Tampa is a major city in, the county seat of, Hillsborough County, United States. It is on the west coast of Florida on Tampa Bay, near the Gulf of Mexico, is the largest city in the Tampa Bay Area; the bay's port is the largest in near downtown's Channel District. Bayshore Boulevard runs along the bay, is east of the historic Hyde Park neighborhood. Today, Tampa is part of the metropolitan area most referred to as the "Tampa Bay Area". For U. S. Census purposes, Tampa is part of the Tampa-St. Petersburg-Clearwater, Florida Metropolitan Statistical Area; the four-county area is composed of 3.1 million residents, making it the second largest metropolitan statistical area in the state, the fourth largest in the Southeastern United States, behind Washington, D. C. Miami, Atlanta; the Greater Tampa Bay area has over 4 million residents and includes the Tampa and Sarasota metro areas. The city had a population of 335,709 at the 2010 census, an estimated population of 385,430 in 2017; the Tampa Bay Partnership and U.
S. Census data showed an average annual growth of 2.47 percent, or a gain of 97,000 residents per year. Between 2000 and 2006, the Greater Tampa Bay Market experienced a combined growth rate of 14.8 percent, growing from 3.4 million to 3.9 million and hitting the 4 million population mark on April 1, 2007. A 2012 estimate shows the Tampa Bay area population to have 4,310,524 people and a 2017 projection of 4,536,854 people. Public Transportation in the area includes. There is the TECO Line Streetcar System; when the pioneer community living near the US Army outpost of Fort Brooke was incorporated in 1849, it was called "Tampa Town", the name was shortened to "Tampa" in 1855. The earliest instance of the name "Tampa", in the form "Tanpa", appears in the memoirs of Hernando de Escalante Fontaneda, who spent 17 years as a captive of the Calusa and traveled through much of peninsular Florida, he described Tanpa as an important Calusa town to the north of the Calusa domain under another chief. Archaeologist Jerald Milanich places the town of Tanpa at the mouth of Charlotte Harbor.
The entrances to Tampa Bay and Charlotte Harbor are obscured by barrier islands, their locations, the names applied to them, were a source of confusion to explorers and map-makers from the 16th century though the 18th century. Bahía Tampa and Bahía de Espíritu Santo were each used, at one time or another, for the modern Tampa Bay and Charlotte Harbor. Tampa Bay was labeled Bahía de Espíritu Santo in the earliest Spanish maps of Florida, but became known as Bahía Tampa as early as 1695. "B. Tampa", corresponding to Tampa Bay, appeared on a British map of 1705, with "Carlos Bay" for Charlotte Harbor to the south, while a 1748 British map had "B. del Spirito Santo" for Tampa Bay, again, "Carlos Bay" to the south. A Spanish map of 1757 renamed Tampa Bay as "San Fernando"; as late as 1774, Bernard Romans called Tampa Bay "Bay of Espiritu Santo", with "Tampa Bay" restricted to the Northwest arm, the northeast arm named "Hillsborough Bay". The name may have come from the Calusa language, or the Timucua language.
Some scholars have compared "Tampa" to "itimpi", which means "close to or nearby" in the Creek language, but its meaning is not known. People from Tampa are known as "Tampans" or "Tampanians". Local authorities consulted by Michael Kruse of the Tampa Bay Times suggest that "Tampan" was more common, while "Tampanian" became popular when the former term came to be seen as a potential insult. A mix of Cuban and Spanish immigrants began arriving in the late 1800s to found and work in the new communities of Ybor City and West Tampa. By about 1900, these newcomers came to be known as "Tampeños", a term, still sometimes used to refer to their descendants living in the area, to all residents of Tampa inconsiderate of their ethnic background; the shores of Tampa Bay have been inhabited for thousands of years. A variant of the Weeden Island culture developed in the area by about 2000 years ago, with archeological evidence suggesting that these residents relied on the sea for most of their resources, as a vast majority of inhabited sites have been found on or near the shoreline and there is little evidence of farming.
