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European single market

The European single market, also known as the European internal market or the European common market, is the single market comprising mainly the member states of the European Union (EU). With certain exceptions, it also comprises Iceland, Liechtenstein, Norway (through the Agreement on the European Economic Area), and Switzerland (through sectoral treaties). The single market seeks to guarantee the free movement of goods, capital, services, and people, known collectively as the "four freedoms". This is achieved through common rules and standards that all participating states are legally committed to follow.

Any potential EU accession candidates are required to agree to association agreements with the EU during the negotiation, which must be implemented prior to accession. In addition, through three individual agreements on a Deep and Comprehensive Free Trade Area (DCFTA) with the EU, Georgia, Moldova, and Ukraine have also been granted limited access to the single market in selected sectors. Turkey has access to the free movement of some goods via its membership in the European Union–Turkey Customs Union. The United Kingdom left the European single market on 31 December 2020. An agreement was reached between the UK Government and European Commission to align Northern Ireland on rules for goods with the European single market, to maintain an open border on the island of Ireland.

The market is intended to increase competition, labour specialisation, and economies of scale, allowing goods and factors of production to move to the area where they are most valued, thus improving the efficiency of the allocation of resources. It is also intended to drive economic integration whereby the once separate economies of the member states become integrated within a single EU-wide economy. The creation of the internal market as a seamless, single market is an ongoing process, with the integration of the service industry still containing gaps. According to a 2019 estimate, because of the single market the GDP of member countries is on average 9 percent higher than it would be if tariff and non-tariff restrictions were in place.

History
One of the core objectives of the European Economic Community (EEC) upon its establishment in 1957 was the development of a common market offering free movement of goods, service, people and capital. Free movement of goods was established in principle through the customs union between its then-six member states.

However, the EEC struggled to enforce a single market due to the absence of strong decision-making structures. Because of protectionist attitudes, it was difficult to replace intangible barriers with mutually recognized standards and common regulations.

In the 1980s, when the economy of the EEC began to lag behind the rest of the developed world, Margaret Thatcher sent Lord Cockfield to the Delors Commission to take the initiative to attempt to relaunch the common market. Cockfield wrote and published a White Paper in 1985 identifying 300 measures to be addressed in order to complete a single market. The White Paper was well received and led to the adoption of the Single European Act, a treaty which reformed the decision-making mechanisms of the EEC and set a deadline of 31 December 1992 for the completion of a single market. In the end, it was launched on 1 January 1993.

The new approach, pioneered at the Delors Commission, combined positive and negative integration, relying upon minimum rather than exhaustive harmonisation. Negative integration consists of prohibitions imposed on member states banning discriminatory behaviour and other restrictive practices. Positive integration consists of approximating laws and standards. Especially important (and controversial) in this respect is the adoption of harmonising legislation under Article 114 of the Treaty on the Functioning of the European Union (TFEU).

The commission also relied upon the European Court of Justice's Cassis de Dijon jurisprudence, under which member states were obliged to recognise goods which had been legally produced in another member state, unless the member state could justify the restriction by reference to a mandatory requirement. Harmonisation would only be used to overcome barriers created by trade restrictions which survived the Cassis mandatory requirements test, and to ensure essential standards where there was a risk of a race to the bottom. Thus, harmonisation was largely used to ensure basic health and safety standards were met.

By 1992 about 90% of the issues had been resolved and in the same year the Maastricht Treaty set about to create an Economic and Monetary Union as the next stage of integration. Work on freedom for services took longer, and was the last freedom to be implemented, mainly through the Posting of Workers Directive (adopted in 1996) and the Directive on services in the internal market (adopted in 2006).

In 1997 the Amsterdam Treaty abolished physical barriers across the internal market by incorporating the Schengen Area within the competences of the EU. The Schengen Agreement implements the abolition of border controls between most member states, common rules on visas, and police and judicial co-operation.

The official goal of the Lisbon Treaty was to establish an internal market, which would balance economic growth and price stability, a highly competitive social market economy, aiming at full employment and social progress, and a high level of protection and improvement of the quality of the environment, with also promoting scientific and technological advance. Even as the Lisbon Treaty came into force in 2009, however, some areas pertaining to parts of the four freedoms (especially in the field of services) had not yet been completely opened. Those, along with further work on the economic and monetary union, would see the EU move further to a European Home Market.

Four Freedoms
The "Four Freedoms" of the single market are:
 * Free movement of goods
 * Free movement of capital
 * Freedom to establish and provide services
 * Free movement of labour

Goods
The range of "goods" (or "products") covered by the term "free movement of goods" "is as wide as the range of goods in existence". Goods are only covered if they have economic value, i.e. they can be valued in money and are capable of forming the subject of commercial transactions. Works of art, coins which are no longer in circulation and water are noted as examples of "goods". Fish are goods, but a European Court of Justice ruling in 1999 stated that fishing rights (or fishing permits) are not goods, but a provision of service. The ruling further explains that, both capital and service can be valued in money and are capable of forming the subject of commercial transactions, but they are not goods.

Council Regulation (EC) 2679/98 of 7 December 1998, on the functioning of the internal market in relation to the free movement of goods among the Member States, was aimed at preventing obstacles to the free movement of goods attributable to "action or inaction" by a Member State. The regulation empowered the Commission to request intervention by a Member State when the actions of private individuals were creating an "obstacle" to free movement of goods. A resolution was adopted by the Council and member state government representatives on the same day, under which the member states agreed to take action where necessary to protect the free movement of goods and other freedoms, and to issue public information where there were disruptions, including their efforts to address obstacles to free movement of goods.

Customs duties and taxation
The customs union of the European Union removes customs barriers between member states and operates a common customs policy towards external countries, with the aim "to ensure normal conditions of competition and to remove all restrictions of a fiscal nature capable of hindering the free movement of goods within the Common Market".

Aspects of the EU Customs area extend to a number of non-EU-member states, such as Andorra, Monaco, San Marino and Turkey, under separately negotiated arrangements. The United Kingdom agreed on a trade deal with the European Union on 24 December 2020, which was signed by Prime Minister Boris Johnson on 30 December 2020.

Customs duties
Article 30 of the Treaty on the Functioning of the European Union ("TFEU") prohibits border levies between member states on both European Union Customs Union produce and non-EUCU (third-country) produce. Under Article 29 of the TFEU, customs duty applicable to third country products are levied at the point of entry into EUCU, and once within the EU external border goods may circulate freely between member states.

Under the operation of the Single European Act, customs border controls between member states have been largely abandoned. Physical inspections on imports and exports have been replaced mainly by audit controls and risk analysis.

Charges having equivalent effect to customs duties
Article 30 of the TFEU prohibits not only customs duties but also charges having equivalent effect. The European Court of Justice defined "charge having equivalent effect" in Commission v Italy.

"[A]ny pecuniary charge, however small and whatever its designation and mode of application, which is imposed unilaterally on domestic or foreign goods by reason of the fact that they cross a frontier, and which is not a customs duty in the strict sense, constitutes a charge having an equivalent effect... even if it is not imposed for the benefit of the state, is not discriminatory or protective in effect and if the product on which the charge is imposed is not in competition with any domestic product."

A charge is a customs duty if it is proportionate to the value of the goods; if it is proportionate to the quantity, it is a charge having equivalent effect to a customs duty.

There are three exceptions to the prohibition on charges imposed when goods cross a border, listed in Case 18/87 Commission v Germany. A charge is not a customs duty or charge having equivalent effect if:
 * it relates to a general system of internal dues applied systematically and in accordance with the same criteria to domestic products and imported products alike,
 * if it constitutes payment for a service in fact rendered to the economic operator of a sum in proportion to the service, or
 * subject to certain conditions, if it attaches to inspections carried out to fulfil obligations imposed by Union law.

Taxation
Article 110 of the TFEU provides:

"No Member State shall impose, directly or indirectly, on the products of other member states any internal taxation of any kind in excess of that imposed directly or indirectly on similar domestic products.

Furthermore, no Member State shall impose on the products of other member states any internal taxation of such a nature as to afford indirect protection to other products."

In the taxation of rum case, the ECJ stated that:

"The Court has consistently held that the purpose of Article 90 EC [now Article 110], as a whole, is to ensure the free movement of goods between the member states under normal conditions of competition, by eliminating all forms of protection which might result from the application of discriminatory internal taxation against products from other member states, and to guarantee absolute neutrality of internal taxation as regards competition between domestic and imported products."

Quantitative and equivalent restrictions
Free movement of goods within the European Union is achieved by a customs union and the principle of non-discrimination. The EU manages imports from non-member states, duties between member states are prohibited, and imports circulate freely. In addition under the Treaty on the Functioning of the European Union article 34, 'Quantitative restrictions on imports and all measures having equivalent effect shall be prohibited between Member States'. In Procureur du Roi v Dassonville the Court of Justice held that this rule meant all "trading rules" that are "enacted by Member States" which could hinder trade "directly or indirectly, actually or potentially" would be caught by article 34. This meant that a Belgian law requiring Scotch whisky imports to have a certificate of origin was unlikely to be lawful. It discriminated against parallel importers like Mr Dassonville, who could not get certificates from authorities in France, where they bought the Scotch. This "wide test", to determine what could potentially be an unlawful restriction on trade, applies equally to actions by quasi-government bodies, such as the former "Buy Irish" company that had government appointees.

