Oregon Signee Terrance Kelly Slain

ESPN - Oregon signee and De La Salle star Kelly slain

One of the nation's best high school linebackers was shot to death two days before he was to leave his crime-ridden city for the University of Oregon on an athletic scholarship. Terrance Kelly, 18, was a star linebacker and tight end for De La Salle High School. He was shot in the driver's seat of his car outside his brother's home around 10:30 p.m. Thursday, Richmond Police Sgt. Enos Johnson said Friday. Police found Kelly lying in the street next to his car, shot in the chest. He was pronounced dead at the scene. Police have yet to identify a motive or any suspects, Johnson said.

Kelly was a standout at De La Salle, a Catholic school in a middle-class suburb about 20 miles east of Kelly's east San Francisco Bay neighborhood. He never played in a losing game in his high school career. In fact, the team boasts a 151-game winning streak. Kelly was one of four de la Salle players recruited by the University of Oregon this year and was considered one of the best defensive players in the nation.

On Friday, Kelly's friends and relatives gathered in his neighborhood, remembering him as a role model for younger children, with his desire to excel and his plans for college. "It hurts me to see it come down to this," said Johnny Dempsey, Kelly's cousin. "My son used to get up and see Terrence on the TV and go 'Daddy! There goes T.K.!"' Flowers and balloons were placed outside the school's red brick chapel, where Friday afternoon, instead of practice, the football team's players and coaches held a private memorial service. A public service will be held after school is in session. "It's a shock," said Justin Alumbaugh, De La Salle' linebacker and tight end coach. "He was a young man who was doing everything right. He was an inspiration, he was admired by everybody." Bruce Shoup, De La Salle's president and chief executive, said Kelley was a leader who "exhibited talent, intelligence and care for others besides himself." "He will be remembered as an excellent student, good friend and inspiration for all the boys destined to follow him through school," Shoup said. Kelly was going to leave on Saturday for Eugene, Ore., where news of his slaying hit hard. "It's so senseless and tragic. It's hard to explain," said Oregon head coach Mike Bellotti. "Certainly it's very difficult to begin the season with this type of thing. But the most important people are Terrance's family and friends ... our prayers go to them."

Tragic.

Beltway Traffic Jam

The Friday linkfest:

• Scott Ott covers an unexpected result of yesterday's gay marriage ruling.
• Steven Taylor looks at the economics of stem cell research.
• Dean Esmay has resolved not to let his baby to grow up to be a cowboy.
• Kathy Kinsley is blogging Hurricane Charley.
• Jen speaks for McGreevey's wife.

To join in, link and send a TrackBack to this post. If your blog doesn't automatically generate one, use the Send TrackBack feature below. For more information, see this post.

Video: Egyptian Man Beheaded

AP - Islamic Web site has pictures of beheading

An Islamic Web site posted still pictures Friday that purportedly show Iraqi militants beheading an Egyptian man they claim was spying for the U.S. military. There was no way to verify the authenticity of the images, and there was no record that the man, identified on the Web site as Mohammed Fawzi Abdaal Mutwalli, had been kidnapped. The pictures are apparently stills from a video on the site that could not be accessed. A second Web site, an English-language site that does not appear to have political links, carried the video of the beheading. Neither site gave a date for the killing.

The pictures and video were not connected to a video that emerged Wednesday purporting to show Iraqi militants beheading a man they alleged was a CIA agent. The victim in Wednesday's tape has not been identified.

Rusty Shackleford, who has the still pictures on his site, disagrees, noting, "The pictures strike me as being in the same location as the last Egyptian 'CIA Agent' was murdered." Presuming both are verified, they would also have in common a rather odd departure from the M.O. of the previous beheadings: no orange jump suits and no pre-execution video making demands.

Reports that Mutwalli had been killed first surfaced Wednesday, but Egyptian government officials have not confirmed his death. Mutwalli's family said they had not heard from him for 15 years. Police officials said Mutwalli, 45, went to Iraq in 1986 to work as a car mechanic. He comes from the village of Saqr in Dakahlia province in the Nile Delta, the officials said, speaking on condition of anonymity. His father, Fawzi Mutwalli, a 67-year-old watchman, said he only heard news of his son's purported killing from journalists Thursday. "I have no idea. If he is dead, let me know, and send me his body," he said. He said Egyptian security officials came Thursday to get information about his son but did not confirm the killing. Although the family had not heard from Mutwalli for more than 15 years, the father dismissed suggestions his son could be a spy. Mohammed is not educated. He can't speak English. How can he be a spy?" the elder Mutwalli said Friday.