At the time of European contact in the early 16th century, the Safety Harbor culture dominated the area, with indigenous peoples organized into three or four chiefdoms around the shores of the bay. Early Spanish explorers to visit the area interacted extensively with the Tocobaga, whose principal town was located at the northern end of Old Tampa Bay near today's Safety Harbor in Pinellas County. While there is a substantial historical record of the Tocobaga, there is less surviving documentation describing the Pohoy chiefdom, which controlled the area near the mouth of the Hillsborough River near today's downtown Tampa. However, brief mentions by explorers along with surviving artifacts suggest that the Pohoy and other groups that once lived on Tampa Bay had similar cultures and lifestyles as the better-documented Tocobaga. Expeditions led by Pánfilo de Narváez and Hernando de Soto landed near Tampa, but neither conquistador stayed long. There is no natural gold or silver in Florida, the native inhabitants repulsed Spanish attempts to establish a permanent settlement or convert them to Catholicism.
The fighting resulted in a few deaths, but the many more deaths were caused by infectious diseases brought from Europe, which devastated the population of Native Americans across Florida and the entir
In baseball, a number of coaches assist in the smooth functioning of a team. They are assistants to the manager, who determines the lineup and decides how to substitute players during the game. Beyond the manager, more than a half dozen coaches may assist the manager in running the team. Baseball coaches are analogous to assistant coaches in other sports, as the baseball manager is to the head coach. Baseball is unique in that the manager and coaches all wear numbered uniforms similar to those of the players. Notable exceptions to this were Baseball Hall of Fame manager Connie Mack, who always wore a black suit during his 50 years at the helm of the Philadelphia Athletics, Burt Shotton, manager of the Brooklyn Dodgers in the late 1940s, who wore a Dodger 200 cap and a team jacket over street clothes in the dugout. After the widespread adoption of numbered uniforms in the early 1930s, Joe McCarthy, another Hall of Fame manager, wore a full uniform but no number on his back for the remainder of his career.
Coincidentally, all three men retired during or after the same season — 1950. Full-time coaches in professional baseball date to 1909, when John McGraw of the New York Giants engaged Arlie Latham and Wilbert Robinson as coaches. By the 1920s, most Major League teams had two full-time coaches, although the manager doubled as third-base coach and specialists such as pitching coaches were rare. After World War II, most MLB teams listed between three and five coaches on their roster, as managers ran their teams from the dugout full-time, appointed pitching and bullpen coaches to assist them and the baseline coaches. Batting and bench coaches came into vogue during later; because of the proliferation of uniformed coaches in the modern game, by the late 2000s Major League Baseball had restricted the number of uniformed staff to six coaches and one manager during the course of a game. Beginning with the 2013 season, clubs are permitted to employ a seventh uniformed coach, designated the assistant hitting coach, at their own discretion.
The first bench coach in baseball was George Huff, who took that helm for the Illinois Fighting Illini baseball in 1905. More the bench coach is a team's second-in-command; the bench coach serves as an in-game advisor to the manager, offering situational advice, bouncing ideas back and forth in order to assist the manager in making game decisions. If the manager is ejected, suspended, or unable to attend a game for any reason, the bench coach assumes the position of acting manager. If the manager is fired or resigns during the season, it is the bench coach who gets promoted to interim manager; the bench coach's responsibilities include helping to set up the day's practice and stretching routines before a game, as well as coordinating spring training routines and practices. A pitching coach trains teams' pitchers, he advises the manager on the condition of pitchers and their arms, serves as an in-game coach for the pitcher on the mound. When a manager makes a visit to the mound, he is doing so to make a pitching change or to discuss situational defense.
