* Posts by elsergiovolador

4245 publicly visible posts • joined 27 Apr 2020

Apple might have to pay that €13B EU tax bill after all

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Re: Simple

You have some valid points, but:

The department I work for is cautious about taking these big corporations to court - where the law is imprecise there's the very real possibility the department might lose - potentially setting an unwelcome precedent, and almost certainly copping the legal fees for their fabulously expensive law firm.

As you mentioned IR35, HMRC has no problem dragging small business through courts for years and then losing and making a mess of case law. I don't think you are correct here.

I stand by my point.

The UK government have been too busy passing rules mandating the microchipping of domestic cats, ensuring that company reports are full of garbage about modern slavery or carbon reporting, or passing the cretinously conceived Online Safety Bill, and endless amounts of crap legislation to deliver net zero.

That is another symptom of corruption in the system. Create controversy, so that people don't talk about how big corporations are _allowed_ to avoid paying taxes.

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Re: If criminal law was determined like tax law the prisons would be empty

*criminal*: Look, we built this school here and we are hiring thousands of dealers, so they are not dependent on benefits and coppers have something to do!

*judge*: Aight, off you go mate! Just don't get caught again!

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Re: The mistake the EU made..

Apple that was barely breaking even

Sure :-) Poor Apple...

The decision was based on an Apple that was barely breaking even but which employed thousands of people in Ireland.

If any business employing people could get such a deal. But I guess they don't have some "magic powers" Apple has.

After how many employees hired company can stop paying taxes? Thousands?

Could small business group together and get same deal? After all together they hire thousands as well.

It all smells of brown envelopes and lazy tax man.

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In the UK all you have to say is that you did it *inadvertently* and you can get away with anything.

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Re: The mistake the EU made..

Irish need to get their *organic matter* together.

They put individuals to prison for tax evasion and at the same time look away when big corporations do it involving likely magnitude more money.

LOL

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Re: Simple

The examples cited indeed reveal the stark reality of how multinational corporations manipulate their internal structures, not for legitimate business purposes, but purely to lower their tax bills. This manipulation, whilst often cloaked in the guise of business strategy, is transparently aimed at tax evasion.

Take the scenario where a Chinese manufacturing company shifts from being profit-making to a pure cost centre. This isn't a reflection of genuine business evolution but a calculated move to declare profits in more tax-efficient jurisdictions. Similarly, the Luxembourg web store transforming into just a customer order processor is another manoeuvre to escape tax liabilities. These are not complex business strategies - they are straightforward tax evasion tactics.

Contrary to what some might argue, our existing tax laws are equipped to handle these scenarios. For instance, anti-avoidance rules and transfer pricing guidelines are designed precisely to counter such profit shifting. The real issue lies in the enforcement of these laws. The tax authorities, either due to corrupt practices, insufficient resources, or a lack of political will, fail to clamp down on these transparently artificial arrangements.

If applied with diligence and integrity, the current legal framework can effectively address these tax evasion methods. It's not about the inadequacy of the law but the failure to enforce it rigorously. By allowing these practices to continue unchecked, we're not just losing out on tax revenue - we're also endorsing a system that privileges the wealthy and powerful, eroding public trust in the fairness and integrity of our tax system.

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Re: Simple

No, it's actually quite straightforward. A web store in Luxembourg purchases phones from China for a cost of X and sells them for Y. The profit from this sale, (Y-X), is realised in Luxembourg. Similarly, the Chinese company manufacturing these phones buys materials and incurs costs totalling X, then sells the phones for Y, thus their profit (Y-X) is generated and taxed in China. A US company might purchase specifications from a German firm for Y; the German company's production cost is X, and they pay Z to a Polish engineer, who then pays personal tax in Poland if they are a resident there. The German company declares and pays tax on the profits made from the sale to the US company. If the Chinese company purchases these specifications from the US firm, this expense is included in their cost (X), and the US company would pay tax on the profits from selling these specifications. The reason large corporations often avoid paying taxes is not due to the complexity of the system, but rather a result of corruption and a lack of enforcement.

Companies just declare that the "profit making" parts of rhe supply chain are in the low tax counties and everything else is a loss making subsidiary.

It should be easy for the tax man to deal with that using existing laws, but it is even easier to find an excuse to do nothing.

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Simple

This is really simple stuff. Any expenses that are not legitimate business expenses should be taxed.

It's interesting how governments and their tax officers "struggle" with this.

We even have "Diverted Profit Tax", that for some magical reason is discretionary, as if the big corporations' books were like a garlic to the tax man.

