Bay Area Jan 8-9 2011 App: Fill & Download for Free

In Today's Mobile World, a portable application isn't just a Customer commitment instrument, rather it is giving Nemours benefits past its job. San Francisco is the biggest business center on the planet base camp with numerous large tech monsters. Finding the best portable application advancement organization in San Francisco is anything but a simple undertaking.For any sort of business today it is one the vital thing to go with Digital way and this must be finished by Mobile applications. Versatile applications are utilized by business as a brand building device, income producing instrument, special apparatus and as an option in contrast to the site. Just when you have a quality versatile application you can ready to make the best out of it.To build up a quality portable application, you need the best application designers. In the event that you are in the need of best versatile application designers in San Francisco, at that point experience the underneath list.Why pick Mobile applications for your Business? In the event that you believe that applications are just for large brands, you are incorrect. These days countless little and medium-sized business are engaging in versatile patterns, learning the adequacy and advantages of portable systems and associated with executing it.It is a difficult task to locate the best engineers in our circle and particularly in a major city like San Francisco where the business is loaded with programming organizations. Here are a portion of the reasons why your business needs versatile application advancement.We can see that independent company that we collaborate each day are having their own versatile applications, it very well might be a spa or a coffeehouse. They are ahead in their promoting way. Look at the top motivations to have a portable application for your business,Can be obvious to your clients constantly — Statistics says that a normal individual goes through 2 hours every day is on utilizing cell phones. What's more, most presumably these hours are taken by Mobile applications. Giving an immediate showcasing Medium — Mobile applications gives numerous capacities that incorporate an overall data, search highlights, couriers, evaluating, client records and considerably more.Perhaps the main viewpoints is that you can arrive at your objective clients readily available about your administrations/items, highlights, rebate offers and your deals and advancements.Giving qualities to your clients — Instead of working with the old assortment cards, cause your clients to get their awards through versatile applications. This will improve the downloading pace of your versatile application.Building Brand advancement and Recognition — Your application resembles a clear board you can make it as more practical, enlightening and in a way that draws in your clients.The more the clients are included, sooner they will purchase your administrations or items. Client Engagement — No issue whatever your business is you need the most ideal approach to arrive at your objective clients.Having an informing highlight will cause you to speak with your clients at unsurpassed. Improved client commitment is accomplished by benefiting a portable application for your business.1 . SISGAINSISGAIN is a Deloitte grant winning iPhone application development organization in the San Francisco Bay Area. SISGAIN is one of the greatest application development companies in the USA, UAE, and India.The organization has been delegated by this renowned honor for its unrivaled presentation in the portability world since its initiation in 2008.SISGAIN, mobile app development company gives portability benefits in San Francisco, Santa Clara, San Jose, and San Diego.SISGAIN is universally perceived for an assorted exhibit of portability administrations like iPhone application advancement, Android application improvement, and iPad application advancement.Aside from versatile application advancement, SISGAIN is best among different portable game organizations in Bay Area. The organization conveys amazing versatile distributed computing, IoT, and undertaking application improvement arrangements.The organization worked together with different undertakings around the globe, including Vodafone, Big Basket, Praxair, Novasys, and some more.Established In: 2007Areas: USA, UAE, UK and Canada2. Y Media LabsY Media Labs is a chief portable applications advancement organization in San Francisco, settled in San Francisco Bay Area. Y Media Labs has branches in Indianapolis, New York, and Bangalore.Versatile application improvement arrangements are their principle strong point. The organization is very much aware of the cutting edge innovations and help you redesign with the most recent pattern on the lookout.The organization gives quality versatile application improvement administrations on iOS, Android, and Windows stages, just as responsive web advancement administrations.A portion of the key customers are for Home Depot, Staples, Molekule, and some more.Established In: 2008Areas: USA, India3. IntellectsoftIntellectsoft is a worldwide portable application improvement organization in California, settled in Palo Alto (CA). Intellectsoft offers versatile