However, to talk about mechanics or how to pitch to a particular batter, the pitching coach is the one who will visit the mound. The pitching coach is a former pitcher. One exception is Dave Duncan, the former pitching coach of the St. Louis Cardinals, a catcher. Prior to the early 1950s, pitching coaches were former catchers; the bullpen coach is similar to a pitching coach, but works with relief pitchers in the bullpen. He does not make mound visits, however, as he stays in the bullpen the entire game, working with relievers who are warming up to enter the game; the bullpen coach is either a former pitcher or catcher. A hitting coach, as the name suggests, works with a team's players to improve their hitting techniques and form, he monitors players' swings during the game and over the course of the season, advising them when necessary between at-bats on adjustments to make. He oversees their performance during practices, cage sessions, pre-game batting practice. With the advent of technology, hitting coaches are utilizing video to analyze their hitters along with scouting the opposing pitchers.
Video has allowed hitting coaches to illustrate problem areas in the swing, making the adjustment period quicker for the player being analyzed. This process is called video analysis. Two on-field coaches are present. Stationed in designated coaches' boxes near first and third base, they are appropriately named base coaches—individually, first base coach and third base coach, they assist in the direction of baserunners, help prevent pickoffs, relay signals sent from the manager in the dugout to runners and batters. While the first base coach is responsible for the batter as to whether he stops at first base or not or for a runner on first, the third base coach carries more responsibility, his duties include holding or sending runners rounding second and third bases, as well as having to make critical, split-second decisions about whether to try to score a runner on a hit, accounting for the arm strength of the opposing team's fielder and the speed and position of his baserunner. The bench coach, third base coach, first base coach are assigned additional responsibility for assisting players in specific areas defense.
Common designations include outfield instructor, infield instructor, catching instructor, baserunning instructor. When a coaching staff is assembled, the selection of the first base coach is m
Cal Ripken Sr.
Calvin Edwin Ripken was a coach and manager in Major League Baseball who spent 36 years in the Baltimore Orioles organization as a player and scout. He played in the Orioles' farm system beginning in 1957, served as manager of the parent club, on which his sons Cal Jr. and Billy played. Born near Aberdeen, which he called home throughout his life, Ripken joined the Baltimore Orioles in 1957 as a minor league player, he would spend the next 36 years in the organization as a coach, with only one season and seven games coming as a manager. As a manager in the minor leagues for 13 years, Ripken won 964 games, compiled a 68-101 record managing the Orioles. Several of his students, including Jim Palmer, Eddie Murray, most prominently his son Cal Jr. went on to Hall of Fame careers. He was credited for helping sculpt his team's tradition of excellence known as "The Oriole Way." Ripken was born December 17, 1935, near Aberdeen, Maryland, in a general store his parents, Clara Amelia and Arend Fredrick Ripken, owned three miles south of Aberdeen.
He became involved in baseball as early as 1946, when he served as the batboy for a semipro team his older brother Oliver played for. He attended Aberdeen High School, where he helped the baseball team win three county championships and go undefeated in 1952; as a player, he was a catcher. In the late 1950s, he played and coached soccer, once helping his team win 17 straight games. However, as former teammate J. Robert Hooper recalled, "We couldn't win the championship because Rip was in spring training." The Baltimore Orioles signed Ripken in 1957. The scout who signed him to his first minor league contract, for $150 a month, did not have a pen and had to borrow one from a spectator, he began his 36-year tenure in the organization as the starting catcher for the Phoenix Stars of the Class C Arizona–Mexico League. Ripken recalled, "At Phoenix, my manager was Bob Hooper, who pitched, he was a great teacher and threw the best stiff-wrist slider I saw. Bob used so much resin that after a game when I'd congratulate him, our hands would stick together."