We don't even know how much tax big corporations should be paying. The numbers presented to the public could as well be pulled from the rusty trombone.

Google dragged to UK watchdog over Chrome's upcoming IP address cloaking

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Re: Child protection

We could install cameras in every home. After all, people say they have nothing to hide.

Then publishers could zap someone sneaking out to make a tea during the ad break.

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Stalking

Why not regulator declares that any tracking is stalking and close Google and all other businesses engaging in this.

UK signals legal changes to self-driving vehicle liabilities

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Re: Scepticism

Uh...

autonomous cars will be entirely predictable

The issue is that you can't predict the behaviour of the environment. You the autonomous car is going to work on the basis of if X then Y, well... good luck. It's not going to work.

we might want some additional signals added to autonomous vehicles for communicating with other road users

One thing driving instructor tells you that you should never trust the signals you see on the car and you have to use your instincts to figure out the intention.

Classic example are roundabouts. Drivers tend to give wrong signals all the time, take the exit at the last second or take one they didn't signal they are going to take.

You could probably mitigate some of it if all cars on the round are autonomous and can coordinate with each other, but it's never going to happen.

The stuff about noting hazards and motorway driving are the (relatively) really easy bits.

Nothing easy about motorway. People tend to picture it as a straight road, with wide lanes and nothing going on. Until you get an animal on the road or your tire bursts and many other scenarios you can't do if X then Y for.

The stuff that is hard for autonomous vehicles is things like unconventional road layouts, cones round roadworks, and similar stuff humans find very easy - basically, like Captchas, where we are much better at certain kinds of image recognition.

We currently don't have a system for autonomous driving, so probably the hardest part is to build one, but such technology does not exist yet. Sure you have some systems that pretend they drive autonomously, but it's like trying to have conversation with AI. You can quickly tell, something is "off". Mainly because current systems can't reason - contrary to what brochures for investors say.

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Re: Scepticism

The problem is that the rich people think earth is over populated. If they foist such a dangerous contraption on the pleb, it means it will have an effect of herd thinning.

They just need to wrap it somehow, so it is palatable to the masses.

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Re: Automated driver handover

as the driver has to be continuously alert and in a position to take control.

That is probably going to be extremely frustrating to many people. It's like being a passenger supervising another driver. At least when driving you are doing something that is somewhat exciting and stimulating. Probably sitting in such a car would be an equivalent of watching the paint dry and you need to jump in and remove any fly you notice.

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Re: 38,000 new skilled jobs

That's literally how it works in many places.

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They'll be a personal transport unit that you hire or rent.

Yes, the essential bit of "you will own nothing".

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1985

Looks like the UK is heading towards totalitarian dystopia and self-driving cars is just a thin end of the wedge.

Here is why:

The government could use the pretext of ensuring safety and efficiency in self-driving vehicles to install advanced surveillance systems. These systems could monitor not just traffic conditions but also keep a track of citizens’ movements, associations, and routines.

With the advent of self-driving technology, the government could exert more control over where and when people travel. By requiring mandatory routes or restricting access to certain areas, the government could effectively control population movement under the guise of traffic management or environmental concerns.

Promoting reliance on automated vehicles could lead to a decline in driving skills among the populace, making them more dependent on government-controlled transportation systems. This dependency could be leveraged to control aspects of citizens' lives, such as limiting travel during certain times or to certain locations.

By highlighting the risks of cyber-attacks, the government could enforce strict cybersecurity measures that may include invasive monitoring of personal devices and communications under the pretext of national security.

The government could exploit the vast amounts of data collected through self-driving vehicles for commercial gain or political manipulation. This could include selling data to third parties (as they do with NHS now) or using it to manipulate public opinion and electoral outcomes.

By controlling the rollout and access to self-driving technology, the government could create a divide in society – those who have access to the latest technology and those who do not. This could lead to social stratification and increased control over the privileged class.

With self-driving vehicles being highly dependent on software and remote control systems, a government with nefarious intentions could theoretically gain access to these systems. This access could be used to remotely control vehicles, directing them to crash at high speeds, making it appear as an accident. Such a method of targeting opponents would offer the government plausible deniability, as vehicle crashes can often be attributed to mechanical failures or errors in the self-driving system, rather than foul play. This tactic could be used selectively and covertly against key political opponents, journalists, activists, or anyone deemed a threat to the regime. The randomness and apparent non-connection of these accidents could make it difficult to trace back to the government. People raising concerns could be dismissed as conspiracy theorists etc. using the usual methods.