application improvement benefits in San Francisco, New York, Dubai, and other significant urban areas of the world.Its administrations incorporate portable application advancement, venture application improvement, distributed computing, and Big Data, and so onFrom thought approval to execution, the organization guarantees to convey top quality yield by addressing the customer's necessities and assumptions.The organization worked with different associations everywhere on the world, for example, Jaguar, Clinique, Audi, Giant, and some more.Established In: 2007Areas: USA, UK, Norway, and Dubai4. CitrusBitsCitrusBits is one of the unmistakable San Francisco engineers, conveying first class benefits everywhere on the world.The firm is open for customers whenever; you can find their advancement group, and get a thought regarding executing your application. Get instincts about the application market to close creating with which innovation that suits for your clients.The application designers at this organization consistently guarantee to meet the separate customer's assumption with their information sources.The organization had practical experience in application advancement, Blockchain application improvement, UI/UX improvement, eCommerce improvement, and some more.Established In: 2005Areas: USA5. ArctouchArctouch is an honor winning versatile application plan and improvement organization that basically centers around building associations face to face and through their items.Since Jan 2016, Arctouch works as an auxiliary of Gray Global Group, Inc. As of now, the organization built up a progression of fruitful applications for various stages like IOS, Android, and Xamarin.Arctouch has offered types of assistance for fortune 500 organizations in San Francisco and everywhere on the world, for example, Audi, Honeywell, and some more. The San Francisco designers are commended for conveying administrations earnestly and constancy in a savvy style.Established In: 2009Areas: USA and Brazil6. AppsterAppster is a San Francisco based web and portable application Development Company in California. Since the commencement of the organization, Appster turns into a head portable plan and improvement organization based out of San Francisco.The organization likewise gives application improvement administrations in Melbourne, Australia. Jagermeister, People's Choice Credit Union, CFMEU, and Anglicare are the significant customers of Appster.Essential administrations that Appster gives incorporate iOS application advancement, Android application improvement, Game turn of events, web applications advancement, and undertaking application advancement.Established In: 2011Areas: USA7. STRVSTRV is a product plan and designing organization established in 2004, settled in San Francisco, USA.The organization has a past filled with dispatching 70+ advanced arrangements consistently by offering life to your thoughts. The organization is one of the fortune 500 organizations in the Bay Area, which is into creating web and versatile application improvement, UX/UI, website composition, and group enlargement commitment.The organization works with little to huge firms for various ventures across the globe. The organization served worldwide customers like Microsoft, Boosted Boards, The Athletic, and ClassDojo.Established In: 2004Areas: USA, UK, Czech Republic8. RaizlabsRaizlabs is a top portable application advancement firm in Boston, Massachusetts, and Oakland, San Francisco Area.It creates top quality portable applications on iOS and Android stage, and web applications. Its Android application advancement cost in the San Francisco territory is appealing and reasonable.In May 2016, Google reported Raizlabs as a Google guaranteed organization. It is a Rightpoint organization, highly esteems uniting the best client experience ability to connect with customers in giving productive arrangements.The organization is driven by greatness, effect, activity, and cooperation; Raizlabs makes computerized encounters to develop the manner in which their customers work together. Its top customers incorporate Rue La, Six banners, Run Keeper, and some more.Established In: 2003Areas: USA9 . ImpekableImpekable is a full-administration advanced studio that fundamentally centers around assisting the association with creating human-driven and essential versatile encounters.Impekable is an honor winning versatile application improvement organization that had some expertise in portable application and web application advancement, UI/UX plan, venture web application advancement, MVP advancement, and fast prototyping.Impekable have confidence in going the additional mile for clients. They make progress toward quality plan and improvement to assist customers with accomplishing their objectives.Generally great of all, Impekable can achieve this with a moderately little yet assorted group of inventive people. As of now, it served top customers like HP, Google, Netgear, Marquee, and some more.Established In: 2012Areas: USA10. Swenson HeSwenson He is an app design and development company founded in 2014 and headquartered in San Francisco, California. Relatively new to the section, the software-consulting firm has been able to proliferate with its never outsourced approach.The company is specialized in IOS and Android app development, web app development, including eCommerce and Java. The firm institutionalized a final 1% method, whereby engineers regularly ask themselves what more they can do to ensure maximum results.Its top clients are ACTually, Simplehuman, ChemoWave, Stanford Medicine, and many more.Founded In: 2014Locations: USAConclusionWe are glad that the list mentioned above of the top 10 mobile app development companies in San Francisco, Bay Area, served your purpose.