Can you feel the love?

Until Friday, there had been no evidence of an Arab hostage having been beheaded by Iraqi militants acting for political motives. A Lebanese Muslim hostage, Hussein Alyan, was killed this year, but his kidnappers may have had criminal motives because they made no political demands to spare his life.

The latest images show three masked men standing in front of a banner carrying the name and golden-sun logo of Tawhid and Jihad, the group led by Jordanian militant Abu Musab al-Zarqawi that has claimed responsibility for beheading other hostages in Iraq, including American Nicholas Berg and South Korean translator Kim Sun-il.
The pictures show a man, with a mustache and wearing an Arabic robe, sitting in front of the three masked men with his hands tied behind his back. Captions on the pictures of the hostage say: "From the Arab Republic of Egypt. Mohammed Fawzi Abdaal Mutwalli. I was working as a spy with the Americans in Iraq."

VodkaCandidate

Stephen Green is apparently a candidate for governor of New Jersey. Not that's there's anything wrong with that.

Kerry Decoder

William Saletan sleuths out an actual answer to the question "Would Kerry Vote Today for the Iraq War?" That answer is "No."

Saletan arrives at this answer, which I believe to be correct, by carefully parsing the various statements Kerry has made on the matter in various interviews. While Kerry refuses to answer the question directly, and indeed seems to be trying to communicate that he would, the preconditions that Kerry always sets -- "United Nations, WMD, compliance, process" -- would have precluded going to war.

The fact that Kerry wants to have it both ways on such a critical issue--quite simply, the key issue in the campaign--is telling. Regardless of whether one agrees with President Bush on the war, we at least know where he stands. That's a rather important thing when choosing a commander in chief. Especially during an ongoing war.

News Flash: People With Income Pay Income Taxes

WaPo - Tax Burden Shifts to the Middle

Since 2001, President Bush's tax cuts have shifted federal tax payments from the richest Americans to a wide swath of middle-class families, the Congressional Budget Office has found, a conclusion likely to roil the presidential election campaign.

The CBO study, due to be released today, found that the wealthiest 20 percent, whose incomes averaged $182,700 in 2001, saw their share of federal taxes drop from 64.4 percent of total tax payments in 2001 to 63.5 percent this year. The top 1 percent, earning $1.1 million, saw their share fall to 20.1 percent of the total, from 22.2 percent.

Over that same period, taxpayers with incomes from around $51,500 to around $75,600 saw their share of federal tax payments increase. Households earning around $75,600 saw their tax burden jump the most, from 18.7 percent of all taxes to 19.5 percent.

NYT is similarly excited: Report Finds Tax Cuts Heavily Favor the Wealthy

Fully one-third of President Bush's tax cuts in the last three years have gone to people with the top 1 percent of income, who have earned an average of $1.2 million annually, according to a report by the nonpartisan Congressional Budget Office to be published Friday. The report calculated that households with incomes in that top 1 percent were receiving an average tax cut of $78,460 this year, while households in the middle 20 percent of earnings - averaging about $57,000 a year - were getting an average cut of only $1,090. The new estimates confirm what independent tax analysts have long said: that Mr. Bush's tax cuts have been heavily skewed to the very wealthiest taxpayers. Those are also the people, however, who pay a disproportionate share of federal income taxes.

Exactly.

We actually commissioned a government study to demonstrate that, given an across-the-board tax cut, the people who pay the most taxes are going to get the biggest cut? That a guy who pays more than $57,000 a year in federal income taxes gets a bigger cut than a guy who only earns $57,000 a year? Really?

Further, if the guy making $57,000 a year gets a tax cut of $1090, does he really think it's a tax hike because he's now paying a slightly higher share of the overall tax burden than he once was?

UPDATE (1138): Sean Davis, a policy analyst for Senator Robert Bennett on the Joint Economic Committee (JEC) has a decidedly different take on the numbers, which he shares via electronic mail:

* As a result of the tax cuts since 2001, all taxpayers face lower effective federal income tax rates than they would have without the tax cuts.