It also means states can be responsible for private actors. For instance, in Commission v France French farmer vigilantes were continually sabotaging shipments of Spanish strawberries, and even Belgian tomato imports. France was liable for these hindrances to trade because the authorities "manifestly and persistently abstained" from preventing the sabotage. Generally speaking, if a member state has laws or practices that directly discriminate against imports (or exports under TFEU article 35) then it must be justified under article 36, which outlines all of the justifiable instances. The justifications include public morality, policy or security, "protection of health and life of humans, animals or plants", "national treasures" of "artistic, historic or archaeological value" and "industrial and commercial property". In addition, although not clearly listed, environmental protection can justify restrictions on trade as an over-riding requirement derived from TFEU article 11. The Eyssen v Netherlands case from 1981 outlined a disagreement between the science community and the Dutch government whether niacin in cheese posed a public risk. As public risk falls under article 36, meaning that a quantitative restriction can be imposed, it justified the import restriction against the Eyssen cheese company by the Dutch government.

More generally, it has been increasingly acknowledged that fundamental human rights should take priority over all trade rules. So, in Schmidberger v Austria the Court of Justice held that Austria did not infringe article 34 by failing to ban a protest that blocked heavy traffic passing over the A13, Brenner Autobahn, en route to Italy. Although many companies, including Mr Schmidberger's German undertaking, were prevented from trading, the Court of Justice reasoned that freedom of association is one of the "fundamental pillars of a democratic society", against which the free movement of goods had to be balanced, and was probably subordinate. If a member state does appeal to the article 36 justification, the measures it takes have to be applied proportionately. This means the rule must be pursue a legitimate aim and (1) be suitable to achieve the aim, (2) be necessary, so that a less restrictive measure could not achieve the same result, and (3) be reasonable in balancing the interests of free trade with interests in article 36.

Often rules apply to all goods neutrally, but may have a greater practical effect on imports than domestic products. For such "indirect" discriminatory (or "indistinctly applicable") measures the Court of Justice has developed more justifications: either those in article 36, or additional "mandatory" or "overriding" requirements such as consumer protection, improving labour standards, protecting the environment, press diversity, fairness in commerce, and more: the categories are not closed. In the most famous case Rewe-Zentral AG v Bundesmonopol für Branntwein, the Court of Justice found that a German law requiring all spirits and liqueurs (not just imported ones) to have a minimum alcohol content of 25 per cent was contrary to TFEU article 34, because it had a greater negative effect on imports. German liqueurs were over 25 per cent alcohol, but Cassis de Dijon, which Rewe-Zentrale AG wished to import from France, only had 15 to 20 per cent alcohol. The Court of Justice rejected the German government's arguments that the measure proportionately protected public health under TFEU article 36, because stronger beverages were available and adequate labelling would be enough for consumers to understand what they bought. This rule primarily applies to requirements about a product's content or packaging. In Walter Rau Lebensmittelwerke v De Smedt PVBA the Court of Justice found that a Belgian law requiring all margarine to be in cube shaped packages infringed article 34, and was not justified by the pursuit of consumer protection. The argument that Belgians would believe it was butter if it was not cube shaped was disproportionate: it would "considerably exceed the requirements of the object in view" and labelling would protect consumers "just as effectively".

In a 2003 case, Commission v Italy Italian law required that cocoa products that included other vegetable fats could not be labelled as "chocolate". It had to be "chocolate substitute". All Italian chocolate was made from cocoa butter alone, but British, Danish and Irish manufacturers used other vegetable fats. They claimed the law infringed article 34. The Court of Justice held that a low content of vegetable fat did not justify a "chocolate substitute" label. This was derogatory in the consumers' eyes. A "neutral and objective statement" was enough to protect consumers. If member states place considerable obstacles on the use of a product, this can also infringe article 34. So, in a 2009 case, Commission v Italy, the Court of Justice held that an Italian law prohibiting motorcycles or mopeds from pulling trailers infringed article 34. Again, the law applied neutrally to everyone, but disproportionately affected importers, because Italian companies did not make trailers. This was not a product requirement, but the Court reasoned that the prohibition would deter people from buying it: it would have "a considerable influence on the behaviour of consumers" that "affects the access of that product to the market". It would require justification under article 36, or as a mandatory requirement.

In contrast to product requirements or other laws that hinder market access, the Court of Justice developed a presumption that "selling arrangements" would be presumed to not fall into TFEU article 34, if they applied equally to all sellers, and affected them in the same manner in fact. In Keck and Mithouard two importers claimed that their prosecution under a French competition law, which prevented them from selling Picon beer under wholesale price, was unlawful. The aim of the law was to prevent cut throat competition, not to hinder trade. The Court of Justice held, as "in law and in fact" it was an equally applicable "selling arrangement" (not something that alters a product's content ) it was outside the scope of article 34, and so did not need to be justified. Selling arrangements can be held to have an unequal effect "in fact" particularly where traders from another member state are seeking to break into the market, but there are restrictions on advertising and marketing. In Konsumentombudsmannen v De Agostini the Court of Justice reviewed Swedish bans on advertising to children under age 12, and misleading commercials for skin care products. While the bans have remained (justifiable under article 36 or as a mandatory requirement) the Court emphasised that complete marketing bans could be disproportionate if advertising were "the only effective form of promotion enabling [a trader] to penetrate" the market. In Konsumentombudsmannen v Gourmet AB the Court suggested that a total ban for advertising alcohol on the radio, TV and in magazines could fall within article 34 where advertising was the only way for sellers to overcome consumers' "traditional social practices and to local habits and customs" to buy their products, but again the national courts would decide whether it was justified under article 36 to protect public health. Under the Unfair Commercial Practices Directive, the EU harmonised restrictions on restrictions on marketing and advertising, to forbid conduct that distorts average consumer behaviour, is misleading or aggressive, and sets out a list of examples that count as unfair. Increasingly, states have to give mutual recognition to each other's standards of regulation, while the EU has attempted to harmonise minimum ideals of best practice. The attempt to raise standards is hoped to avoid a regulatory "race to the bottom", while allowing consumers access to goods from around the continent.

Capital
Free movement of capital was traditionally seen as the fourth freedom, after goods, workers and persons, services and establishment. The original Treaty of Rome required that restrictions on free capital flows only be removed to the extent necessary for the common market. From the Treaty of Maastricht, now in TFEU article 63, "all restrictions on the movement of capital between the Member States and between Member States and third countries shall be prohibited". This means capital controls of various kinds are prohibited, including limits on buying currency, limits on buying company shares or financial assets, or government approval requirements for foreign investment. By contrast, taxation of capital, including corporate tax, capital gains tax and financial transaction tax, are not affected so long as they do not discriminate by nationality. According to the Capital Movement Directive 1988, Annex I, 13 categories of capital which must move free are covered.

In Baars v Inspecteur der Belastingen Particulieren the Court of Justice held that for investments in companies, the capital rules, rather than freedom of establishment rules, were engaged if an investment did not enable a "definite influence" through shareholder voting or other rights by the investor. That case held a Dutch Wealth Tax Act 1964 unjustifiably exempted Dutch investments, but not Mr Baars' investments in an Irish company, from the tax: the wealth tax, or exemptions, had to be applied equally. On the other hand, TFEU article 65(1) does not prevent taxes that distinguish taxpayers based on their residence or the location of an investment (as taxes commonly focus on a person's actual source of profit) or any measures to prevent tax evasion. Apart from tax cases, largely following from the opinions of Advocate General Maduro, a series of cases held that government owned golden shares were unlawful. In Commission v Germany the Commission claimed the German Volkswagen Act 1960 violated article 63, in that §2(1) restricted any party having voting rights exceeding 20% of the company, and §4(3) allowed a minority of 20% of shares held by the Lower Saxony government to block any decisions. Although this was not an impediment to the actual purchase of shares, or receipt of dividends by any shareholder, the Court of Justice's Grand Chamber agreed that it was disproportionate for the government's stated aim of protecting workers or minority shareholders. Similarly, in Commission v Portugal the Court of Justice held that Portugal infringed free movement of capital by retaining golden shares in Portugal Telecom that enabled disproportionate voting rights, by creating a "deterrent effect on portfolio investments" and reducing "the attractiveness of an investment". This suggested the Court's preference that a government, if it sought public ownership or control, should nationalise in full the desired proportion of a company in line with TFEU article 345.

Capital within the EU may be transferred in any amount from one country to another (except that Greece currently has capital controls restricting outflows, and Cyprus imposed capital controls between 2013 and April 2015). All intra-EU transfers in euro are considered as domestic payments and bear the corresponding domestic transfer costs. This includes all member States of the EU, even those outside the eurozone providing the transactions are carried out in euro. Credit/debit card charging and ATM withdrawals within the Eurozone are also charged as domestic; however, paper-based payment orders, like cheques, have not been standardised so these are still domestic-based. The ECB has also set up a clearing system, TARGET, for large euro transactions.

The final stage of completely free movement of capital was thought to require a single currency and monetary policy, eliminating the transaction costs and fluctuations of currency exchange. Following a Report of the Delors Commission in 1988, the Treaty of Maastricht made economic and monetary union an objective, first by completing the internal market, second by creating a European System of Central Banks to co-ordinate common monetary policy, and third by locking exchange rates and introducing a single currency, the euro. Today, 20 member states have adopted the euro, one is in the process of adopting (Bulgaria), one has determined to opt-out (Denmark) and 5 member states have delayed their accession, particularly since the Eurozone crisis. According to TFEU articles 119 and 127, the objective of the European Central Bank and other central banks ought to be price stability. This has been criticised for apparently being superior to the objective of full employment in the Treaty on European Union article 3.