Fujin Peter Cheung 2019No earthquake in HK. In Dec 2017, I happened to be in Tokyo and experienced for the first time what a magnitude 6+ earthquake was like.Tsunami Height Peter Cheung 2019No tsunami in HK. In Dec 2019, I had dinner in a Sendai seashore restaurant and learned that the 2011 tsunami height reaching there was about five feet above ground.Tsukemen Peter Cheung 2020HK’s Jan 1 (Wed) 2020. I got a phone message from HK Police alerting a public event on Hong Kong island in the afternoon. I went to Kowloon for Tsukemen.Beef Pho Peter Cheung 2020HK’s Jan 2 (Thur) 2020. In the morning, I went to work and acted for a client. Then I had a delicious beef pho in a restaurant. It was uneventful.Sun Yat-sen Memorial Park Peter Cheung 2020HK’s Jan 3 (Fri) 2020. Leaving my chambers, I went swimming a Sports Center next to the Sun Yat-sen Memorial Park and then watched a concert in City Hall.Chep Lap Kok Airport Peter Cheung 2020HK’s Jan 4 (Sat) 2020. My family ate out for lunch. Then I got a roadworthy certificate at a car testing centre. At night, we saw a daughter off at the Airport.Kaji - Our Pet Peter Cheung 2020HK’s Jan 5 (Sun) 2020. My son and I ate out for lunch. Then, my family took our pet Kaji to see her Vet. After a very nice dinner in a mall, we went shopping.SMART Car Peter Cheung 2020HK’s Jan 6 (Mon) 2020. I drove my SMART car to enjoy morning coffee. Then I wrote a mini-screenplay entitled “Sixs & Sevens” about people’s desires and emotions.Look Alike Peter Cheung 2020HK’s Jan 7 (Tue) 2020. I took MTR to Kennedy Town. I swam before going to see my dentist. On my way, I met this male Shiba Inu, which looked like Kaji.Fly Again Peter Cheung 2020HK’s Jan 8 (Wed) 2020. I checked in the Chep Lap Kok Airport in the early hours of the morning, bound for Tokyo Narita. Everything was safe and smooth.Fair Balance Peter Cheung 2020HK’s Jan 9 (Thur) 2020. While in Tokyo, I got a dinner invitation from a friend in Hong Kong. Again online, I got a dispute-settlement assignment from HKIAC.No News Peter Cheung 2020HK’s Jan 10 (Fri) 2020. I watched the world news during breakfast and there was no news about Hong Kong. That should be good news.No Delay Peter Cheung 2020HK’s Jan 11 (Sat) 2020. My flight black to Hong Kong flew as scheduled and there was no delay. Hong Kong Airport’s operation was smooth.Walking Alone Peter Cheung 2020HK’s Jan 12 (Sun) 2020. Getting off from an Airport bus sometime after 02:00 am, I walked home alone without any worry of my safety.US$4.5 Peter Cheung 2020HK’s Jan 13 (Mon) 2020. I acted for a client in the morning. After my afternoon swimming, I bought my favourite chicken pies and a strawberry dessert in a cake shop.At Central Peter Cheung 2020HK’s Jan 14 (Tue) 2020. After drafting something at home, I went to Central to join my wife and friends for an expensive steak dinner at Central.Money Smells Peter Cheung 2020HK’s Jan 15 (Wed) 2020. I went to AsiaWorld-Expo to attend a sold-out 12,000-participant Block Chain, Fin-Tech, AI and Robotics Conference.HKUST Peter Cheung 2020HK’s Jan 16 (Thur) 2020. One important thing I did was to go back to HKUST to sign an important document so that the University can optimise it’s available resources.Pigeons Of Content Peter Cheung 2020HK’s Jan 17 (Fri) 2020. Having gone to my banker in Causeway Bay, I passed by the Kowloon Park and the pigeons before going to a music store to buy a gig bag.Come Saturday Morning Peter Cheung 2020HK’s Jan 18 (Sat) 2020. Having gone to a public swimming pool swimming early in the morning, I stayed home to draft a domain name dispute decision.Stylish Dessert Peter Cheung 2020HK’s Jan 19 (Sun) 2020. I went swimming in the morning, brought takeaways home and had a very delicious dinner in a mall restaurant.Lunchtime Peter Cheung 2020HK’s Jan 20 (Fri) 2020. After issuing an on-line arbitral decision, I went to a Tsimshatsui restaurant for lunch with friends. There were a lot of shoppers in the area.Where To Keep Fit Peter Cheung 2020HK’s Jan 21 (Tue) 2020. I went swimming in a public swimming pool and then reading newspapers in a public library, before enjoying fried noodles in a restaurant.Victoria Harbour Peter Cheung 2020HK’s Jan 22 (Wed) 2020. I drove my wife to a hospital for a routine check up, captured some photos and had lunch with her in a Spanish restaurant in Central.Residential Premises Peter Cheung 2020HK’s Jan 23 (Thur) 2020. I went to a public library reading newspapers and then to a public swimming pool to swim my usual 1000 meters.Kai Tak Cruise Terminal Peter Cheung 2020HK’s Jan 24 (Fri) 2020. On Chinese New Year home, my family drove 40 km home to have a joyful togetherness banquet in a Chinese restaurant.Elderly Home Peter Cheung 2020HK’s Jan 