Next year, he was promoted to the Wilson Tobs of the Class B Carolina League, where he played 118 games. In 1959, he split the season between the Pensacola Dons of the Class D Alabama–Florida League and the Amarillo Gold Sox of the Texas League. Most of his playing time came in 61 games with Pensecola. Ripken spent 1960 with the Fox Cities Foxes of the Class B Illinois–Indiana–Iowa League, known as the Three-I League, he had his best season that year, batting a career-high.281 with 100 hits, nine home runs, 74 RBI. Earl Weaver a Hall of Fame manager for the Orioles but manager of Fox Cities in 1960, recalled, "He was hitting over.300 until our team bus driver quit and Cal started doing his job, too. The 15-hour bus trips were strenuous work, but Rip always was hard as nails -- toughness personified." During spring training in 1961, he suffered an injury. Initial X-rays showed nothing, but three months into the season it was discovered that Ripken had a dislocated shoulder, an atrophied deltoid muscle, a tendon problem.
He continued to play, but the injury was one which would take years to recover from, his son, Cal Jr. wrote, "Practically speaking, if my father wanted to stay in the game he'd have to shift his sights from playing to coaching and managing." He played with three teams in 1961: the Class D Leesburg Orioles of the Florida State League, the Double-A Little Rock Travelers of the Southern Association, the Triple-A Rochester Red Wings of the International League. The stint with Rochester came, he appeared in 58 games with the Class D Appleton Foxes in 1962, played his final games in 1964, when made two appearances for the Class A Aberdeen Pheasants of the Northern League. As Ripken's playing career wound down, his coaching career began, his first experience as manager came in 1961, when he succeeded Billy DeMars as Leesburg's manager in June. Leesburg folded after the 1961 season. In 1963, at the age of 27, he became a full-time manager with Fox Cities. From 1963 through 1974, he managed Fox Cities, the Tri-City Atoms, the Miami Marlins, the Elmira Pioneers, the Dallas-Fort Worth Spurs, the Asheville Orioles.
As a manager in the minor leagues, Ripken oversaw the development of Jim Palmer, Eddie Murray, Rich Dauer, among other Orioles. In addition to normal coaching duties, he would at times be responsible for driving the team bus, or fixing it. During 1969–70, managing a Triple-A team, he would conduct baseball clinics for the Red Wings players. Cal Jr. would always listen to these. Although Ripken always considered Aberdeen, his home during this period, he and his family lived all over the country as he moved from city to city. In 1975, Ripken served as a scout for the Orioles. In 1976, Ripken reached the major leagues when the Orioles named him their bullpen coach. Halfway through 1977, he became the third base coach for the Orioles when Billy Hunter was hired to be the manager of the Texas Rangers. Ripken served in this role through the 1986 season. During this time, later when he became a manager, he would pitch batting practice and hit fungoes before games, he would be one of the last members of the team to leave after games.
Ripken could be tough on the players he c
Florida is the southernmost contiguous state in the United States. The state is bordered to the west by the Gulf of Mexico, to the northwest by Alabama, to the north by Georgia, to the east by the Atlantic Ocean, to the south by the Straits of Florida. Florida is the 22nd-most extensive, the 3rd-most populous, the 8th-most densely populated of the U. S. states. Jacksonville is the most populous municipality in the state and the largest city by area in the contiguous United States; the Miami metropolitan area is Florida's most populous urban area. Tallahassee is the state's capital. Florida's $1.0 trillion economy is the fourth largest in the United States. If it were a country, Florida would be the 16th largest economy in the world, the 58th most populous as of 2018. In 2017, Florida's per capita personal income was ranking 26th in the nation; the unemployment rate in September 2018 was 3.5% and ranked as the 18th in the United States. Florida exports nearly $55 billion in goods made in the 8th highest among all states.
The Miami Metropolitan Area is by far the largest urban economy in Florida and the 12th largest in the United States with a GDP of $344.9 billion as of 2017. This is more than twice the number of the next metro area, the Tampa Bay Area, which has a GDP of $145.3 billion. Florida is home to 51 of the world's billionaires with most of them residing in South Florida; the first European contact was made in 1513 by Spanish explorer Juan Ponce de León, who called it la Florida upon landing there in the Easter season, known in Spanish as Pascua Florida. Florida was a challenge for the European colonial powers before it gained statehood in the United States in 1845, it was a principal location of the Seminole Wars against the Native Americans, racial segregation after the American Civil War. Today, Florida is distinctive for its large Cuban expatriate community and high population growth, as well as for its increasing environmental issues; the state's economy relies on tourism and transportation, which developed in the late 19th century.