Within the building on the Investment Plan for Europe, for a closer integration of capital markets, in 2015, the Commission adopted the Action Plan on Building a Capital Markets Union (CMU) setting out a list of key measures to achieve a true single market for capital in Europe, which deepens the existing Banking Union, because this revolves around disintermediated, market-based forms of financing, which should represent an alternative to the traditionally predominant (in Europe) bank-based financing channel. The EU's political and economic context call for strong and competitive capital markets to finance the EU economy. The CMU project is a political signal to strengthen the single market as a project of all 28 Member States, instead of just the Eurozone countries, and sent a strong signal to the UK to remain an active part of the EU, before Brexit.

Services
As well as creating rights for "workers" who generally lack bargaining power in the market, the Treaty on the Functioning of the European Union or TFEU also protects the "freedom of establishment" in article 49, and "freedom to provide services" in article 56.

Establishment
In Gebhard v Consiglio dell’Ordine degli Avvocati e Procuratori di Milano the Court of Justice held that to be "established" means to participate in economic life "on a stable and continuous basis", while providing "services" meant pursuing activity more "on a temporary basis". This meant that a lawyer from Stuttgart, who had set up chambers in Milan and was censured by the Milan Bar Council for not having registered, should claim for breach of establishment freedom, rather than service freedom. However, the requirements to be registered in Milan before being able to practice would be allowed if they were non-discriminatory, "justified by imperative requirements in the general interest" and proportionately applied. All people or entities that engage in economic activity, particularly the self-employed, or "undertakings" such as companies or firms, have a right to set up an enterprise without unjustified restrictions. The Court of Justice has held that both a member state government and a private party can hinder freedom of establishment, so article 49 has both "vertical" and "horizontal" direct effect. In Reyners v Belgium the Court of Justice held that a refusal to admit a lawyer to the Belgian bar because he lacked Belgian nationality was unjustified. TFEU article 49 says states are exempt from infringing others' freedom of establishment when they exercise "official authority", but this did an advocate's work (as opposed to a court's) was not official. By contrast in Commission v Italy the Court of Justice held that a requirement for lawyers in Italy to comply with maximum tariffs unless there was an agreement with a client was not a restriction. The Grand Chamber of the Court of Justice held the commission had not proven that this had any object or effect of limiting practitioners from entering the market. Therefore, there was no prima facie infringement freedom of establishment that needed to be justified.

In regard to companies, the Court of Justice held in R (Daily Mail and General Trust plc) v HM Treasury that member states could restrict a company moving its seat of business, without infringing TFEU article 49. This meant the Daily Mail newspaper's parent company could not avoid tax by shifting its residence to the Netherlands without first settling its tax bills in the UK. The UK did not need to justify its action, as rules on company seats were not yet harmonised. By contrast, in Centros Ltd v Erhversus-og Selkabssyrelsen the Court of Justice found that a UK limited company operating in Denmark could not be required to comply with Denmark's minimum share capital rules. UK law only required £1 of capital to start a company, while Denmark's legislature took the view companies should only be started up if they had 200,000 Danish krone (around €27,000) to protect creditors if the company failed and went insolvent. The Court of Justice held that Denmark's minimum capital law infringed Centros Ltd's freedom of establishment and could not be justified, because a company in the UK could admittedly provide services in Denmark without being established there, and there were less restrictive means of achieving the aim of creditor protection. This approach was criticised as potentially opening the EU to unjustified regulatory competition, and a race to the bottom in standards, like in the US where the state of Delaware attracts most companies and is often argued to have the worst standards of accountability of boards, and low corporate taxes as a result. Similarly in Überseering BV v Nordic Construction GmbH the Court of Justice held that a German court could not deny a Dutch building company the right to enforce a contract in Germany on the basis that it was not validly incorporated in Germany. Although restrictions on freedom of establishment could be justified by creditor protection, labour rights to participate in work, or the public interest in collecting taxes, denial of capacity went too far: it was an "outright negation" of the right of establishment. However, in Cartesio Oktató és Szolgáltató bt the Court of Justice affirmed again that because corporations are created by law, they are in principle subject to any rules for formation that a state of incorporation wishes to impose. This meant that the Hungarian authorities could prevent a company from shifting its central administration to Italy while it still operated and was incorporated in Hungary. Thus, the court draws a distinction between the right of establishment for foreign companies (where restrictions must be justified), and the right of the state to determine conditions for companies incorporated in its territory, although it is not entirely clear why.

Types of service
The "freedom to provide services" under TFEU article 56 applies to people who provide services "for remuneration", especially in commercial or professional activity. For example, in Van Binsbergen v Bestuur van de Bedrijfvereniging voor de Metaalnijverheid a Dutch lawyer moved to Belgium while advising a client in a social security case, and was told he could not continue because Dutch law said only people established in the Netherlands could give legal advice. The Court of Justice held that the freedom to provide services applied, it was directly effective, and the rule was probably unjustified: having an address in the member state would be enough to pursue the legitimate aim of good administration of justice.

Case law states that the treaty provisions relating to the freedom to provide services do not apply in situations where the service, service provider and other relevant facts are confined within a single member state. An early Council Directive from 26 July 1971 included works contracts within the scope of services, and provided for the abolition of restrictions on the freedom to provide services in respect of public works contracts.

The Court of Justice has held that secondary education falls outside the scope of article 56, because usually the state funds it, though higher education does not. Health care generally counts as a service. In Geraets-Smits v Stichting Ziekenfonds Mrs Geraets-Smits claimed she should be reimbursed by Dutch social insurance for the costs of receiving treatment in Germany. The Dutch health authorities regarded the treatment as unnecessary, so she argued this restricted the freedom (of the German health clinic) to provide services. Several governments submitted that hospital services should not be regarded as economic, and should not fall within article 56. But the Court of Justice held that health care was a "service" even though the government (rather than the service recipient) paid for the service. National authorities could be justified in refusing to reimburse patients for medical services abroad if the health care received at home was without undue delay, and it followed "international medical science" on which treatments counted as normal and necessary. The Court requires that the individual circumstances of a patient justify waiting lists, and this is also true in the context of the UK's National Health Service. Aside from public services, another sensitive field of services are those classified as illegal. Josemans v Burgemeester van Maastricht held that the Netherlands' regulation of cannabis consumption, including the prohibitions by some municipalities on tourists (but not Dutch nationals) going to coffee shops, fell outside article 56 altogether. The Court of Justice reasoned that narcotic drugs were controlled in all member states, and so this differed from other cases where prostitution or other quasi-legal activity was subject to restriction.

If an activity does fall within article 56, a restriction can be justified under article 52 or over-riding requirements developed by the Court of Justice. In Alpine Investments BV v Minister van Financiën a business that sold commodities futures (with Merrill Lynch and another banking firm) attempted to challenge a Dutch law prohibiting cold calling customers. The Court of Justice held the Dutch prohibition pursued a legitimate aim to prevent "undesirable developments in securities trading" including protecting the consumer from aggressive sales tactics, thus maintaining confidence in the Dutch markets. In Omega Spielhallen GmbH v Bonn a "laserdrome" business was banned by the Bonn council. It bought fake laser gun services from a UK firm called Pulsar Ltd, but residents had protested against "playing at killing" entertainment. The Court of Justice held that the German constitutional value of human dignity, which underpinned the ban, did count as a justified restriction on the freedom to provide services. In Liga Portuguesa de Futebol v Santa Casa da Misericórdia de Lisboa the Court of Justice also held that the state monopoly on gambling, and a penalty for a Gibraltar firm that had sold internet gambling services, was justified to prevent fraud and gambling where people's views were highly divergent. The ban was proportionate as this was an appropriate and necessary way to tackle the serious problems of fraud that arise over the internet. In the Services Directive a group of justifications were codified in article 16 that the case law has developed.

Digital Single Market
In May 2015 the Juncker Commission announced a plan to reverse the fragmentation of internet shopping and other online services by establishing a Single Digital Market that would cover digital services and goods from e-commerce to parcel delivery rates, uniform telecoms and copyright rules.

People
The free movement of people means EU citizens can move freely between member states for whatever reason (or without any reason) and may reside in any member state they choose if they are not an undue burden on the social welfare system or public safety in their chosen member state. This required reduction of administrative formalities and greater recognition of professional qualifications of other states. Fostering the free movement of people has been a major goal of European integration since the 1950s.

Broadly defined, this freedom enables citizens of one Member State to travel to another, to reside and to work there (permanently or temporarily). The idea behind EU legislation in this field is that citizens from other member states should be treated equally to domestic citizens and should not be discriminated against.

The main provision on the freedom of movement of persons is Article 45 of the TFEU, which prohibits restrictions on the basis of nationality.