25 (Sat) 2020. I first went to an elderly home to meet my mother-in-law and then to another estate to meet another mother-in-law.Restaurant Neon Peter Cheung 2020HK’s Jan 26 (Sun) 2020. My family conducted several relative visits in the New Territories before having a feast in a restaurant near Mongkok.High-end Restaurant Peter Cheung 2020HK’s Jan 27 (Mon) 2020. I hosted a dozen guests in a high-end restaurant next to the Hong Kong Museum of Art, had a great time and an expensive bill.Pet Playmates Peter Cheung 2020HK’s Jan 28 (Tue) 2020. My wife and I explored a pet garden near Kai Tak that was new to us. Our pet, Kaji, had new playmates and all has fun.Public Hygiene Peter Cheung 2020HK’s Jan 29 (Wed) 2020. After the public holidays, my wife followed instruction to work at home. I went to my clubhouse and hygienic facilities were in place.Fairview Park Peter Cheung 2020HK’s Jan 30 (Thur), 2020. I went back to my NT premises to take care of household chores. I realised if I go back often, I would have less chores.Banking Services Peter Cheung 2020HK’s Jan 31 (Fri), 2020. In an ATM machine, I withdrew some cash; and in a bank, I withdrew some Japanese yen. In another bank, I did some wealth management.Airport Greetings Peter Cheung 2020HK’s Feb 1 (Sat), 2020. Taking a bus, I arrived at the Airport smoothly and enjoyed my favourite dessert from a Michelin-starred restaurant.Out of Stock 1 Peter Cheung 2020HK’s Feb 2 (Sun), 2020. I was visiting Hokkaido, Japan. I thought I could buy face masks back to Hong Kong. I didn’t find any in Chitose and in Sapporo.Out Of Stock 2 Peter Cheung 2020HK’s Feb 3 (Mon) 2020. At Otaru, I went to pharmacies in search for face masks. As the situation there was no different, I wouldn’t search for them any more .Surprised Success. Peter Cheung 2020HK’s Feb 4 (Tue) 2020.Getting off a Sapporo tram, I went to my favourite 100 Yen store. There I bought a few of the remaining face masks - too good to be true!Hokkaido Rice Peter Cheung 2020HK’s Feb 5 (Wed) 2020. As my wife asked me to buy some uncooked rice back to Hong Kong, I managed to buy some at the New Chitose Airport.Snacks Taiwan Style Peter Cheung 2020HK’s Feb 6 (Thur) 2020. Back in Hong Kong, I bought some Taiwanese snacks and can’t wait to eat them while walking the streets of Hong Kong.Sweet & Sour Peter Cheung 2020HK’s Feb 7 (Fri) 2020. While having lunch with my wife who now works from home, I got a surprised online assignment from Kuala Lumpur - good for me.HK$250 for 2Kg Peter Cheung 2020HK’s Feb 8 (Sat) 2020. After trying some Japanese curry at MegaBox at Kowloon Bay with my family, we went shopping in supermarket selling Japanese stuff.Terminal 1, Hong Kong AirportHK’s Feb 9 (Sun) 2020. After having a good lunch in a restaurant near home, my wife and I went to the Airport to see our son flying back to Sydney.Business School HKUST Peter Cheung 2020HK’s Feb 10 (Mon) 2020. After attending a meeting in Central, I went back to my chambers to say hello to the secretaries before having a meal in a restaurant.Roast Goose Noodles Peter Cheung 2020HK’s Feb 11 (Tue) 2020. I was appointed to settle two related domain name disputes as a dispute settlement panelist and thought I should be busy with online work.My Complaint Peter Cheung 2020HK’s Feb 12 (Wed) 2020. I filed complaints with the Police against someone outside Hong Kong, who threatened to kill me if I decide the cases against him.Cupid -My Song Peter Cheung 2020HK’s Feb 13 (Thur) 2020. I had the urge to do a music video and recording a new version of a song as “Cupid” on the eve of Valentines.Happy Valentines Peter Cheung 2020HK’s Feb 14 (Fri) 2020. It’s Valentines Day. My wife I had dinner at a Michelin-starred seafront restaurant in Sai Kung - a great night.My Love of 30 Years Peter Cheung 2020HK’s Feb 15 (Sat) 2020. I took a car to a car testing centre to check its road worthiness. I got the certificate so that I can renew the license and felt good.My Pet Peter Cheung 2020HK’s Feb 16 (Sun) 2020. I stayed at home to update on my social media sites as Apps made changes; and I began writing better daily screenplays.The Imagination Peter Cheung 2020HK’s Feb 17 (Mon) 2020. Feeling bored, I opened enjoyed the chocolate pack I bought at Oshigaki. Then I listened to my own music.My Other Pets Peter Cheung 2020HK’s Feb 18 (Tue) 2020. After playing with my other pets, I focused on writing something so as to render quality online services.Smiling Flowers Peter Cheung 2020HK’s Feb 19(Wed) 2020. At a supermarket, I bought flowers for my wife. Then I rendered some online service for a dispute settlement centre at Kuala Lumpur.Dumplings For Two Peter Cheung 2020HK’s Feb 20 (Thur) 2020. After having a brunch with my wife in a nearby restaurant, I had a marathon online meeting as a Council Member of HKUST.Shared Cake Peter Cheung 2020HK’s Feb 21 (Fri) 2020. I got a cold but warm call, enquiring: “How are you?” We had a nice chat and agreed on the way forward. Obligations are mutual.Korean NoodlesHK’s Feb 22 (Sat) 2020. My wife prepared some very nice Korean noodles for us so that we didn’t need to eat out. I stayed home to update my monthly travel history.Closed Restaurant Peter Cheung 2020HK’s Feb 23 (Sun) 2020. I went to buy take-away breakfast and reckoned