Florida is renowned for amusement parks, orange crops, winter vegetables, the Kennedy Space Center, as a popular destination for retirees. Florida is the flattest state in the United States. Lake Okeechobee is the largest freshwater lake in the U. S. state of Florida. Florida's close proximity to the ocean influences many aspects of daily life. Florida is a reflection of multiple inheritance. Florida has attracted many writers such as Marjorie Kinnan Rawlings, Ernest Hemingway and Tennessee Williams, continues to attract celebrities and athletes, it is internationally known for golf, auto racing, water sports. Several beaches in Florida have emerald-colored coastal waters. About two-thirds of Florida occupies a peninsula between the Gulf of the Atlantic Ocean. Florida has the longest coastline in the contiguous United States 1,350 miles, not including the contribution of the many barrier islands. Florida has a total of 4,510 islands; this is the second-highest number of islands of any state of the United States.
It is the only state that borders both the Gulf of the Atlantic Ocean. Much of the state is characterized by sedimentary soil. Florida has the lowest high point of any U. S. state. The climate varies from subtropical in the north to tropical in the south; the American alligator, American crocodile, American flamingo, Roseate spoonbill, Florida panther, bottlenose dolphin, manatee can be found in Everglades National Park in the southern part of the state. Along with Hawaii, Florida is one of only two states that has a tropical climate, is the only continental state with either a tropical climate or a coral reef; the Florida Reef is the only living coral barrier reef in the continental United States, the third-largest coral barrier reef system in the world. By the 16th century, the earliest time for which there is a historical record, major Native American groups included the Apalachee of the Florida Panhandle, the Timucua of northern and central Florida, the Ais of the central Atlantic coast, the Tocobaga of the Tampa Bay area, the Calusa of southwest Florida and the Tequesta of the southeastern coast.
Florida was the first region of the continental United States to be visited and settled by Europeans. The earliest known European explorers came with the Spanish conquistador Juan Ponce de León. Ponce de León spotted and landed on the peninsula on April 2, 1513, he named the region Florida. The story that he was searching for the Fountain of Youth is mythical and only appeared long after his death. In May 1539, Conquistador Hernando de Soto skirted the coast of Florida, searching for a deep harbor to land, he described seeing a thick wall of red mangroves spread mile after mile, some reaching as high as 70 feet, with intertwined and elevated roots making landing difficult. The Spanish introduced Christianity, horses, the Castilian language, more to Florida. Spain established several settlements with varying degrees of success. In 1559, Don Tristán de Luna y Arellano established a settlement at present-day Pensacola, making it the first attempted settlement in Florida, but it was abandoned by 1561.
In 1565, the settlement of St. Augustine was established under the leadership of admiral and
The Baltimore Orioles are an American professional baseball team based in Baltimore, Maryland. As one of the American League's eight charter teams in 1901, this particular franchise spent its first year as a major league club in Milwaukee, Wisconsin, as the Milwaukee Brewers before moving to St. Louis, Missouri, to become the St. Louis Browns. After 52 often-beleaguered years in St. Louis, the franchise was purchased in November 1953 by a syndicate of Baltimore business and civic interests led by attorney/civic activist Clarence Miles and Mayor Thomas D'Alesandro Jr; the team's current majority owner is lawyer Peter Angelos. The Orioles adopted their team name in honor of the official state bird of Maryland. Nicknames for the team include the "O's" and the "Birds"; the Orioles experienced their greatest success from 1966 to 1983, when they made six World Series appearances, winning three of them. This era of the club featured several future Hall of Famers who would be inducted representing the Orioles, such as third baseman Brooks Robinson, outfielder Frank Robinson, starting pitcher Jim Palmer, first baseman Eddie Murray, shortstop Cal Ripken Jr. and manager Earl Weaver.