Free movement of workers
Since its foundation, the Treaties sought to enable people to pursue their life goals in any country through free movement. Reflecting the economic nature of the project, the European Community originally focused upon free movement of workers: as a "factor of production". However, from the 1970s, this focus shifted towards developing a more "social" Europe. Free movement was increasingly based on "citizenship", so that people had rights to empower them to become economically and socially active, rather than economic activity being a precondition for rights. This means the basic "worker" rights in TFEU article 45 function as a specific expression of the general rights of citizens in TFEU articles 18 to 21. According to the Court of Justice, a "worker" is anybody who is economically active, which includes everyone in an employment relationship, "under the direction of another person" for "remuneration". A job, however, need not be paid in money for someone to be protected as a worker. For example, in Steymann v Staatssecretaris van Justitie, a German man claimed the right to residence in the Netherlands, while he volunteered plumbing and household duties in the Bhagwan community, which provided for everyone's material needs irrespective of their contributions. The Court of Justice held that Mr Steymann was entitled to stay, so long as there was at least an "indirect quid pro quo" for the work he did. Having "worker" status means protection against all forms of discrimination by governments, and employers, in access to employment, tax, and social security rights. By contrast a citizen, who is "any person having the nationality of a Member State" (TFEU article 20(1)), has rights to seek work, vote in local and European elections, but more restricted rights to claim social security. In practice, free movement has become politically contentious as nationalist political parties appear to have utilised concerns about immigrants taking jobs and benefits.

The Free Movement of Workers Regulation articles 1 to 7 set out the main provisions on equal treatment of workers. First, articles 1 to 4 generally require that workers can take up employment, conclude contracts, and not suffer discrimination compared to nationals of the member state. In a famous case, the Belgian Football Association v Bosman, a Belgian footballer named Jean-Marc Bosman claimed that he should be able to transfer from R.F.C. de Liège to USL Dunkerque when his contract finished, regardless of whether Dunkerque could afford to pay Liège the habitual transfer fees. The Court of Justice held "the transfer rules constitute[d] an obstacle to free movement" and were unlawful unless they could be justified in the public interest, but this was unlikely. In Groener v Minister for Education the Court of Justice accepted that a requirement to speak Gaelic to teach in a Dublin design college could be justified as part of the public policy of promoting the Irish language, but only if the measure was not disproportionate. By contrast in Angonese v Cassa di Risparmio di Bolzano SpA a bank in Bolzano, Italy, was not allowed to require Mr Angonese to have a bilingual certificate that could only be obtained in Bolzano. The Court of Justice, giving "horizontal" direct effect to TFEU article 45, reasoned that people from other countries would have little chance of acquiring the certificate, and because it was "impossible to submit proof of the required linguistic knowledge by any other means", the measure was disproportionate. Second, article 7(2) requires equal treatment in respect of tax. In Finanzamt Köln Altstadt v Schumacker the Court of Justice held that it contravened TFEU art 45 to deny tax benefits (e.g. for married couples, and social insurance expense deductions) to a man who worked in Germany, but was resident in Belgium when other German residents got the benefits. By contrast in Weigel v Finanzlandesdirektion für Vorarlberg the Court of Justice rejected Mr Weigel's claim that a re-registration charge upon bringing his car to Austria violated his right to free movement. Although the tax was "likely to have a negative bearing on the decision of migrant workers to exercise their right to freedom of movement", because the charge applied equally to Austrians, in absence of EU legislation on the matter it had to be regarded as justified. Third, people must receive equal treatment regarding "social advantages", although the Court has approved residential qualifying periods. In Hendrix v Employee Insurance Institute the Court of Justice held that a Dutch national was not entitled to continue receiving incapacity benefits when he moved to Belgium, because the benefit was "closely linked to the socio-economic situation" of the Netherlands. Conversely, in Geven v Land Nordrhein-Westfalen the Court of Justice held that a Dutch woman living in the Netherlands, but working between 3 and 14 hours a week in Germany, did not have a right to receive German child benefits, even though the wife of a man who worked full-time in Germany but was resident in Austria could. The general justifications for limiting free movement in TFEU article 45(3) are "public policy, public security or public health", and there is also a general exception in article 45(4) for "employment in the public service".

For workers not citizens of the union but employed in one member state with a work permit, there is not the same freedom of movement within the Union. They need to apply for a new work permit if wanting to work in a different state. A facilitation mechanism for this process is the Van Der Elst visa which gives easier rules should a non-EU worker already in one EU state need to be sent to another, for the same employer, because of a service contract that the employer made with a customer in that other state.

Free movement of citizens
Beyond the right of free movement to work, the EU has increasingly sought to guarantee rights of citizens, and rights simply by being a human being. But although the Court of Justice stated that 'Citizenship is destined to be the fundamental status of nationals of the Member States', political debate remains on who should have access to public services and welfare systems funded by taxation. In 2008, just 8 million people from 500 million EU citizens (1.7 per cent) had in fact exercised rights of free movement, the vast majority of them workers. According to TFEU article 20, citizenship of the EU derives from nationality of a member state. Article 21 confers general rights to free movement in the EU and to reside freely within limits set by legislation. This applies for citizens and their immediate family members. This triggers four main groups of rights: (1) to enter, depart and return, without undue restrictions, (2) to reside, without becoming an unreasonable burden on social assistance, (3) to vote in local and European elections, and (4) the right to equal treatment with nationals of the host state, but for social assistance only after 3 months of residence.

First, article 4 of the Citizens Rights Directive 2004 says every citizen has the right to depart a member state with a valid passport or national identity card. This has historical importance for central and eastern Europe, when the Soviet Union and the Berlin Wall denied its citizens the freedom to leave. Article 5 gives every citizen a right of entry, subject to national border controls. Schengen Area countries (of which Ireland is not included) have abolished the need to show travel documents, and police searches at borders, altogether. These reflect the general principle of free movement in TFEU article 21. Second, article 6 allows every citizen to stay three months in another member state, whether economically active or not. Article 7 allows stays over three months with evidence of "sufficient resources... not to become a burden on the social assistance system". Articles 16 and 17 give a right to permanent residence after 5 years without conditions. Third, TEU article 10(3) requires the right to vote in the local constituencies for the European Parliament wherever a citizen lives.

Fourth, and more debated, article 24 requires that the longer an EU citizen stays in a host state, the more rights they have to access public and welfare services, on the basis of equal treatment. This reflects general principles of equal treatment and citizenship in TFEU articles 18 and 20. In a simple case, in Sala v Freistaat Bayern the Court of Justice held that a Spanish woman who had lived in (Germany) for 25 years and had a baby was entitled to child support, without the need for a residence permit, because Germans did not need one. In Trojani v Centre public d’aide sociale de Bruxelles, a French man who lived in Belgium for two years was entitled to the "minimex" allowance from the state for a minimum living wage. In Grzelczyk v Centre Public d’Aide Sociale d’Ottignes-Louvain-la-Neuve a French student, who had lived in Belgium for three years, was entitled to receive the "minimex" income support for his fourth year of study. Similarly, in R (Bidar) v London Borough of Ealing the Court of Justice held that it was lawful to require a French UCL economics student to have lived in the UK for three years before receiving a student loan, but not that he had to have additional "settled status". Similarly, in Commission v Austria, Austria was not entitled to restrict its university places to Austrian students to avoid "structural, staffing and financial problems" if (mainly German) foreign students applied, unless it proved there was an actual problem. However, in Dano v Jobcenter Leipzig, the Court of Justice held that the German government was entitled to deny child support to a Romanian mother who had lived in Germany for 3 years, but had never worked. Because she lived in Germany for over 3 months, but under 5 years, she had to show evidence of "sufficient resources", since the Court reasoned the right to equal treatment in article 24 within that time depended on lawful residence under article 7.

Schengen Area
Within the Schengen Area, 25 of the EU member states (excluding Cyprus, and Ireland) and the four EFTA members (Iceland, Liechtenstein, Norway, and Switzerland) have abolished physical barriers across the single market by eliminating border controls. In 2015, limited controls were temporarily re-imposed at some internal borders in response to the migrant crisis.

Public sector procurement of goods and services
Public procurement legislation and guidance based on "a set of basic standards for the award of public contracts which are derived directly from the rules and principles of the EC Treaty", relating to the four freedoms, require equal treatment, non-discrimination, mutual recognition, proportionality and transparency to be maintained when purchasing goods and services for EU public sector bodies.

Integration of non-EU states

Only the EU member states are fully part of the European single market, while several other countries and territories have been granted various degrees of participation. The single market has been extended, with exceptions, to Iceland, Liechtenstein, and Norway through the agreement on the European Economic Area (EEA) and to Switzerland through sectoral bilateral and multilateral agreements. The exceptions, where these EFTA states are not bound by EU law, are:

 * the common agricultural policy and the common fisheries policy (although the EEA agreement contains provisions on trade in agricultural and fishery produce);
 * the customs union;
 * the common trade policy;
 * the common foreign and security policy;
 * the field of justice and home affairs (although each EFTA country is part of the Schengen area); and
 * the economic and monetary union (EMU).

Switzerland
Switzerland, a member of EFTA but not of the EEA, participates in the single market with a number of exceptions, as defined by the Switzerland–European Union relations.

Western Balkans
Stabilisation and Association Agreement states have a "comprehensive framework in place to move closer to the EU and to prepare for [their] future participation in the Single Market".

Turkey
Turkey has participated in the European Union–Turkey Customs Union since 1995, which enables it to participate in the free movement of goods (but not of agriculture or services, nor people) with the EU.