that the estate Chinese restaurant has closed business because of COVID19.Tsimshatsui East Peter Cheung 2020HK’s Feb 24 (Mon) 2020. My wife and I went to Tsimshatsui for lunch. We had very nice blue-fin toro lunch set in a Japanese restaurant.Red Bean Ice Peter Cheung 2020HK’s Feb 25 (Tue) 2020. After having a very delicious roast goose rice and red bean ice, I worked at home to make my sluggish computer efficient again.Pay Queue Peter Cheung 2020HK’s Feb 26 (Wed) 2020. After a nice lunch, my wife and I went shopping in an Aeon Supermarket. We experienced long queues to pay.What I Also Play Peter Cheung 2020HK’s Feb 27 (Thur) 2020. Our maid brought brunch for my wife and me. While my wife stayed home-working, I played guitar with an amplifier and a rhythm box.Valet Parking Peter Cheung 2020HK’s Feb 28 (Fri) 2020. My wife and I ate out in the afternoon and in the evening. We were surprised that expats provided valet service for a Chinese restaurant.Japanese Restaurant Peter Cheung 2020HK’s Feb 29 (Sat) 2020. My wife and I had a very nice dinner in a Japanese restaurant. The food quality was good and the price reflected that.Mongkok Peter Cheung 2020HK’s March 1 (Sun) 2020. After dinner, I drove past Mongkok to a Cinema in Yau Ma Tei. Later, I had my car’s gas filled in San Po Kong.Kiddy Hobby Peter Cheung 2020HK’s March 2 (Mon) 2020. I saw my wife returning to the office after a 5-week lapse. I jogged a bit before doing some kiddy thing at home.Hen-like Peter Cheung 2020HK’s March 3 (Tue）2020. My wife and I had lunch in a mall restaurant. Afterwards, we continue to our respective home-working.A ProblemHK’s March 4 (Wed) 2020. I had a pleasure ride in the New Territories. I found that one tire might have a problem but it was Okay after all.Jack Up The Economy Peter Cheung 2020HK’s March 5 (Thur) 2020. In order to preamp the scare of any tire problem while driving on the highway, I had all the tires replaced - boosting the economy a bit.Simple Breakfast Peter Cheung 2020HK’s March 6 (Fri) 2020. After some nice jogging in a park nearby, I shared my simple breakfast at home with my pet, a shiba inu.Kaji Is Her Name Peter Cheung 2020HK’s March 7 (Sat) 2020. My wife and I drove Kaji to a pet garden to relax and have fun before taking her to the Vet to get a preventive injection.Tsumshatsui Restaurant Peter Cheung 2020HK’s March 8, (Sun) 2020. I composed a song to celebrate the International Women’s Day before going to a Tsimshatsui restaurant for a family dinner.In Demand Peter Cheung 2020HK’s March 9 (Mon) 2020. Our younger daughter bought masks before she left for UK in January. We posted some of her stock to her in UK.Jogging Track Peter Cheung 2010HK’s March 10 (Tue) 2020. I went jogging in a Park before going to a store to buy some props to create some colourful installation art at home.HKU Peter Cheung 2020HK’s March 11 (Wed) 2020. After contributing hours of volunteering work at the HK Club Building, I went to HKU to get my replacement library card.Spring Peter Cheung 2020HK’s March 12 (Thur) 2020. I was so excited with the aesthetic and emotional appeal of my installation arts that I craved to have more.Japanese Strawberries Peter Cheung 2020HK’s March 13 (Fri) 2020. After having brunch with my wife, we bought a box of strawberries from Fukuoka - the price HK$108 was on par with those in Japan.Installation Art Peter Cheung 2020HK’s March 14 (Sat) 2020. After jogging twice in a park, I stayed at home to create some installation arts that have aesthetic and emotive to me.Beijing Duck Peter Cheung 2020HK’s March 15 (Sun) 2020. I bought take-a-way breakfast, watched at home the Japanese “Shall we dance?”, and had Beijing duck in a restaurant.Original Screenplay Peter Cheung 2020HK’s March 16 (Mon) 2020. After enjoying the afternoon tea in a restaurant, I went to park nearby and practised a few Tango footwork.The Best Picture Peter Cheung 2020HK’s March 17 (Tue) 2020. My wife and I went to the Broadway Cinema at Hollywood, Kowloon to watch the Best Picture Parasite, and I captured my best picture.Mango Chocolate Peter Cheung 2020HK’s March 18, (Wed) 2020. I went to an estate park to jog and practise dance footwork twice today. In between, I enjoyed Malaysian Mango Chocolates.The Communication Peter Cheung 2020HK’s March 19, (Thur), 2020. At the park spot where I practise my dance footwork, I saw an emotive appealing flower installation on the ground.All Over The World Peter Cheung 2020HK’s March 20 (Fri), 2020. The COVID-19 pandemic is rendering the world unsafe. My focus has been to facilitate my daughter in UK to catch a flight home.Natural Colours Peter Cheung 2020HK’s March 21 (Sat), 2020. In order to stay healthy with style, I have begun to practise Viennese Waltz without wearing a mask in the Park again.In Focus Peter Cheung 2020HK’s March 22, (Sun), 2020. Every Sunday, I publish a screenplay about my pet Kaji. My son came home for dinner and I drove him home.Tea Break Peter Cheung 2020HK’s March 23 (Mon) 2020. My wife and I had tea break in a restaurant. My favourite is roast goose noodles and red bean ice.Supplies to Japan Peter Cheung 2020HK’s March 24, (Tue), 2020. While one daughter had left UK and was in transit in Dubai, we posted some Japanese noodles to another daughter