* While many characterize the CBO report as evidence that the tax cuts shifted the burden of taxation to the middle class, CBO data show precisely the opposite effect. The tax cuts actually made the tax system more progressive. The highest 20 percent of earners now pay a larger share of federal income taxes than they would have without the tax cuts, while the share of income taxes paid by all other income groups fell.

* The overwhelming majority of federal income taxes are paid by the very highest income earners. The top 1% of income earners pays 31.6% of all income taxes, the top 5% pays 51.4%, the top 10% pays 63.5%, and the top 20% of income earners pays 78.4% of all federal income taxes. The bottom four-fifths of income earners pay just over one-fifth of all federal income taxes.

* Some analysts cite total effective federal tax rates, as opposed to effective income tax rates, as the best measure of the effects of the tax cuts across income groups. This method can be misleading because it measures the burden of payroll taxes without accounting for the highly progressive Social Security and Medicare benefits to which payroll taxes are linked.

The full report (PDF) is available here.

Update (1549): Steve Verdon has more.

Greece’s Olympic Hero Kenteris Faces Expulsion

Reuters - Greece's Olympic Hero Kenteris Faces Expulsion

Greece's top athlete Costas Kenteris faces expulsion from the Athens Games Friday after missing a drugs test, triggering shock and tears across the host nation hours before the opening ceremony. International Olympic Committee President Jacques Rogge summoned Olympic 200 meters champion Kenteris to a disciplinary hearing Friday with fellow Greek athlete Katerina Thanou, 100 meters silver medallist at Sydney, who also missed a test. "I have called for a disciplinary hearing ... The process has started rolling," said Rogge, who has vowed all drug cheats will be caught.

Kenteris, the only man to win the Olympic, world and European 200 titles, is a national hero in Greece and has been the host nation's best medal hope at the Games. "If he didn't turn up (for the drugs test), he's a fool and he deserves to be out," said an Olympic official, declining to be named. A missed drugs test is normally treated as a failed test and leads to immediate suspension from competition.

The drama swept the Games city, with some people bursting into tears at the news on the man they call "Greece Lightning." Greek television broke into programs to report developments. "This is surely very bad news for us, Kenteris is a great guy, low-key and a very good athlete," said 48-year-old taxi driver Costas Mathes.

Bizarre. So far, the Olympics have been one fiasco after another for Greece, which rather clearly was not up to the challenge of hosting the Games. Rather ironic given that they created them to begin with.

Al Qaeda Scorecard

Arnaud de Borchgrave has an interesting commentary this morning entitled "Al Qaeda's U.S. network" that I heard about on C-SPAN driving in this morning. It presents a bleak picture:

Before we convince ourselves al Qaeda is down for the count, check the stats. Islamist extremists in the world as estimated by moderate Muslim leaders: about 12 million. Fundamentalist sympathizers: 120 million. Those numbers represent 1 percent and 10 percent of the world's Muslim population of 1.2 billion. The CIA puts the extremists much higher -- 40 million. Then there's the number who trust Osama bin Laden more than President Bush: a majority in Muslim countries whose populations total 450 million.

European intelligence services know an alarming number of mosques are privileged sanctuaries used by extremists. Self-proclaimed imams can choose any place, from a basement to a garage, and declare it a mosque, an Islamic place of worship. Germany has 8,000 mosques, according to German intelligence officials, to minister to a Turkish minority of 2.4 million and some 500,000 North African Muslims. France has some 10,000 mosques for 6 million North Africans; the U.S. about 2,000. Beyond normal Friday prayers in Western mosques, there is a common anti-American political message, virulent in Europe, more subtle and discreet in the United States. Intelligence chiefs on both sides of the Atlantic agree the Western world in general and the U.S. in particular now face a global ideological foe convinced the U.S. is the fount of all evil. France is summarily deporting imams who preach hatred and jihad, including one recently who had been a legal Turkish resident for 28 years.

Nasir Ahmad al Bahri, known as Abu Jandal, a former Osama bin Laden bodyguard, interviewed by Al Quds Al Arabi, a London-based, anti-U.S. Arab daily, said last week: "Al Qaeda is no longer an entity but an ideology against America. ... The plan is now to draw the U.S. into a confrontation with all the Islamic peoples. ... Bin Laden and al Qaeda have succeeded in drawing the U.S. into an unequal confrontation, not from a military technology standpoint but from the ideological aspect. Muslims [are now] fed up with the U.S., which lives in prosperity off our nation's resources. I believe the U.S. is heading for its demise. Now that it has found what it wanted, al Qaeda can melt into a new caldron, and a new giant would be reborn. ... Many Islamic world leaders would join it, and the confrontation with the U.S. would be inevitable. Al Qaeda would then [be] a vanguard army."