Georgia, Moldova, and Ukraine
Through the agreement of the Deep and Comprehensive Free Trade Area (DCFTA), the three post-Soviet countries of Georgia, Moldova, and Ukraine were given access to the "four freedoms" of the EU single market: free movement of goods, services, capital, and people. Movement of people however, is in form of visa free regime for short stay travel, while movement of workers remains within the remit of the EU Member States. The DCFTA is an "example of the integration of a Non-EEA-Member into the EU Single Market".

Northern Ireland
The United Kingdom of Great Britain and Northern Ireland left the European Union at the end of January 2020 and left the single market in December 2020. Under the terms of the Northern Ireland Protocol of the Brexit withdrawal agreement, Northern Ireland remains aligned to the European single market in a limited way to maintain an open border on the island of Ireland. This includes legislation on sanitary and phytosanitary standards for veterinary controls, rules on agricultural production/marketing, VAT and excise in respect of goods, and state aid rules. It also introduces some controls on the flow of goods to Northern Ireland from Great Britain.

Under the terms of the Protocol, the Northern Ireland Assembly has the power by a simple majority to continue or terminate the protocol arrangements. In the event that consent to continue is not given, the arrangements would cease to apply after two years. The Joint Committee would make alternative proposals to the UK and EU to avoid a hard border on the island of Ireland.

Akrotiri and Dhekelia
Akrotiri and Dhekelia, the British Sovereign Base Areas, located on the island of Cyprus, are integral parts of the EU Customs Union, allowing goods to move freely.

Further developments
Since 2015, the European Commission has been aiming to build a single market for energy. and for the defence industry.

On 2 May 2017, the European Commission announced a package of measures intended to enhance the functioning of the single market within the EU:
 * a single digital gateway based on an upgraded Your Europe portal, offering enhanced access to information, assistance services and online procedures throughout the EU
 * Single Market Information Tool (a proposed regulation under which the commission could require EU businesses to provide information in relation to the internal market and related areas where there is a suspicion that businesses are blocking the operation of the single market rules)
 * SOLVIT Action Plan (aiming to reinforce and improve the functioning of the existing SOLVIT network).

New Hanseatic League
The New Hanseatic League is a political grouping of economically like-minded northern European states, established in February 2018, that is pushing for a more developed European single market, particularly in the services sector.

title: European single market


text:
Talk:Will Eisner

Brooklynite?
The article claims that Will Eisner is a Brooklynite, but I'm not really sure about this. Isn't he from the Bronx? His pseduo-historical works all chronicle Bronx neighborhoods (the fictional Dropsie Avenue) and DeWitt Clinton, the high school he attended is in the Bronx as well. Maybe he was born in Brooklyn? I'm not sure, but that is possible. Yet even then I'd think he was more of a Bronx man than a Brooklynite.

Photos
The 2001 photo of Eisner is grainy beyond belief and of such poor quality it in no way belongs in an encyclopedia. And I'm not sure why we have a photograph of a panel of a bunch of people who aren't Will Eisner; that looks like it's just aggrandizement for the panelists. --Tenebrae (talk) 22:49, 9 October 2013 (UTC)
 * True. Google doesn't turn up a lot of free images.  I wonder if there's maybe a photo from an old newspaper somewhere whose copyright hasn't been renewed...
 * The photo of the panelist is taotally gratuitous, and a terrible picture. I've removed it.
 * I've got a couple Eisner bios (Andelman's & Shumacher's), and hope to get to the article sometime, though it's not at the top of my stack of priorities right now. Curly Turkey (gobble) 01:41, 10 October 2013 (UTC)

 * I'm with ya, Curly! --Tenebrae (talk) 16:28, 10 October 2013 (UTC)

license: Creative Commons - Attribution Share-Alike - https://creativecommons.org/licenses/by-sa/4.0/

title: Talk:Will Eisner


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Denver Dynamos

The Denver Dynamos were a soccer team based in Denver that played in the NASL from 1974 to 1975. Their home field was Mile High Stadium. After the 1975 season, they moved to Minnesota and became the Minnesota Kicks.

History
Between the 1973 and 1974 North American Soccer League seasons the league added eight new expansion teams, including one located in Denver. English full-back and NASL veteran Ken Bracewell was hired as player-coach and Oldham Athletic A.F.C. players Andy Lochhead and Ian Wood were brought over on loan. The team lost its first game to the Toronto Metros 3-2 and finished the 1974 season in last place of the Central Division with a record of five wins and fifteen losses. During the season, the Dynamos went 523 minutes without scoring a goal, setting a record that held until the Philadelphia Fury went 524 minutes and 18 seconds without scoring during the 1978 NASL season. Following the season, GM Norman Sutherland announced that Bracewell's contract would not be renewed, effectively firing the head coach. On October 22, 1974, Sutherland, who had played for East Fife F.C. in Scotland and had won the 1968 and 1969 American Soccer League titles as manager of the Washington Darts, was named coach for the 1975 season. However, less than five months later and a week before training camp, Sutherland announced his resignation as both coach and general manager of the organization. Less than a week later, John Young, who had coached the Miami Toros for three seasons, was named head coach and Joe Echelle was named general manager, a position he had held previously for four years with the Dallas Tornado. For the 1975 NASL season, the Dynamos finished in third place of the Central Division with a record of nine wins and thirteen losses. The team played two season at Mile High Stadium, averaging 4,840 fans a game in 1974 and 3,654 during the 1975 season. On November 18, 1975, Jack Crocker announced that a group led by him would be purchasing the club and moving it to Minnesota for the 1976 season, the sale was completed on November 25.

Coaches

 * 🏴 Ken Bracewell 1974
 * 🏴 John Young 1975

Honors
NASL All-Stars
 * 1975: Hugh Fisher (honorable mention)

U.S. Soccer Hall of Fame
 * 2003: Patrick Ntsoelengoe

title: Denver Dynamos


text:
Gabiley

Gabiley (Gabiley, غابيلي), also known as Gebiley, is a city in the Maroodi Jeex region of Somaliland.

Gabiley is located 58 km west of Hargeisa, the capital of Somaliland. It is in the center of the Gabiley district, bounded on the north by the Gulf of Aden, on the west by the Awdal region, on the east by the Hargeisa district, and on the south by the Somali Region of Ethiopia.

History
Gabiley is one of the oldest towns in Somaliland after Zeila, Berbera and Amud. Some stones left behind in the area were believed to have been earmarked for the construction of pyramids. For example Dhagax Gurre situated around 45km northeast of Gabiley and lies about two Hours drive from Hargeisa the paintings are more than 5000 years old.

It comprises several individual painted shelters scattered on a rocky hill. The main shelter has an inclined ceiling which is decorated with an assemblage of bovid figures as well as one giraffe and one anthropomorphic figure. The second most important shelter, which lies at the base of the granite outcrop, is adorned with panels representing sheep (or goats) and a few human figures holding a bow. The colours and the complexity of the paintings are much less striking than those at Las Geel, but they’re interesting nonetheless.

Demographics
The town of Gabiley has a population of around 141,000.

The Gabiley District in which the city is situated is exclusively dominated by people from the Somali ethnic group, with the Jibril Abokor and Abdalla Abokor sub divisions of the Sa'ad Musa subclan of the Habar Awal Isaaq.

Education
Primary schools, Secondary schools and University education is available throughout the district. The smaller communities have their own primary schools. For post-secondary education, Timacade University was opened in 1999 to serve the needs of the town's students. The education system in Gabiley region is growing in a faster pace than most of Somaliland. Gabiley district has many secondary Schools such as Qalax Secondary, Cigaal Schools, and Al-Irshaad Secondary. The Gabiley National Library opened in April 2021 to provide a suitable space for all Gabiley residents and students students to be able to read from the numerous books available.

Healthcare
Gabiley has 6 operating general hospitals. One massive hospital opened in 2010, it provides medical services to the larger region. Gabiley is considered one of the medium-sized district that has a very sufficient medical spacious centers that the population of Gabiley benefits from them and the sustainability of ongoing small private hospitals and clinics have been growing for the last two decades.

In 2016 the municipal government was led by Mahamed-Amiin Omer Abdi who is the current mayor of Gabiley city and the governor of Gabiley region.

Agriculture

Gabiley is the main farm land for Somaliland and produces up to 85% of Somaliland's food supplies. It is known for its agricultural and farming industry, and is where most of Somaliland's crops are produced. Crops grown in the area include apples, oranges, bananas, corn, pears, maize, wheat, barley, beans, lemon, peas, groundnuts, potatoes, tomatoes, onions, garlic, salad and cabbages, broccoli, watermelon, papaya and many other types of fruits and vegetables. Gabiley is considered to be the most fertile region in Somaliland.

Climate
According to Köppen-Geiger system, Gabiley has a hot semi-arid climate (BSh), although it is moderated by altitude. The average annual temperature is 21.4 °C, and the average annual rainfall 489 mm. June is the hottest month of the year with an average of 24.5 °C, whilst January is the coolest with an average of 17.6 °C. The driest month is December, with 2 mm of rain, and the wettest August with 91 mm. There is a difference of 89 mm of rainfall between the driest and wettest months. The variation in annual temperature is around 6.9 C-change.