in Japan.Home Coming Peter Cheung 2020HK’s March 25, (Wed), 2020. Early in the morning, our younger daughter came home. I did not greet and meet her and she has been subjected to quarantine.The Substitute Peter Cheung 2020HK’s March 26, (Thur), 2020. But for the flight cancellation and Japanese quarantine, I should have been in Kumamoto meeting my daughter there.Business School Peter Cheung 2020HK’s March 27 (Fri) 2020. I went to Central for a meeting, shopped at Tom Lee Music in Tsimshatsui and went to a wet market in Kwun Tong.Free Service Peter Cheung 2020HK’s March 28 (Sat) 2020. Our daughter being quarantined thought she had coronavirus symptoms. It was a relief her COVID-19 test result was negative.Stay Indoors Peter Cheung 2020HK’s March 29 (Sun), 2020. We took our pet Kaji to a hairdresser salon inside a mall. She enjoyed the fresh air and the sights on route very much.Herbal Stuff Peter Cheung 2020HK’s March 30 (Mon) 2020. I took public transport to a Clinic to Chai Wan. And then I bought lots to herbal stuff to sanitise the organs of my family members.Social Distancing Peter Cheung 2020HK’s March 31 (Tue) 2020. Due to the COVID-19 pandemic, Hong Kong restaurants began new seating arrangement for customers. I like that.Going Home Peter Cheung 2020HK’s April 1 (Wed) 2020. Despite more emergency regulations on social distancing, they do not prevent me to dance Waltz and Tango in a park.Takeaways Peter Cheung 2020HK’s April 2 (Thur) 2020. Although I could have left the task to our maid, I went to a mall and bought takeaways from three different restaurants with heart.My Favourite Peter Cheung 2020HK’s April 3 (Fri) 2020. Masked, I did my morning exercises in a park, had tea break in a restaurant and walked my pet in the neighbourhood.Flexible Strength Peter Cheung 2020HK’s April 4 (Sat) 2020. It’s Ching Ming Festival but we broke our custom and didn’t visit the graves of our ancestors - all because of COVID-19.

Across the globe, businesses are experiencing issues with productivity due to employees being self-quarantined to prevent risk of exposure to the coronavirus (COVID-19), and due to facilities being shut down in an attempt to slow the virus’ spread. In light of this, many businesses are now seeking to determine whether they are obligated to perform under their contracts, or whether they can invoke a force majeure clause to excuse performance temporarily or even permanently. Below, we review force majeure, how it can apply in various jurisdictions, the analysis companies must undertake before invoking it, and the options available in lieu of force majeure.Force Majeure Clauses GenerallyA force majeure clause is a contractual provision which excuses one or both parties’ performance obligations when circumstances arise which are beyond the parties’ control and make performance of the contract impractical or impossible.[1]Force majeure events typically enumerated in contracts include:acts of God, such as severe acts of nature or weather events including floods, fires, earthquakes, hurricanes, or explosions;war, acts of terrorism, and epidemics;acts of governmental authorities such as expropriation, condemnation, and changes in laws and regulations;strikes and labor disputes; andcertain accidents.[2] Economic hardship typically is not enough to qualify as a force majeure event on its own.[3]Determining whether a force majeure clause can be invoked is a fact intensive inquiry, as it depends on the specific language of a contract. Generally, force majeure clauses are interpreted narrowly.[4] “[T]he general words are not to be given expansive meaning; they are confined to things of the same kind or nature as the particular matters mentioned.”[5] Force majeure clauses are interpreted in light of their purpose, which is “to limit damages in a case where the reasonable expectation of the parties and the performance of the contract have been frustrated by circumstances beyond the control of the parties.”[6] “[W]hen the parties have themselves defined the contours of force majeure in their agreement, those contours dictate the application, effect, and scope of force majeure.”[7]State Specific Requirements for Force Majeure Clauses: New York, Florida, California, Texas, IllinoisUnder New York law, a key issue in determining whether a party can successfully invoke a force majeure clause is whether the clause lists the specific event claimed to be preventing performance.[8] As noted previously, some force majeure clauses list “epidemics” or “pandemics” as force majeure events. The CDC defines an epidemic as an outbreak of disease that infects communities in one or more areas, and a pandemic is an epidemic which spreads across the globe. If a contract at issue lists epidemics or pandemics as a force majeure event, the claiming party could argue that the coronavirus qualifies in light of the fact that is has been officially declared a pandemic by World Health Organization.If a force majeure clause does not list epidemic or pandemic as a triggering event, it is possible that the coronavirus could be covered as an act of governmental authority in some areas, given that many governments, including the United States government, have instituted lockdowns to prevent the spread of the coronavirus.If a listed force majeure event occurs, however, there is still further analysis required to determine whether invocation will be successful. In New York, the force majeure event must be unforeseen, and the party seeking to invoke the force majeure clause must attempt to perform its contractual duties despite the event.