Google, Amazon among big names in tech axing jobs this week

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Loyalty

Never make the mistake of thinking that a corporation cares about you.

Do only as much work as is necessary.

In fact, do as little as you can without repercussions.

The moment the spreadsheet indicates you are surplus to requirements, you'll be dismissed, and no one will remember any sacrifices you've made.

Microsoft hits Alt+F4 on internal ChatGPT access over security jitters, irony ensues

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The old fogies and the techs realised that, within seconds of receiving the request, but the other people were still on the "Yes, but it's Microsoft" and "Other places are doing it" etc. bandwagons.

Convenience will prevail, so these type of worries are purely academic.

People will choose the path of least resistance and most already think that big corporations know everything about them, so why bother.

Now imagine when things pop up like "How did you make that hiring decision? What data on my client did you have and how was that processed and by whom?" and now you a potential timebomb on your hands.

These regulations are not designed to help candidates, but to keep competition at bay. Smaller businesses get all swamped with regulatory nonsense and the big ones can navigate with ease. If small business makes a mistake, often it means bankruptcy whereas for the big one, it's merely an exchange of a few brown envelopes and a small fine.

In the end, business will always hire who they want and need.

Want a well-paid job in tech? You just need to become a cloud-native god

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Re: Someone Else's Computer certification

Yes, a single dedicated server could typically serve millions of users without breaking sweat. That provided your services are not doing any stupid things.

However, investors are unlikely to back such a setup, as they often have preconceived notions. They might ask, "What if a marketing campaign is hugely successful and you suddenly gain 100 million users? How will you scale up?" or "What if your server malfunctions?" or "You'll need to employ a full-time dev ops team."

The responses to these concerns are straightforward. Firstly, such a user surge is rare, and if it does occur, there's a chance that your service hasn't been tested in the cloud for such scenario and could fail regardless. Simply adding more machines isn't a solution; your entire application architecture must be designed to handle such a scenario from the beginning. Cloud or not, this requirement doesn't change.

In case of server failure, having a failover system is essential. Setting this up isn't too complex, and cloud systems can fail too, often with less control on your part.

Regarding the need for a dev ops team, even a small team can be more cost-effective than using the cloud.

However, convincing investors to support self-hosting is challenging. They prefer having a third party, like a cloud provider, to hold accountable if things go wrong, rather than their direct investment.

Traffic patterns typically fluctuate, often resembling a sawtooth wave, depending on the service. Therefore, your servers need to be equipped to handle these peak periods.

Apple exec defends 8GB $1,599 MacBook Pro, claims it's like 16GB in a PC

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Re: *Placed*

It's not "a long way". It's very much the same process. Plus the chips are close together so you can do them in one go.

Only issue is that you can't buy new chips that would have balls applied to them, so you have to reball the sourced used chips, which is a bit of pain.

But that's entirely Apple fault.

If you had access to new chips, then it would be very much 5 minute job (excluding disassembly and assembly of the laptop)

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Re: I was gonna say...

What is big today? If it fits on an USB stick then it's not big. These days running 1TB database on a laptop shouldn't raise eyebrows.

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Re: *Placed*

The memory chips are soldered though. Only difference it makes it that they are closer to the CPU, so you have shorter traces and you can achieve higher bandwidth more easily.

But you can definitely desolder the memory and replace it on Mx chips.

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*Placed*

The reference to unified memory refers to the fact that Apple Silicon Macs' memory is placed next to the system-on-chip die within the processor package rather than being soldered to the motherboard or connected using SODIMM modules.

Hmm how do you *place* that memory? Hmm blue-tac? tape? superglue?

No! It's soldered.

Intel's Arun Gupta on open source pragmatism and fanatics

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Misunderstanding

Seems like he has a fundamental misunderstanding of open source.

The mentioned Four Freedoms refer to personal use. For instance:

3. The freedom to redistribute copies so you can help your neighbour.

4. The freedom to distribute copies of your modified versions to others. By doing this you can give the whole community a chance to benefit from your changes. Access to the source code is a precondition for this.

Does not say:

3. The freedom to redistribute copies so you can help your customer.

4. The freedom to sell copies of your modified versions to customer. By doing this you can give the whole target audience a chance to benefit from your changes. Access to the source code is a precondition for this.

Big corporations jumped on the open source bandwagon, because it saves them money on R&D and wages.

I mean for many developers it is just "a hobby", so why pay them, no?

Notice how Gupta doesn't say how to ensure people who contribute to Open Source are compensated fairly and paid royalties.