Notable residents

 * Abdillahi Suldaan Mohammed Timacade, prominent Somali poet during the pre- and post-colonial period from Galooley who conducted public readings in the area. He belongs to the Ali Jibril (Reer Hareed) sub-clan of the Jibril Abokor clan.
 * Mohamed Hasan Abdullahi, former Chief of Staff of Somaliland Armed Forces and SNM General. He belongs to the Ali Jibril (Reer Dalal) sub-clan of the Jibril Abokor clan.
 * Mo Farah, British four-time Olympic gold medalist and the most decorated athlete in British athletics history; belongs to the Muhammed Jibril (Deriyahan) sub-clan of the Jibril Abokor clan.
 * Nuh Ismail Tani, current Chief of Staff of Somaliland Armed Forces. He belongs to the Ali Jibril (Reer Hareed) of the Jibril Abokor clan.
 * John Drysdale, also known as Abbas Idriss, a British-born army officer, diplomat, writer, historian, publisher, and businessman who spent the last years of his life in the city. Most notably, due to his expertise on Somali history and culture, he served as an advisor to UNOSOM II and advocated for a diplomatic resolution to the war raging between UNOSOM II and Mohammed Farah Aidid in 1993. He was also the first ever Caucasian to vote in Somaliland elections.

title: Gabiley


text:
Detroit Cougars (soccer)

The Detroit Cougars were an American professional soccer team based out of Detroit, Michigan that was a charter member of the United Soccer Association (USA) in 1967. When the USA and rival National Professional Soccer League (NPSL) merged in 1968 to form the North American Soccer League (NASL), the team moved to the new league. The Cougars played its home matches at the University of Detroit Stadium for the 1967 USA season and at Tiger Stadium for the 1968 NASL season, except when scheduling conflicts with the Detroit Tigers forced the team to play at the University of Detroit Stadium. The team folded at the conclusion of the 1968 NASL season.

Origins
In 1966 several groups of entrepreneurs were exploring the idea of forming a professional soccer league in United States. One of these groups, United Soccer Association (USA) led by Jack Kent Cooke, selected 12 cities for team locations and a group headed by William Clay Ford, owner of the Detroit Lions, and John Fetzer, owner of the Detroit Tigers, were selected to run the Detroit franchise. The USA originally planned to start play in the spring of 1968; however the rival National Professional Soccer League, which secured a TV contract from CBS, announced it was ready to launch in 1967. Not wanting to let the rival league gain an advantage, the USA decided to launch early. Not having secured any player contracts, the league imported teams from Europe, Brazil, and Uruguay to represent the franchise cities. Northern Irish team Glentoran F.C. was brought over to play as the Cougars with player-coach John Colrain hired to act in the same capacity with the team. Prior to the season, the organization announced that Millwall F.C. center forward player-coach Len Julians was signed to coach the team for the 1968 season.

United Soccer Association 1967
The Cougars opened the season on May 27, 1967, against the Boston Shamrock Rovers in Lynn, Massachusetts, with the match ending in a 1–1 draw. The team's first home match at the University of Detroit Stadium on June 4, 1967, against the Vancouver Royal Canadians drew 11,629 spectators and also ended in a 1–1 draw. The team's match on June 14, 1967, against the Houston Stars, represented by Brazilian team Bangu Atlético Clube, ended 17 minutes before the end of regulation with the Stars winning 2–0 when Houston fullback Luiz Alberto kicked Tommy Jackson in the kidney and police were needed to restore order on the pitch. In late June 1967, Colrain announced he had sidelined himself for the season and would only continue in his capacity as head coach. The Cougars finished the 1967 season in third place of the Eastern Division with a record of 3 wins 6 ties and 3 losses and an average attendance of 5,708.

North American Soccer League 1968
With the merger of the United Soccer Association and the National Professional Soccer League it was announced that Detroit would be one of the 20-teams team play in the North American Soccer League (NASL). Walter Bruce who had been part of the 1967 USA team returned to play for Detroit after helping of Glentoran F.C. win the 1967–68 Irish League title. Prior to the beginning of the season, the Cougars made a tour of the Caribbean, playing friendlies against local teams in Kingston, Jamaica and in Port-au-Prince, Haiti against Cavalier F.C., Violette AC, and Racing CH winning eight games and losing only one. Following the tour, the team signed three Haiti international players Edner Breton, Claude Barthélemy, and Jean-Claude Désir.

The Cougars began the season on the road, with matches against the Atlanta Chiefs on March 30, 1968, and Kansas City Spurs on April 10, 1968, before their first home game against the Vancouver Royals held at the University of Detroit Stadium due to scheduling conflicts with the Detroit Tigers. On August 17, 1968, with the team in last place, Julians resigned and the team named Andre Nagy as the new coach. The Cougars ended the season in last place of the Lakes Division with a record of six wins, four draws and twenty-one losses and averaging 4,266 fans in attendance. Reporting losses of over $1 million during its two seasons of play, the organization folded on September 23, 1968, the first of 12 NASL teams to fold between the 1968 and 1969 seasons.

Legacy
To commemorate the 50th anniversary of Glentoran F.C.'s representing Detroit in the United Soccer Association, local semi-pro side Detroit City FC announced that it would host Glentoran at Keyworth Stadium for an international friendly; City beat the Northern Irish visitors, 1–0.

title: Detroit Cougars (soccer)


text:
Talk:Constructible number

In the table at the end, in the row about trisecting an angle, the"counterexample" does not match the "associated set of numbers", i.e. it is not obviously a counterexample. Could one of the authors correct this?

e^(2πi) / 7 is not constructible, because 7 is not a Fermat prime

This can lead to confusion, because its not a necesarely condition that n should be a fermat prime in order to a regular n-gon to be constructible.

A regular 15-gon is constructible, cause cos(2pi/15) is constructible, but 15 is not a fermat prime

 * You are correct. But 15 is the product of the two Fermat primes 3 and 5. 7 is neither a Fermat prime nor the product of 2^n and one or more Fermat primes (the only known ones being 3, 5, 17, 257 and 65,537). I've edited the main article accordingly. --Glenn L (talk) 05:50, 13 April 2010 (UTC)

Unclear definition
What is a "fixed" coordinate system? Our article on coordinate systems lists many systems. Could we fix the system to bipolar coordinates? Even if we have the standard Cartesian system, how does that impact the rules for what is allowed in construction with Straightjacket & Compassion? And next, what does it mean for a point to be constructible from the axes? It is all very unclear.

Why not simply define a constructible point as a point that can be constructed with S&C, starting from two given distinct points. Then we can define constructible complex numbers as those whose points in the complex plane are constructible when the given starter points are (0,0) and (1,0).

Comments? --Lambiam 13:03, 31 January 2008 (UTC)

The intro isnt that nice i think. those 2 parts should be merged into one :

old: "A point in the Euclidean plane is a constructible point if, given a fixed coordinate system (or a fixed line segment of unit length), the point can be constructed with unruled straightedge and compass. A complex number is a constructible number if its corresponding point in the Euclidean plane is constructible from the usual x- and y-coordinate axes.

It can then be shown that a real number r is constructible if and only if, given a line segment of unit length, a line segment of length |r| can be constructed with compass and straightedge.[1] It can also be shown that a complex number is constructible if and only if its real and imaginary parts are constructible."

isnt "constructible from the usual x- and y-coordinate axes." in the above text a fuzzy term? Note: The above version somehow differentiates between point and number. is that differentiation improtant/necessary? in my opinion both are tied so close together one can/should be aware of it and then treat both as somehow the same object.

New suggestion to improve article: "A point in the Euclidean plane is a constructible point if, given a fixed coordinate system (or a fixed line segment of unit length), the point can be constructed with unruled straightedge and compass. It can be shown that a real number r is constructible if and only if, given a line segment of unit length, a line segment of length |r| can be constructed with compass and straightedge.[1] It can also be shown that a complex number is constructible if and only if its real and imaginary parts are constructible." — Preceding unsigned comment added by 2A02:8108:1A00:3000:94FE:109A:4DE0:2BB2 (talk) 00:19, 27 May 2017 (UTC)

 * This introduction has some real problems. It seems to me to be a mish-mash of synthetic and coordinate geometry. From the synthetic point of view, one doesn't talk about constructible points, but rather constructible lengths since there is no "origin" (a coordinate concept) to relate a point's position to. On the other hand, if you assume coordinate axes then you already have all real number lengths and every point is construcible. I notice that there are no references for this approach and I am willing to assume that it is all OR and needs to be removed. --Bill Cherowitzo (talk) 04:06, 27 May 2017 (UTC)
 * See "Clean-up" section below. --Bill Cherowitzo (talk) 18:55, 28 May 2017 (UTC)

Fourth Root of 2
It's possible that you can construct line ABC which AC=2^(1/4)*AB. 220.255.2.63 (talk) 03:48, 30 October 2011 (UTC)

Other Tools other Numbers
The number 2^(1/3) can be constructed if the ruler is used in a certain way:

http://demonstrations.wolfram.com/ConstructingTheCubeRootOfTwo/

Jan Burse (talk) 22:35, 3 October 2016 (UTC)

meaning of notation in geometric part not clear
In the geometric part it says:

"The geometric definition of a constructible point is as follows. First, for any two distinct points P and Q in the plane, let L(P, Q ) denote the unique line through P and Q, and let C (P, Q ) denote the unique circle with center P, passing through Q. (Note that the order of P and Q matters for the circle.) By convention, L(P, P ) = C (P, P ) = {P }. Then a point Z is constructible from E, F, G and H if either"