These numbers are quite plausible, even conservative, and further discredit the "it's just a few Muslim extremists" argument.

Ralph Peters, however, issues a much sunnier forecast.

Al Qaeda and its affiliates are losing. They'll do their utmost to strike the United States before our elections. But even if they succeed, the effect will be the opposite of what they hope. And it won't change the fact that the terrorist beast is badly wounded. The recent wave of arrests, from Pakistan through the Middle East to Britain, stunned the terrorists and sent them crawling for ever-deeper cover. The blow against terror has been so indisputable that even our embrace-the-terrorists-with-understanding crowd stopped crying that the War on Terror's a failure (note the shift in campaign rhetoric). But it's also a fact that this struggle is far from over. It will take at least a full generation — perhaps much longer — to rid the world of the demons who have appointed themselves as Allah's executioners.

We do have some unexpected allies in this war, though: the terrorists themselves. Counter to the made-on-campus nonsense that we can't succeed against terror, it's the terrorists who can't win. They can do horrific damage, creating scenes of slaughter among the innocent. But when it comes to employing such mega-violence, the terrorists are damned if they do, and damned if they don't.

He goes on to list several events where the Islamists have made miscalculations, creating enemies of former allies.

Around the world, leaders have wondered if their country would be next. In a few cases, this led to appeasement. Yet far more often we've seen growing counter-terror cooperation — with far more arrests than you'll read about in the newspapers.

Terrorists always overreach. They create fantasy worlds in which they convince themselves that a grand and gruesome gesture will bring world-changing results. Yet, the more powerful the blow they deliver, the more likely they are to unify their enemies. The recent arrests in Pakistan and Britain have been far more devastating to al Qaeda than media reports suggest. The headlines focus on the number of arrests, but an even greater loss to al Qaeda will be the loss of confidence in essential technologies. Osama bin Laden lost a great propaganda tool when he stopped allowing video cameras near him. (He grew too afraid for his personal safety after 9/11.) But the terrorists' real "secret weapon" has been the Internet, the greatest means of disseminating hatred in history, more virulent by far than even the printing press. For years, Islamic extremists used the 'Net with confidence and skill. It became their virtual empire and a citadel within which they could muster. Now — as a result of the seizure of over 50 computer discs in Pakistan and, by some reports, a thousand in Britain, along with loaded hard drives, Web address books and so much data we've barely begun to decipher it — al Qaeda must fear each next keystroke. Even before the recent arrests, al Qaeda and its allies found themselves restricted in their abilities to travel, to raise funds and even to use cell phones (another great terrorist tool). By diffusing their efforts instead of concentrating on one objective, they created enemies for themselves among governments that had long looked the other way.

The terrorists have been their own worst enemies, always over-reaching in time to prevent the world from forgetting that the threat is real and immediate. Their madness will be their undoing.

Peters is right that the terrorists are unlikely to achieve their political objectives and therefore we will ultimately win. What worries me is that too many Americans, including much of our political leadership, is still in a 9/10 mindset. I heard Sen. Chris Dodd on the Don Imus show this morning saying that President Bush is doing everything he can to make this an election about national security when what most Americans really care about are domestic issues like jobs and health care. Dodd is hardly a lunatic; he's a senior senator and former head of the Democratic Party. If it's really the case that he doesn't understand that we're in a war, and that reflects a plurality view, then we're in trouble.

McGreevey: Gay American

AP - N.J. Governor Resigns, Admits Gay Affair

In a stunning declaration, Gov. James E. McGreevey announced his resignation Thursday and acknowledged that he had an extramarital affair with another man. "My truth is that I am a gay American," he said.

"Shamefully, I engaged in adult consensual affairs with another man, which violates my bonds of matrimony," the married father of two said. "It was wrong, it was foolish, it was inexcusable."

The Democrat said his resignation would be effective Nov. 15. Senate President Richard J. Codey, a Democrat, will become acting governor and serve out the remainder of McGreevey's term, which ends in early 2006. If McGreevey were to leave office before Nov. 15, a special election would be held.