The Orioles have won a total of nine division championships, six pennants, three wild card berths. After suffering a stretch of 14 straight losing seasons from 1998 to 2011, the team qualified for the postseason three times under manager Buck Showalter and general manager Dan Duquette, including a division title and advancement to the American League Championship Series for the first time in 17 years in 2014. However, the 2018 team finished with a franchise-worst record of 47–115, prompting the team to move on from Showalter and Duquette following the season's conclusion; the Orioles' current manager is Brandon Hyde, while Mike Elias serves as general manager and executive vice president. The Orioles are well known for their influential ballpark, Oriole Park at Camden Yards, which opened in 1992 in downtown Baltimore; the modern Orioles franchise can trace its roots back to the original Milwaukee Brewers of the minor Western League, beginning in 1894, when the league reorganized. The Brewers were there when the WL renamed itself the American League in 1900.
At the end of the 1900 season, the American League removed itself from baseball's National Agreement. Two months the AL declared itself a competing major league; as a result of several franchise shifts, the Brewers were one of only two Western League teams that didn't fold, move or get kicked out of the league. In its first game in the American League, the team lost to the Detroit Tigers 14–13 after surrendering a nine-run lead in the 9th inning. To this day, it is a major league record for the biggest deficit overcome that late in the game. In the first American League season in 1901, they finished last with a record of 48–89, its lone Major League season, the team played at Lloyd Street Grounds, between 16th and 18th Streets in Milwaukee. After one year in Milwaukee the club relocated to St Louis, for a while enjoyed some success in the 1920s behind Hall of Fame first baseman George Sisler. However, the team's fortunes declined from on, as playing success and gate receipts instead went to the Browns' own tenants at Sportsman's Park, the National League Cardinals.
During this period the Browns only won one pennant, in the 1944 season stocked with wartime replacement players, lost to the Cardinals in the third and last World Series played in one ballpark. In 1953, with the Browns unable to afford stadium upkeep, owner Bill Veeck sold Sportsman's Park to the Cards and attempted to move the club back to Milwaukee, but this was vetoed by the other Major League owners. Instead, Veeck sold his franchise to a partnership of Baltimore businessmen; the Miles-Krieger -Hoffberger group renamed their new team the Baltimore Orioles soon after taking control of the franchise. The name has a rich history in Baltimore. In 1901, Baltimore and John McGraw were awarded an expansion franchise in the growing American League, naming the team the Orioles. After a battle with Ban Johnson, the Head of the American League in 1902, McGraw took many of the top players including Walter Scott "Steve" Brodie, Dan McGann, Roger Bresnahan, Joe McGinnity to the New York Giants; as an affront to Johnson, McGraw kept the black and orange colors of the New York Giants, which San Francisco wears to this day.
In 1903, the franchise—the remaining players and debts, the corporation—was transferred to New York where they were nicknamed the Highlanders until circa 1912, by which time Yanks or Yankees had taken over as their popular moniker. As a member of the high-minor league level International League, the Orioles competed at what is now known as the AAA level from 1903 to 1953; when Oriole Park burned down in 1944, the team moved to a temporary home, Municipal Stadium, where they won the Junior World Series. Their large postseason crowds caught the attention of the major leagues leading to a new MLB franchise in Baltimore. After starting the 1954 campaign with a two-game split agai
Sporting News Executive of the Year Award
The Sporting News Executive of the Year Award was established in 1936 by Sporting News and is given annually to one executive — including general managers — in Major League Baseball. Listed below in chronological order are the baseball executives chosen as recipients of the TSN Executive of the Year Award. Executive of the Year Award by The Sporting News | Baseball Almanac
A contract is a legally-binding agreement which recognises and governs the rights and duties of the parties to the agreement. A contract is enforceable because it meets the requirements and approval of the law. An agreement involves the exchange of goods, money, or promises of any of those. In the event of breach of contract, the law awards the injured party access to legal remedies such as damages and cancellation. In the Anglo-American common law, formation of a contract requires an offer, consideration, a mutual intent to be bound; each party must have capacity to enter the contract. Although most oral contracts are binding, some types of contracts may require formalities such as being in writing or by deed. In the civil law tradition, contract law is a branch of the law of obligations. At common law, the elements of a contract are offer, intention to create legal relations and legality of both form and content. Not all agreements are contractual, as the parties must be deemed to have an intention to be bound.