I dont get this part:

"...By convention, L(P, P ) = C (P, P ) = {P }. Then a point Z is constructible from E, F, G and H if either"

what does L(P, P ) = C (P, P ) = {P } mean? (Ive never seen such notation. Is L(P, P ) a line connecting P to itself?) Where do the points Z,E,F,G and H suddenly come from? — Preceding unsigned comment added by 2A02:8108:1A00:3000:94FE:109A:4DE0:2BB2 (talk) 00:32, 27 May 2017 (UTC)

 * This is poorly phrased and is probably WP:OR. I'll try to come up with something to replace it with in a few days. --Bill Cherowitzo (talk) 04:10, 27 May 2017 (UTC)
 * See clean-up section below.--Bill Cherowitzo (talk) 18:55, 28 May 2017 (UTC)

thanks --2A02:8108:1A00:3000:D8B3:7D52:4006:188 (talk) 01:46, 16 June 2017 (UTC)

Clean-up
While attempting a clean-up of this page and the introduction of some references I decided to remove the statements about the complex numbers. The extension to the complexes is trivial once one has a coordinate plane and there does not seem to be any advantage to viewing things this way. Also, I could find no references that supported this viewpoint. If I am wrong, or being too harsh, and someone can provide references, I'll be happy to reinsert that material. --Bill Cherowitzo (talk) 18:51, 27 May 2017 (UTC)

I have found a reference for the complex numbers and it seems, the source for most of the problematic parts of this article. I'll add the reference but will reduce the mention of complexes to an aside. Even the source I have doesn't do anything in the complex realm except describe the field extensions in those terms. He needs to restrict to the reals to be compatible with the rest of the literature, so, in keeping with the larger literature, I will stay with the reals and just mention the extension. --Bill Cherowitzo (talk) 18:55, 28 May 2017 (UTC)
 * I thinking keeping the bulk of the complex article free of complex numbers might be good idea, there reason why they nevertheless often occur in sources is probably due to some textbooks base their treatment/description of geometry on the complex number plane.--Kmhkmh (talk) 11:38, 1 June 2017 (UTC)

I've actually found a few more references using the complexes. They are all coming from the algebraic side of things, so I am assuming that some results might be easier to prove in algebraically closed fields. I will look at this more closely as I move on to the section on field extensions. I still see no obvious advantage in describing things using the complexes from the geometric side of this topic, but perhaps my viewpoint will change as I continue to flesh out this article. --Bill Cherowitzo (talk) 15:42, 1 June 2017 (UTC)

More illustrations
I've added illustrations on commons (and an assocaited category) for multiplication, inverse and root construction (one identical to the recently added one and one based on the pythagoras/cathetus theorem).--Kmhkmh (talk) 11:18, 1 June 2017 (UTC)
 * P.S. I added the geometric mean theorem to the existing illustration, that is based on it. It might be also a good idea to mention it in the article's normal text as well as the intercept theorem that can be used for mutliplication and the inverse.--Kmhkmh (talk) 11:22, 1 June 2017 (UTC)

Constructibility of ,cosine or sine, of 2 pi over n
•The powers of two •The Fermat primes, prime numbers that are one plus a power of two •The products of powers of two and any number of distinct Fermat primes.

The second and third bullet points are apart. This does not necessarily mean that one of them is not a particular case of the other. For if we assume "distinct Fermat primes", encompasses one Fermat prime number appearing on its own , then when one Fermat prime number multiplies 2 to the power of 0 , it is a Fermat prime ; which is the condition of the value of n in bullet point two.

Perhaps therefore the use of the word, "distinct" , should be clarified.

Post Script. I have mentioned something similar on the talk page of Constructible polygon.EuclidIncarnated (talk) 23:49, 27 April 2024 (UTC) EuclidIncarnated (talk) 18:11, 26 April 2024 (UTC)

 * I think it is clearer to keep the bullets separated, concise, and under some interpretations overlapping, than to be pedantic and make the text much more WP:TECHNICAL in order to make them unambiguously cover disjoint sets. What is the point of disjointness here? —David Eppstein (talk) 00:12, 28 April 2024 (UTC)
 * There is no real necessity for disjointedness here ; I am not necessarily suggesting we should only have two bullet points. By giving three bullet points it could be misinterpreted that they are all separate conditions. Which could lead to an erogenous interpretation of the word distinct. All I am suggesting is a clearer meaning of the word distinct. I have raised this in Wikipedia talk:WikiProject Mathematics under the section titled "Distinct" definition ; as it is not a problem just to this page. EuclidIncarnated (talk) 14:13, 28 April 2024 (UTC)
 * The problem has been sorted in the Wikipedia talk:WikiProject Mathematics page and there does not seem to be any reason to edit this page, thank you for your contributions. EuclidIncarnated (talk) 18:16, 28 April 2024 (UTC)
 * I suspect that rather than erogenous you meant erroneous. —David Eppstein (talk) 18:47, 28 April 2024 (UTC)
 * Yes I did mean erroneous, thank you for bringing that to my attention ; a very amusing misspelling. EuclidIncarnated (talk) 19:34, 28 April 2024 (UTC)

title: Talk:Constructible number


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User talk:KRIZSAGE

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Detroit Express

The Detroit Express were a soccer team based in suburban Detroit that played in the now defunct North American Soccer League (NASL) from 1978 to 1980. Its home field was the Pontiac Silverdome. The Express were co-owned by Roger Faulkner, Sonny Van Arnem, Gary Lemmen and Jimmy Hill who was also the managing director and chairman of the English club Coventry City. The team was coached by Ken Furphy.

1978
The Express were Detroit's first professional soccer team since the ASL's Detroit Mustangs disbanded in 1973, and the city's first NASL entry since the Detroit Cougars played their last season in 1968. The club made a splash by signing England forward Trevor Francis; he missed the first third of the season (arriving only after the European season ended in May), but still led the team with 22 goals and ten assists in 19 games. The coach's son, forward Keith Furphy, was second in scoring with 11 goals and 12 assists, while David Bradford and Alan Brazil added nine goals each. On July 12, Francis scored five times as the Express slaughtered the San Jose Earthquakes, 10–0, which as of 2021 is still the widest margin of victory in an American major pro soccer match (NASL or MLS). Detroit went on to win the NASL American Conference Central Division title with a 20–10 mark, and Francis had the only tally in a 1–0 defeat of the Philadelphia Fury in the first round of the playoffs. In the second round, the Express split a pair of games with Fort Lauderdale Strikers, but lost the mini-game immediately afterward, 1–0. Despite their on-field success, however, the Express were only mediocre at the box office, with an average attendance of 12,194, good enough for seventh place in the 24-team NASL but less than the league average of 13,084.

1979
Back in England, Francis made history as the first player in the UK to command a £1 million transfer when he was purchased by Nottingham Forest from Birmingham City, despite a bid from Jimmy Hill for Francis to split time between Coventry and the Express in a unique co-ownership agreement. Forest were not keen to allow their new asset to return to the United States, but they relented and Francis returned just past the midway point of the 1979 season. He drew large crowds and contributed 14 goals and 8 assists in 14 games, tying Keith Furphy for the team lead; Ted MacDougall added nine goals and 11 assists. But the Express struggled to a 14–16 season and a third-place finish. They were then swept out of the playoffs 2–0 in the first round by the Tampa Bay Rowdies. Despite the disappointment on the field, attendance improved at the cavernous Pontiac Silverdome, up to 14,058 per match, right around the NASL average of 14,201.

After 1979, though, Trevor Francis would not return to the NASL. Widely recognized as one of the finest forwards to play in the NASL, Francis notched 36 goals with 18 assists in just 33 regular-season matches—which placed him one spot ahead of Pelé on the all time NASL scoring list, despite playing 23 fewer games. (Francis also had three goals and three assists in five playoff games.) He was a first team all-star selection in 1978 and 1979 alongside Franz Beckenbauer, Giorgio Chinaglia, Johan Cruyff, Carlos Alberto and Rodney Marsh and other international greats, and the only Detroit player ever to be selected to the NASL first XI. Francis planned to return to the Silverdome in 1980 in an exhibition match between Nottingham Forest and the Express, but Francis was injured and the match was canceled. Finally, Francis returned to the Express (now in the American Soccer League) in 1981 for an exhibition game against the ASL All-Stars; the All-Stars won, 2–0, in front of 14,500 at the Silverdome.

1979-80
The Express headed indoors that winter to play in the 1979–80 NASL Indoor season. They had competition, as the Major Indoor Soccer League also decided to place a franchise in the Motor City: the Detroit Lightning. The Express managed a 7–5 record, third place in the Eastern Division and a playoff spot; unfortunately, the same Tampa Bay Rowdies that beat Detroit in the outdoor playoffs crushed them in the first round, 12–1, in St. Petersburg. (Tampa Bay would go on to beat Memphis to claim the championship.) Neither of Detroit's indoor soccer teams did much at the box office: The Express drew 3,937 fans per match at the Silverdome, while the Lightning could only manage 3,520 a game at Cobo Hall. (The Lightning would move to San Francisco and then Kansas City.)