[9] However, some jurisdictions, including Texas, do not require that the force majeure event be unforeseeable.[10]Under Florida law, a party seeking to invoke a force majeure clause must show that the force majeure event was unforeseeable, and that the force majeure event occurred outside the party’s control. This means that the claiming party must show that the event could not have been prevented or overcome, and there additionally cannot be any fault or negligence on the part of the claiming party.[11]In California, force majeure is not necessarily limited to the equivalent of an act of God, but the test is whether under the particular circumstances there was such an insuperable interference occurring without the party’s intervention as could not have been prevented by the exercise of prudence, diligence and care. Mathes v. City of Long Beach, 121 Cal. App. 2d 473, 477, 263 P.2d 472, 474 (1953). Even in the case of a force majeure provision in a contract, mere increase in expense does not excuse the performance unless there exists extreme and unreasonable difficulty, expense, injury, or loss involved. Butler v. Nepple, 54 Cal. 2d 589, 598, 354 P.2d 239 (1960)Under Texas law, unless expressly included in a contract, parties seeking to invoke a force majeure clause to excuse non-performance are not required to exercise reasonable diligence to perform or overcome the force majeure event.[12] If the parties contracted for this, however, determining whether a party exercised reasonable diligence is fact intensive, and must be assessed on a case-by-case basis.[13] “Reasonable diligence” is defined under Texas law as “such diligence that an ordinarily prudent and diligent person would exercise under similar circumstances.[14]”On the other hand, under Illinois law, there is an implied duty on the claiming party to make an effort to attempt to resolve the event causing delay or inability to perform under the contract before invoking a force majeure clause. This duty is “related to the duty of good faith [and] is read into all express contracts unless waived.”[15]Some contracts additionally require that the claiming party give the other contractual parties notice before invoking a force majeure clause. If the claiming party does not give proper notice as set forth in the contract, it could preclude successful invocation of a force majeure clause.Businesses seeking to invoke the force majeure clause of their contracts likely have a strong argument that the coronavirus outbreak is an unforeseen event, unless the parties entered into the contract after the outbreak of coronavirus. Whether businesses have also attempted to perform their contractual duties despite the coronavirus outbreak, and whether that is even required under a particular contract are questions that must be assessed on a case-by-case basis.Force Majeure CertificatesOf importance to note is that due to the extent of the coronavirus outbreak and the government-imposed lockdowns in China, a quasi-governmental agency called the China Council for The Promotion of International Trade (CCPIT), backed by Beijing’s Commerce Ministry, has been providing businesses in China with force majeure “certificates.” CCPIT is issuing the force majeure certificates if businesses can provide documents proving that they cannot meet their contractual obligations due to the effects of the coronavirus.[16] Given this fact, if a business in China located in an area on government-imposed lockdown has a force majeure clause in a contract governed by Chinese law, the invocation of a force majeure clause may be successful.Other Options: Impossibility/Impracticability and Frustration of PurposeIf a party is unable to successfully utilize a force majeure clause to excuse performance during the coronavirus outbreak, or if a contract does not contain a force majeure clause, other options may still potentially be available to excuse performance, such as the defenses of impossibility and impracticability.[17] The Uniform Commercial Code (UCC) provides that a seller is excused from performing under a contract when “performance as agreed has been made impracticable by the occurrence of a contingency the non-occurrence of which was a basic assumption on which the contract was made or by compliance in good faith with any applicable foreign or domestic governmental regulation or order whether or not it later proves to be invalid.”[18] The Restatement (Second) of Contracts defines impossibility as “not only strict impossibility but impracticability because of extreme and unreasonable difficulty, expense, injury or loss involved.”