Nexperia sells Newport Wafer Fab to American chipmaker for $177M

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There are several reasons why EU and UK do that:

- Local businesses may become powerful enough to challenge your authority, particularly if they unite against your rule. Foreign companies, however, are less likely to engage in domestic politics and can be more easily controlled or expelled if necessary. A strong local business sector could finance opposition movements or create centres of power that encourage democratic reforms. By keeping them weak, the government reduces this risk.

- By creating an economy that's heavily reliant on foreign investment and companies, you could prevent the rise of a domestic middle class or powerful entrepreneurs who could push for economic reforms or political changes.

- Immediate gains that come with large foreign investments, such as kickbacks or the ability to embezzle funds.

- Keeping domestic businesses small prevents the accumulation of wealth within the country, maintaining the economic status quo where the government and their close allies hold the majority of the wealth and power.

- Having foreign entities that invest might be used as a form of validation of the government, presenting the illusion of a stable and attractive investment climate to the international community.

- By keeping local businesses from growing, the government ensures that all lucrative resources remain under their direct control or are only accessible to foreign entities that have struck deals with the regime, thereby reinforcing their power.

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Failure

This is another failure of 13 years of Conservative incompetence.

Ruin the economy to the point nobody local wants to have anything to do with business so they cash out.

Google mulled offering paid-for no-logging private Search subscription

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Search

The thing is Google's search today doesn't work.

It resembles abandoned Wordpress instance where you can find more spam, malware than the content you are interested in.

And a ton of adverts that are irrelevant to you shown by broken stalking and targeting algorithm.

Adobe sells fake AI-generated Israel-Hamas war images – then the news ran them as real

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Re: Metadata... yea, that'll solve the problem

And this also requires the readers to read the fine print, which I find many people don't do. It seems to be a lost art these days.

The problem is that real journalism today virtually doesn't exist and reading articles to the last word is a waste of time. "Journalists" have an agenda that is set by the shareholders / owners / spooks and government and they have to keep things in line if they want to keep their jobs or life.

In the grand scheme of things, these "news" are irrelevant to most people anyway. You can't change what's going on, so you might as well free yourself from reading about it.

Monero Project admits thieves stole 6-figure sum from a wallet in mystery breach

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Re: True cryptocurrency

The linked article says the frozen funds were ETH through BTC.

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True cryptocurrency

Monero is a true crypto currency unlike things like Bitcoin.

The reason is that it is not possible to trace coin's transaction history from the chain itself (at least not to my knowledge) and that makes it fungible unlike BTC, where 1 BTC != 1 BTC (nobody wants to touch coins from blacklisted walled, therefore they are worth 0).

So it will be a test for Monero. If they recover the funds by any other mean than theft's good will, then Monero is toast.

Boffins detect direct evidence of atomic oxygen on Venus's day side

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Molecule

Imagine being an oxygen molecule that nobody breathes in, ever.

Such a sad existence.

UK may demand tech world tell it about upcoming security features

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Re: Shirley

No, ˙˙˙ᔭ1˙Ɛ

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Re: High level security features

Have they ever prosecuted this guy Epstain or something clients?

That all you need to know how much they care. It's all about access to business and personal information.

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Re: Starting soon.

It will be an issue for UK banks, as users will rapidly have browsers that are not secure, so a reversion to offline banking will be required - cheque books, paper statements etc.

This is the UK. If someone loses money thanks to that it will be their fault, never a bank's fault.

Foreign companies operating in the UK would not be able to use insecure systems that allowed the UK government to snoop on them, and most software would no longer be available here anyway, so they would have to up sticks and move out.

They will get exemptions for VPNs etc. It's all about brown envelopes coming, these types of legislation.

Privacy will be an issue for things like medical data, if a back door is enforced. The NHS, which isn't that secure as it is, will have to move back to paper records, and it then won't be flogging data to US companies. Unless it pays folk to type it all in from paper records on disconnected systems.

I think it is going to be "It is what it is" and nobody is going to care about privacy anymore. Big pharmaceutical companies are going to love that.

You could still develop next gen tech in the UK

Government could always deploy the nuclear option and create a law that any citizen could be "asked" and couldn't refuse to spy for the government and they wouldn't be able to tell anyone about the request.

This way UK workforce would no longer be trusted worldwide and anything developed here.

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It's probably going to be used by the police to stalk their partners, exes or "love interests".

Wouldn't be surprised if poorly paid police officers sold access as a side gig to burglars or other miscreants.

