promise in fact induces such action; 4. The circumstances require the enforcement of the promise in order to avoid injustice. An estoppel may arise from a promise of future performance. The doctrine of promissory estoppel is based in a promise which the promisor should reasonably expect to induce action of forbearance of a definite and substantial character on the part of the promise and which induces such action or forbearance and is binding if injustice can be avoided only by enforcement of the promise. Under the theory of promissory estoppel, liability on a contract may ensue even if the detriment incurred by one party is not bargained for where it can be shown that the promisor should reasonably have expected its promise to induce another’s detrimental action. The impairment-of-contract clause in the state’s constitution applies to an implied-in-law obligation created by promissory estoppel. The effect of promissory estoppel is to imply a contract in law where none exists in fact. When a promise is enforced pursuant to the doctrine of promissory estoppel, the remedy granted for the breach may be limited as justice requires; relief may be limited to damages measured by the promise’s reliance. RELATED CASE PRECEDENTS INFORMATION The following information is designed to provide samples of cases that may influence decisions made related to the case situation. The participants must decide what, if any, relevance these Related Case Precedents have on this Case Study Situation. Grouse v. Plan, Inc. (1981) The doctrine of promissory estoppel was applied by the court to grant damages to a pharmacist who accepted a job offer, resigned his current job and declined another job offer in reliance on this offer, but was â€Å"terminated† from his new job before he even had a chance to start it. Plan Inc knew that to accept its offer Grouse would have to resign his employment. Grouse promptly gave notice and informed Plan Inc that he had done so when specifically asked by them. Under these circumstances it would be unjust not to hold Plan Inc to its promise. Gorham v. Optical (1995) Former employee was entitled to reliance damages based on theory of promissory estoppel, where he quit his previous job and declined any renegotiations with previous employer in reliance on promise of new job, and on his first day of employment went through hostile reinterview process that led to his immediate termination. Lewis v. Assurance Society (1986) A promise of employment on particular terms of unspecified duration, if presented in form of an offer and accepted by employee, will create a binding unilateral contract. Pine River v. Mettille (1983) Generally speaking, promise of employment on particular terms of unspecified duration, if in form of an offer, and if accepted by employee, may create binding unilateral contract; offer must be definite in form and must be communicated to the offeree. Goodkind v. University (1988) Whether a proposal by employer is meant to be an offer for a unilateral contract is determined by the outward manifestations of the parties, not by their subjective intentions, and employer’s general statements of policy do not meet the contractual requirements for an offer. Gunderson v. Professionals, Inc. (2001) To overcome the presumption that employment is at will, an employee typically must establish clear and unequivocal language by the employer evidencing an intent to provide job security. General statements about job security, company policy, or an employer’s desire to retain an employee indefinitely are insufficient to overcome the presumption that employment is at will. Spanier v. Bank (1993) Terminated employee failed to show any evidence of offer for long-term employment in definite form so as to be entitled to recover for employer’s breach of implied covenant of good faith and fair dealing as result of his termination, where employee’s claims were based on subjective belief and his own inferences that employer’s commitment to commercial lending business would provide him job security and employer’s statements about developing this new area of business did not constitute long-term employment offer.