[19]Given the fact that the governments of many countries, including the United States, have implemented lockdowns, businesses can argue that performance under their contracts is impracticable or impossible. In the United States in particular, a national state of emergency has been declared. The governors of California, Ohio, Illinois, Washington, and Massachusetts have ordered that all bars and restaurants must close. The mayors of New York City and Los Angeles have ordered that all bars, restaurants, cafes, and theatres must close to slow the spread of coronavirus. Other cities and counties in the United States, including New Rochelle, New York, and the San Francisco Bay area are currently under similar government-imposed lockdowns as well. These factors support the possibility that businesses will be able to successfully utilize an impossibility/impracticability defense.If a contract does not contain a force majeure clause, and an impossibility or impracticability defense fails, another possible defense for a party unable to fulfill its obligations under a contract due to the coronavirus is frustration of purpose. For the doctrine to apply, “the frustrated purpose must be so completely the basis of the contract that, as both parties understood, without it, the transaction would have made little sense. ”[20] Put differently, frustration of purpose occurs where “a change in circumstances makes one party’s performance virtually worthless to the other, frustrating his purpose in making the contract.”[21] Business should be mindful, though, that economic hardship such as an increase in the cost of performing under a contract is not enough to assert a frustration of purpose defense.[22]ConclusionThe coronavirus is having a significant and harmful impact on businesses and their ability to perform under their contracts. However, whether a claiming party can successfully invoke a force majeure clause, an impossibility/impracticability defense, or a frustration of purpose defense in order to excuse performance due to the coronavirus is a fact intensive inquiry and must be assessed on a case-by-case basis. Contractual parties must look to the specific language of the contract, including the applicable law, to determine their likelihood of success.[1] See Ner Tamid Congregation of N. Town v. Krivoruchko, 638 F. Supp. 2d 913, 931 (N.D. Ill. 2009), as amended (July 9, 2009).[2] General Contract Clauses: Force Majeure, Practical Law Standard Clauses 3-518-4224; see also Kel Kim Corp. v. Cent. Markets, Inc., 70 N.Y.2d 902 (1987); Rochester Gas & Elec. Corp. v. Delta Star, Inc., 2009 WL 368508, at *2 (W.D.N.Y. Feb. 13, 2009).[3] Sherwin Alumina L.P. v. AluChem, Inc., 512 F. Supp. 2d 957, 967 (S.D. Tex. 2007).[4] Kel Kim Corp. v. Cent. Markets, Inc. 70 N.Y.2d at 902; see also Allegiance Hillview, L.P. v. Range Texas Prod., LLC, 347 S.W.3d 855, 865 (Tex. App.—Fort Worth 2011, no pet.).[5] Kel Kim Corp. v. Cent. Markets, Inc. 70 N.Y.2d at 903 (citing 18 Williston, Contracts § 1968 (3d ed. 1978)); see also Wisconsin Elec. Power Co. v. Union Pac. R. Co., 557 F.3d 504, 507 (7th Cir. 2009).[6] Constellation Energy Servs. of New York, Inc. v. New Water St. Corp., 146 A.D.3d 557, 558 (1st Dep’t 2017) (quoting United Equities Co. v First Natl. City Bank, 52 A.D.2d 154, 157 (1st Dep’t 1976), affd on op below 41 N.Y.2d 1032 (1977)).[7] Constellation Energy Servs. of New York, Inc, 146 A.D.3d at 558 (quoting Route 6 Outparcels, LLC v Ruby Tuesday, Inc., 88 A.D.3d 1224, 1225 (3d Dep’t 2011)); see also Allegiance Hillview, L.P. v. Range Texas Prod., LLC, 347 S.W.3d at 865; Sun Operating Ltd. P’ship v. Holt, 984 S.W.2d 277, 283 (Tex. App. 1998).[8] Phibro Energy, Inc. v. Empresa De Polimeros De Sines Sarl, 720 F. Supp. 312, 318 (S.D.N.Y. 1989) (citing Kel Kim Corp. v. Central Markets, Inc., 70 N.Y.2d at 902-03).[9] See Rochester Gas & Elec. Corp. v. Delta Star, Inc., 2009 WL at *7; Phibro Energy, Inc. v. Empresa De Polimeros De Sines Sarl, 720 F. Supp. at 318; see also Goldstein v. Orensanz Events LLC, 146 A.D.3d 492, 493 (1st Dep’t 2017).[10] See Perlman v. Pioneer Ltd. P’ship, 918 F.2d 1244, 1248 (5th Cir. 1990)(“Because the clause labeled “force majeure” in the lease does not mandate that the force majeure event be unforeseeable or beyond the control of [the non-performing party] before performance is excused, the district court erred when it supplied those terms as a rule of law.”); See Sun Operating Ltd. P’ship v. Holt, 984 S.W.2d at 288 (“Indeed, to imply an unforeseeability requirement into a force majeure clause would be unreasonable.”)[11] Bloom v. Home Devco/Tivoli Isles, LLC, 2009 WL 36594, at *4 (S.D. Fla. Jan. 6, 2009) (quoting Florida Power Corp. v. City of Tallahassee, 18 So.2d 671, 675 (Fla. 1944)); see also Fru-Con Const. Corp. v. U.S., 44 Fed. Cl. 298, 314 (1999).[12] See Sun Operating Ltd. P’ship v. Holt, 984 S.W.2d at 283-84.[13] El Paso Field Servs., L.P. v. Mastec N. Am., Inc., 389 S.W.3d 802, 808 (Tex. 2012).[14] Id. at 808-09.[15] Commonwealth Edison Co. v. Allied-Gen. Nuclear Servs., 731 F. Supp. 850, 859 (N.D. Ill. 1990).[16]China trade agency to offer firms force majeure certificates amid coronavirus outbreak[17] Id. at 855.[18] NY UCC § 2-615(a).[19] Second Restatement of Contacts § 254.[20] Crown IT Servs. v. Olsen, 11 A.D.3d 263, 265 (1st Dep’t. 2004).[21] PPF Safeguard, LLC v. BCR Safeguard Holding, LLC, 924 N.Y.S.2d 391, 394 (2011) (quoting Restatement (Second) of Contracts § 265, Comment a).[22] A + E Television Networks, LLC v. Wish Factory Inc., 2016 WL 8136110, at *13 (S.D.N.Y. Mar. 11, 2016).