A so-called gentlemen's agreement is one, not intended to be enforceable, "binding in honour only". In order for a contract to be formed, the parties must reach mutual assent; this is reached through offer and an acceptance which does not vary the offer's terms, known as the "mirror image rule". An offer is a definite statement of the offeror's willingness to be bound should certain conditions be met. If a purported acceptance does vary the terms of an offer, it is not an acceptance but a counteroffer and, therefore a rejection of the original offer; the Uniform Commercial Code disposes of the mirror image rule in §2-207, although the UCC only governs transactions in goods in the USA. As a court cannot read minds, the intent of the parties is interpreted objectively from the perspective of a reasonable person, as determined in the early English case of Smith v Hughes, it is important to note that where an offer specifies a particular mode of acceptance, only an acceptance communicated via that method will be valid.
Contracts may be unilateral. A bilateral contract is an agreement in which each of the parties to the contract makes a promise or set of promises to each other. For example, in a contract for the sale of a home, the buyer promises to pay the seller $200,000 in exchange for the seller's promise to deliver title to the property; these common contracts take place in the daily flow of commerce transactions, in cases with sophisticated or expensive precedent requirements, which are requirements that must be met for the contract to be fulfilled. Less common are unilateral contracts in which one party makes a promise, but the other side does not promise anything. In these cases, those accepting the offer are not required to communicate their acceptance to the offeror. In a reward contract, for example, a person who has lost a dog could promise a reward if the dog is found, through publication or orally; the payment could be additionally conditioned on the dog being returned alive. Those who learn of the reward are not required to search for the dog, but if someone finds the dog and delivers it, the promisor is required to pay.
In the similar case of advertisements of deals or bargains, a general rule is that these are not contractual offers but an "invitation to treat", but the applicability of this rule is disputed and contains various exceptions. The High Court of Australia stated that the term unilateral contract is "unscientific and misleading". In certain circumstances, an implied contract may be created. A contract is implied in fact if the circumstances imply that parties have reached an agreement though they have not done so expressly. For example, John Smith, a former lawyer may implicitly enter a contract by visiting a doctor and being examined. A contract, implied in law is called a quasi-contract, because it is not in fact a contract. Quantum meruit claims are an example. Where something is advertised in a newspaper or on a poster, the advertisement will not constitute an offer but will instead be an invitation to treat, an indication that one or both parties are prepared to negotiate a deal. An exception arises if the advertisement makes a unilateral promise, such as the offer of a reward, as in the famous case of Carlill v Carbolic Smoke Ball Co, decided in nineteenth-century England.
The company, a pharmaceutical manufacturer, advertised a smoke ball that would, if sniffed "three times daily for two weeks", prevent users from catching the'flu. If the smoke ball failed to prevent'flu, the company promised that they would pay the user £100, adding that they had "deposited £1,000 in the Alliance Bank to show our sincerity in the matter"; when Mrs Carlill sued for the money, the company argued the advert should not be taken as a serious binding offer. Although an invitation to treat cannot be accepted, it should not be ignored, for it may affect the offer. For instance, where an offer is made in response to an invitation to treat, the offer may incorporate the terms of the invitation to treat. If, as in the Boots case, the offer is made by an action without any