McGreevey, 47, refused to answer questions at a news conference where he was flanked by his wife and parents. He said that "it makes little difference that as governor I am gay," but added that staying in office and keeping the affair and his sexual orientation secret will leave the governor's office "vulnerable to rumors, false allegations and threats of disclosure."

"Given the circumstances surrounding the affair and its likely impact upon my family and my ability to govern, I have decided the right course of action is to resign," he said.

The logic here elludes me: He did something that was sufficiently bad that he must resign the governorship--but not bad enough that he can't wait three months plus? Apparently, he's a gay Democrat before he's a gay American.

Porter Goss and the Reverse Peter Principle

Julian Sanchez, rather tongue-in-cheek, passes along Matt Gunn's report that Rep. Porter Goss, appointed recently to be the next CIA Director, has said that he's unqualified to be a CIA officer:

It is true I was in CIA from approximately the late 50’s to approximately the early 70’s. And it's true I was a case officer, clandestine services officer and yes, I do understand the core mission of the business. I couldn't get a job with CIA today. I am not qualified. I don't have the language skills. I, you know, my language skills were romance languages and stuff. We're looking for Arabists today. I don't have the cultural background probably. And I certainly don't have the technical skills, uh, as my children remind me every day, 'Dad you got to get better on your computer.’ Uh, so, the things that you need to have, I don't have.

While this is rather amusing, Goss' inability to serve as an agent has virtually nothing to do with his ability to lead the agency. As Hit-and-Run commentator Wilson observes,

This seems akin to me to Mike Ditka saying that he's completely unqualified to play tight end in the NFL today--the game has changed so much, and he is really freakin old. Even though he played quite well 30 years ago or whatever. It's quite a different thing to say that Iron Mike can't coach in the NFL because of this. clearly the skill set is not just a little different, it is massively, incredibly different. What possible similarity is there between a field agent and the head of the CIA in terms of duties? About the same similarity as between head coach of a football team and starting tight end--almost nil, except you're on the same field.

Quite right. Years ago, Lawrence Peter put out a book entitled The Peter Principle. The eponymous thesis was that in a hierarchically structured administration, people tend to be promoted up to their "level of incompetence." The rationale is that we choose people for leadership based on their ability to perform a lower level task--even though these skills are only tangentially related--and stop promoting them once they no longer perform well. Humorist Scott Adams countered years later with the The Dilbert Principle, a wagish take-off for the information age: "The most ineffective workers are systematically moved to the place where they can do the least damage: management." The rationale was that the contributions of the truly competent engineers could not be spared from their technical duties, so it was smarter to foist the less qualified but more attractive ones off to various executive grooming programs. There is some truth to both observations.

The Peter Principle works in reverse, too. Most senior managers are incompetent to perform the duties of those whom they supervise. This is not an aspersion on the capabilities of the managers but rather a natural outgrowth of specialization and division of labors, keystones of the modern economy. It is the exceptional CEO who is genuinely expert at anything going on at the lower levels of his corporation, let alone more than one thing.

Bill Gates is by all accounts a brilliant man but he is no longer competent to design service packs to correct the many flaws in the latest Windows operating system. Technology changes quickly and even a few months out of the trenches is enough to render a person obsolete. This observation holds true in all fields, not just the fast-moving world of technology. Contrary to the image created by science fiction programs, where the captain has the engineering schematics in his head and is an expert on all aspects of his ship, leaders in most endeavors must count on the skills of those below them. Even the most learned university presidents are, at best, masters of only their own discipline. Most aren’t even that, having long departed the world of rigorous scholarship for that of university administration.

The expertise of the manager is management. Successful ones have a clear view of the big picture, delegate tasks to people who are more competent at their subject matter than they are, and oversee the enterprise. Bill Parcells was a decent college linebacker but was not good enough for the National Football League. He’s been a rather successful head coach. Similarly, Bob Mueller is unqualified to conduct a homicide investigation and Tom Ridge would be a poor choice to defuse a bomb. Porter Goss would have a hard time infiltrating al Qaeda. He is perfectly qualified to run the CIA.