Add to that, today announced, more powers for police to enter without a warrant, they could probably become burglars themselves. Knowing when people are not home and know that they talked where they hide money or what expensive they bought recently.

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Re: Politicians

It's not about having a clue. We have probably the most corrupt government in history and they just want to know business and personal secrets.

What do they need these for?

Sell IP to foreign states?

Harass undesirable groups?

If only people could learn from history. Even a proposal of Stasi-on-steroids level of surveillance should have people proposing it given P45 and perhaps getting them sectioned.

Wipro: Get back to the office for three days a week or else

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Letter

Dear Team,

In an exuberant celebration of corporate visibility, we are excited to announce a return to the golden age of managerial oversight. Recognizing the immense benefits of in-person collaboration and innovation, we are now taking the next step in our workplace policy evolution and requiring all employees to work from the office three days a week, effective November 15, 2023.

It's not that we don't trust you, but there's something ineffably reassuring about seeing your diligent faces, tirelessly working away in the natural habitat of your designated desks. How else could we possibly ensure it's you delivering those impressive productivity metrics and not your tech-savvy nana?

We strongly believe that in-person interactions are critical to the professional development of our talent as well as to our success in driving ongoing innovation for clients. Plus, let's face it, our managerial staff has been feeling a tad uneasy with all this "remote trust" business. They miss the comforting certainty that only comes from peering over your shoulders to witness creativity bloom in real-time (and ensuring no one has replaced you with a cardboard cutout).

We look forward to welcoming all our employees back to the office. After all, there's nothing quite like the collective sound of typing and mouse-clicking to set a manager's heart at ease.

Warmest Regards,

WeBroke WeWork, WePromise WeFix it: How subleasing giant hopes to survive bankruptcy

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Re: WeWorkFromHome

One time I was looking for private office for some medium term project and the prices I got...

Well, it was cheaper to rent a house and "work from home".

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Purpose

The problem with all these WeWork kind of shops is that their offices are not fit for purpose.

I mean unless you are a shop that needs bums on seats and can scare / manipulate / coerce people into commuting to your office place.

If you do anything else than having people stuck to their laptops or having endless beer soaked meetings, then you are out of luck finding suitable space.

There is very much nothing available for creatives, crafts, light manufacturing, the things many people are passionate about and would love to turn into business.

Their dreams are sentenced to die in a living room (if they are lucky to have access to one), when their house mates are tired of them, and they couldn't find anything else.

Italy seizes from Airbnb $836M in alleged unpaid taxes

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Re: Having worked in Italy indirectly for Guardia di Finanzia

You don't read much about their successes. Probably the first one I hear about.

Aren't the drones simply for creeps to watch the ladies on the yacht as an excuse for "investigation"?

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Pick and choose

Funny how when you seem to be too big to fail you can pick and choose your taxes.

Something that is not available to small business.

Healthy capitalism needs level playing field and something like this would most likely would force small business to fold (even if the were in the right). Is AirBnB going to fold?

US slaps sanctions on accused fave go-to money launderer of Russia's rich

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Re: fave go-to money launderer

any bank?

UK throws millions at scheme to heat homes with waste energy from datacenters

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Re: Think of the rhubarb

Rhubarb

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follow the money

Something SFO and others seem to be incapable of doing.

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Re: Assumptions

by coal-fired power stations or by steelworks uneconomic in a global context.

They work quite well in China. By uneconomic, of course people often mean, that they provide lower profit margin and if people object to moving them to Asia, you can always invoke climate bogeyman. Then out of sight, out of mind, and if you are an exec, you can then afford yet another Yacht, while the pleb is out of jobs.

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Don't ask difficult questions. There is £36 million to spend! Do you want all those directors to starve?

Shock horror – and there goes the network neighborhood

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Re: When checking voltages...

At one company, new programmers had to build their PC for work on their first day.

Company had a utility room with motherboards, CPUs, memory, graphics cards and so on and if something was missing or they liked something else, they could get a company credit card and order anything they wanted online (within reason).

Wouldn't work at larger business though.

YouTube cares less for your privacy than its revenues

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Re: Content providers have to be paid. We get that.

Go back to journalism

Something we now longer have. Especially investigative journalism is very much dead.

Unfortunately a niche nobody wants to fill, but I would happily pay for access to something like this.

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Re: Chrome

I switched to Chrome at the time when Firefox was practically unusable. Bloated, slow, memory hungry. I remember procuring extra memory so that people wouldn't have to wait ages for the pages they need to load, because machines were constantly swapping.

Chrome made life easier. Probably there is still that myth going that Firefox is crap.