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Certain mass media channels offer efficient opportunities to target smoking cessation messages so they reach relatively large audiences of smokers at relatively low cost. The approach used in this study can be applied to other types of health risk factors to improve health communication planning and increase efficiency of program media expenditures.

Almost one-half million babies in the United States are born yearly to women who report smoking while pregnant. Almost all of these pregnant women have access to prenatal care, through federally financed health clinics, state and county health programs, or private providers. However, many pregnant smokers are unlikely to receive any type of counseling or assistance to help them stop smoking--despite the availability of evidence-based treatment and the considerable return on investment. This article recommends four next steps to ensure that tobacco dependence treatment is available for all pregnant women. These steps are (a). expanding Medicaid coverage for, and promotion of, effective counseling services for pregnant smokers, (b). improving health care systems by building the capacity of prenatal providers and health care systems to deliver effective treatments, (c). encouraging purchasers of private and public health benefit packages to demand coverage for, and promotion of, effective counseling services for pregnant smokers, and (d). redirecting state resources to ensure a statewide system of care for pregnant smokers. Implementation of these steps requires leadership, diligence, and action by the public health community--as well as ongoing monitoring to assess progress in improving coverage, capacity, and coordination.

A complex question in international commercial arbitration is the extent to which an enforcement court should defer to the decisions of courts at the seat of arbitration. In the recent case of Gujarat, the Federal Court of Australia held that it would generally be inappropriate for an Australian court, called upon to enforce an arbitral award under the International Arbitration Act 1974 (Cth) (IAA), to reach a different conclusion on the same question as that reached by the court at the seat of arbitration. This article critically examines Gujarat in light of the broader debate about the role of the seat in international arbitration jurisprudence. The article contends that the role of the seat is far from settled. In the first place, there are competing theories of international arbitration, each according to a different degree of importance to the seat of arbitration. Second, enforcement courts applying the provisions of the New York Convention have taken very different approaches to the decisions of courts at the seat of arbitration. US courts, for example, generally defer to the decisions of courts at the seat; French courts, on the other hand, tend to disregard the decisions of courts at the seat. Nevertheless, this article contends that the deferential approach taken by the Federal Court in Gujarat and the US courts is the correct one. Australian courts should, for strong policy reasons, defer to the decisions of courts at the seat of arbitration, save in exceptional cases where such decisions are shown on the basis of cogent evidence to be partial and dependent or in violation of basic principles of justice. This approach promotes finality and efficiency in international arbitration whilst upholding the international rule of law.

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