1980
Without Francis, the Express slipped to a 14–18 mark, missing the playoffs by a single point (130-129 to the Houston Hurricane) and drawing only 11,198 a game—not all that bad by NASL standards, but not enough to pay the bills, either. Argentinian Pato Margetic was signed to replace Trevor Francis at the forward spot and he led the team with 11 goals and 11 assists. Gary Bannister and Adam Oates added 10 goals each, while Bradford finished with 16 assists. Wearing the number 10 shirt, David Bradford scored 14 goals and had 38 assists in his three years with the Express.

1980-81 and transfer to Washington
The Express' second and last indoor season produced only a 7–11 record, and they missed the playoffs; the Express' last NASL contest was a 7-5 win over the Atlanta Chiefs in front of 5,598 at the Silverdome on February 15. (Their last games under the Express name came the following week, when they played a three-game money-raising tour in Guatemala.) Overall attendance improved to 4,761, a bit below league average and not enough to save the Express. In the spring of 1981, Jimmy Hill won a court battle to move the team to RFK Stadium to become the new Washington Diplomats, replacing the old franchise of that name which had folded. The Express-turned-Diplomats lasted just one season in D.C. before going out of business. Hill reportedly lost $2 million because of the failed venture, prompting his son to claim ''We've lost all the family money. All we have left is our home.''

Later years
The Detroit Express franchise was purchased and retained by local businessman Sonny Van Arnem, who started a new version of the Express in the second division American Soccer League for the 1981 season. The ASL version of the Express won the league title in 1982, but the league folded after the 1983 season. Van Arnem initially expressed enthusiasm for joining the ASL's successor, the United Soccer League, but he backed out of those plans when the league was not sanctioned by the USSF. The team was not able to find a home in another league and disbanded for good in 1984.

George Best also appeared for the Express during a tour of Europe in September 1978. Best played two games in Austria with the Express before the team headed to Switzerland.

In popular culture
In the November 2009 episode of How I Met Your Mother called "Bagpipes", Ted wears an old Detroit Express shirt when trying to complain to his neighbors about their bagpiping.

Mac also wears a Detroit Express shirt in the Season 5 (2009) episode "The Gang Gives Frank an Intervention" of It's Always Sunny in Philadelphia.

Honors
Division titles
 * 1978 Central Division, American Conference

All-Star first team selections
 * 1978 Trevor Francis
 * 1979 Trevor Francis

Indoor All-Stars
 * 1980–81 Pato Margetic

Indoor Soccer Hall of Fame
 * 2014 Slobo Ilijevski
 * 2019 Pato Margetic

title: Detroit Express


text:
Talk:Frankie Hejduk

Untitled
despite the consternation of many fans concerned about his lack of technique This seems POV, given the vagueness of the attribution, and the vagueness of the criticism. Can we do better? Bovlb 17:17, 2005 May 28 (UTC)

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title: Talk:Frankie Hejduk


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User talk:Pgianpy~enwiki

Welcome!

Hello, and welcome to Wikipedia. Thank you for your contributions. I hope you like the place and decide to stay. Here are a few good links for newcomers: I hope you enjoy editing here and being a Wikipedian! By the way, you can sign your name on Talk and vote pages using three tildes, like this: ~~~. Four tildes (~~~~) produces your name and the current date. If you have any questions, see the help pages, add a question to the village pump or ask me on my Talk page. Again, welcome! -- Mgm|(talk) 17:17, May 28, 2005 (UTC)
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User:Pgianpy/Frame
I've removed User::Pgianpy/Frame and Http://it.wikipedia.org/wiki/Utente:Pgianpy/Frame for having faulty punctuation and page titles. Please be more careful how you name a page in the future. User:Pgianpy/Frame (with only one colon) is still accessible. Cheers! Mgm|(talk) 17:17, May 28, 2005 (UTC)

 * I tried to move the site to my Italian account to tranlate it, but I made a mistake. Sorry and thanks for deleting Pgianpy 17:22, 28 May 2005 (UTC)

Your account will be renamed
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Edmonton Drillers (1979–1982)

The Edmonton Drillers were a North American Soccer League team that played both outdoors and indoors from 1979 to 1982, at the peak of the league's success. The team was brought to Edmonton by local entrepreneur and Edmonton Oilers owner Peter Pocklington, after witnessing the strong support for Brian Rice's Edmonton Black Gold team in 1978. Previous to playing in Edmonton, the team was known as the Oakland Stompers, Hartford Bicentennials and Connecticut Bicentennials.

History
Joe Petrone was the Drillers general manager for their entire existence. The Drillers were coached in 1979 and 1980 by Hans Kraay, who brought a number of players with him from the Netherlands. After Kraay, Timo Liekoski took over as coach in 1981, while Patrone would serve as the team's final caretaker coach until the team folded at the end of the 1982 season.

During the outdoor season, the Drillers played their home games at Commonwealth Stadium, but dwindling crowds during the final year saw the team move to much older and smaller Clarke Stadium, which led to even fewer fans attending the games. The Drillers played their two seasons of indoor soccer at Northlands Coliseum and also at Edmonton Gardens. The outdoor team was characterized by a strong defensive style of play, but their indoor style was built upon a run-and-go style of attack. Attendance for the outdoor games ranged greatly from 10,000 in the early stages of the franchise to 4,000 per game in 1982. By comparison, the more successful and profitable indoor games had attendances ranging between 5,000 and 7,000 paying fans per game in 1981 and 1982.

Because the Northlands Coliseum was booked, Game 1 of the 1981 NASL indoor finals was instead played at the slated-for-demolition Edmonton Gardens. On March 2, 1981, the Drillers defeated the Chicago Sting, 9–6, in front of 5,089 fans to lead the series. In Game 2, played five days later, Edmonton came from behind to down the Sting, 5–4, in front of a then-record NASL indoor crowd of 16,257 at Chicago Stadium to sweep the finals and claim the 1981 NASL indoor championship.

Factors leading to collapse
In 1982, costs were skyrocketing for the team as they were with a number of the other NASL franchises. In Edmonton's case in particular, the following have been speculated as factors connected with the team's collapse: poor support by local media; difficulties stemming from a tricky deal with the owners of the Coliseum and Commonwealth Stadium relating to the attendance, concessions and parking at the indoor games; and as admitted by John Colbert, the Drillers' business manager in 1982, a business strategy that consisted a "top-down construction" for the team (i.e., bringing in expensive international players as opposed to developing cheaper local talent).

Honours
Championships (1)
 * NASL indoor: 1980–81

Regular Season/ Division Titles (2)
 * NASL: 1980
 * NASL indoor: 1981–82

NASL All Stars
 * 1980: Peter Nogly -Second Team
 * 1981: Peter Nogly -First Team

NASL indoor MVP
 * 1980–81: Kai Haaskivi

NASL indoor Scoring Champion
 * 1980–81: Kai Haaskivi (co-champion)

NASL indoor Finals MVP
 * 1981–82: Kai Haaskivi

NASL indoor All Stars
 * 1980–81: Drew Ferguson, Kai Haaskivi
 * 1981–82: Jan Goossens, Kai Haaskivi

Canadian Soccer Hall of Fame
 * Mike Sweeney: 2002
 * Bruce Twamley: 2008

Indoor Soccer Hall of Fame
 * Kai Haaskivi: 2013
 * Timo Liekoski: 2019

title: Edmonton Drillers (1979–1982)


text:
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title: MediaWiki:Sorbs create account reason


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Houston Hurricane

The Houston Hurricane was a soccer team based out of Houston that played in the NASL. They played from 1978 to 1980. Their home field was the Astrodome. Their colors were orange, white and red.

History
The team was the last of six expansion teams granted for the 1978 season and had about three months to sign players and sell tickets. Though the coach, Timo Liekoski, who had been an assistant with the Dallas Tornado, was capable, assembling a competitive team in so short a time would be daunting. In any case, the Hurricane placed last in its first season with ten wins of thirty matches (there were no draws in the NASL) and drew a miserable average attendance of 5,806, with only the Chicago Sting and San Diego Sockers drawing less in the 24-team league.

In the 1979 season, the Hurricane produced the second best record in the league, winning the division with 22 wins in thirty matches. Timo Liekoski was awarded Coach of the Year honors. But the Hurricane couldn't replicate those results in the playoffs, losing to the Philadelphia Fury in two straight. Average attendance was better at 6,211 but was still next to last in the league - the worst being Philadelphia. Kyle Rote, Jr. had joined the Hurricane that season, but left the team after the season on a relief mission to Cambodia and later retired from soccer.

The Hurricane didn't do as well in what turned out to be their final season, placing second in the division and again losing in the playoffs versus the Edmonton Drillers. They won fourteen and lost eighteen in the expanded schedule, and attendance fell to 5,818 a match, with only the Atlanta Chiefs and, again, Philadelphia being the only teams with worse gates. The Hurricane's Denver-based owners had had enough, and the team folded in late 1980.

Honors
Regular Season Premiership
 * 1979: runner-up

Division titles
 * 1979: Central Division, American Conference

Coach of the Year
 * 1979: Timo Liekoski

FIFA World Cup players
 * 1966: 🇨🇭 Fritz Künzli

All-Star Selections
 * 1979: Paul Hammond (second team)

Indoor All-Tournament Team
 * 1978: Dale Russell

U.S. Soccer Hall of Fame members
 * 2009: Kyle Rote Jr.

Indoor Soccer Hall of Fame members
 * 2013 Kai Haaskivi
 * 2019 Timo Liekoski

title: Houston Hurricane