Beltway Traffic Jam

A rainy Thursday linkfest:

• Black-5 presents The Night Before Christmas (Cambodian Version).
• Erick-Woods Erickson gives an insider's account of cloak-and-dagger exploits in a small political campaign.
• Courtney Knapp gives some helpful tips for picking up cute baristas.
• Frank J explains the role of women in science.
• Andrew Cline addresses the politics of barbecue.
• Steven Taylor has a new 404 message.

To join in, link and send a TrackBack to this post. If your blog doesn't automatically generate one, use the Send TrackBack feature below. For more information, see this post.

Game Plan: Winning the Terror War

Stephen Green revises and extends his remarks on how to win the war on terror over at TCS.

California Supremes Overturn Gay Marriage

AP - Calif. Court Voids S.F. Same-Sex Marriages

The California Supreme Court on Thursday voided the nearly 4,000 same-sex marriages sanctioned in San Francisco this year and ruled unanimously that the mayor overstepped his authority by issuing marriage licenses to gay and lesbian couples. The court said the city violated the law when it issued the certificates, since both legislation and a voter-approved measure defined marriage as a union between a man and woman. The justices separately decided with a 5-2 vote to nullify the marriages peformed between Feb. 12 and March 11, when the court halted the weddings. Their legality, Justice Joyce Kennard wrote, must wait until courts resolve the constitutionality of state laws that restrict marriages to opposite-sex couples.

The same-sex marriages had virtually no legal value, but powerful symbolism. Their nullification by the high court dismayed Del Martin and Phyllis Lyon, the first same-sex couple to receive a marriage license in San Francisco. "Del is 83 years old and I am 79," Lyon said. "After being together for more than 50 years, it is a terrible blow to have the rights and protections of marriage taken away from us. At our age, we do not have the luxury of time."

The court did not resolve whether the California Constitution would permit a same-sex marriage, ruling instead on the narrow issue of whether local officials could bypass state judicial and legislative branches. Chief Justice Ronald George noted that Thursday's ruling doesn't address "the substantive legal rights of same sex couples. In actuality, the legal issue before us implicates the interest of all individuals in ensuring that public officials execute their official duties in a manner that respects the limits of the authorities granted to them as officeholders."

Undoubtedly, this is the correct result on that issue. Clearly, mayors can't overturn state constitutions on their merest whim. Only courts can do that.

OTB 404

I was time to update my 404 Message.

Teresa Heinz Kerry: African American

This flap is rather amusing: Group Runs Anti-Kerry Ads on Black Radio Stations

A group financed by a major Republican contributor has begun running radio ads in about a dozen cities, many in battleground states, attacking Sen. John F. Kerry as "rich, white and wishy-washy" and mocking his wife for boasting of her African roots.

The D.C.-based group, People of Color United, has substantial financial backing from J. Patrick Rooney, the former chairman of Golden Rule Insurance Co. and the founder of a new firm, Medical Savings Insurance Co. Both firms specialize in medical savings accounts, created by Republican-backed 1996 legislation, and health savings accounts, which were created by President Bush's 2003 Medicare prescription drug legislation. One of the radio ads addresses Kerry's failure to vote on a bill to extend unemployment benefits for 13 weeks: "It needed 60 votes to pass. Ninety-nine out of 100 senators voted -- Kerry did not! It lost by one vote! Maybe Kerry thought the more of us who are unemployed and hurting, the more likely we would vote Democrat."

Another ad attacks Teresa Heinz Kerry, who, at the Democratic convention last month cited her birth and upbringing in Mozambique and who has described herself as African American. In the radio commercial, the announcer says: "His wife says she's an African American. While technically true, I don't believe a white woman, raised in Africa, surrounded by servants, qualifies."

The Kerry campaign denounced the ads, all of which are being aired on radio stations with largely black audiences. "It's disgusting that the president's political allies are now using race as a political weapon," said Bill Lynch, deputy manager of the Kerry campaign. "First a group of right-wing Swift boat veterans began smearing John Kerry's military service, and now another group has resorted to playing racial politics."

It's always amusing to see the Democrats get upset when someone plays racial politics.

While I'm no big fan of TuhRAYsuh Heinz-Kerry, she is unquestionably African American. This just shows the silliness of trying to create a euphemism for "black," a concept that needs no euphemism. "African American" is one of my least favorite politically correct affectations, in that it's not only silly, it's awkward and inaccurately conveys the concept it is intended to communicate.