Lex Luthor & Corporate Crimes in Canada

I recently read John Byrne’s mid 1980s classic The Man of Steel, a re-imagining of the original Superman story. This six part mini-series recounted how Superman escaped Krypton, met Batman and the Daily Planet crew, met Bizarro and perhaps most importantly met Lex Luthor and subsequently became his arch enemy. In the fifth comic of the story, Luthor, after an attempt to kill Superman, hides behind the myriad of corporations he controls and shields himself from any criminal responsibility for his actions. Have a look: 

Image from DC's The Man of Steel Vol. 1 #5 (December 1986) Writing and pencils by John Byrne, inks by Dick Giordano, colours by Tom Ziuko & letters by John Costanza. 

From DC's The Man of Steel Vol. 1 #5 (December 1986)

From DC's The Man of Steel Vol.1 #5 (December 1986)

The story has Lex effectively shield himself from the crime by way of his corporation(s). When I read this I thought it might be an interesting issue to discuss in this blog: namely when can a corporation be found guilty of a criminal act? The following entry will examine criminal law and how it relates to the corporate activity within the Canadian context. With hope, you’ll leave here with a better understanding of how Canadian corporate law works and how exactly a corporation can be found criminally responsible for an action it's involved in. For the purposes of this piece I will use the Canadian Business Corporations Act (CBCA) as the statutory basis for our examination. This is the statute used when companies choose to incorporate federally.

We start with the basic idea that a corporation created under Canadian law is a separate legal personality and has, according to Section 15 of the CBCA, the rights of a “natural person”. To better illustrate this Canadians can look back to England to get a sense of what this exactly means. The case Solomon v Solomon Brothers and Company Limited [1897] from the House of Lords held that Mr. Solomon, the founder of the company at issue could not be held personally accountable to creditors for the acts of his namesake company because they were separate legal personalities. This idea was later codified in the CBCA in Sections 15 and 45 with s.45 reading: “The shareholders of a corporation are not, as shareholders, liable for any liability, act or default of the corporation.” This notion, that there was a separation between shareholders and management and the corporation has subsequently been labelled by some as the “corporate veil” and was undoubtedly on Lex Luthor's mind when he taunted Superman. 

The notion that a corporate body has a separate legal personality hasn’t gone without commentary as common law developed and many jurists from both sides of the Atlantic have considered it. In the early 1600s for example, English jurist Sir Edward Coke (pronounced "Cook") in the Sutton Hospital Case (1613) noted that the corporation was “aggregate of many is invisible, immortal and resteth only in intendment and consideration of the law" (sic) and "They may not commit treason, nor be outlawed nor excommunicate, for they have no souls." Centuries later the fourth and longest serving Chief Justice of the United States John Marshall remarked in Dartmouth College v Woodward (1819) that the corporation was "an artificial being, invisible, intangible and existing only in contemplation of law". Clearly these legal greats saw corporations as strictly legal constructs. But this raises the question: what if these legal entities are used for less-than-honourable purposes? Such a consideration brings to mind the observations of Lord Thurlow who wrote in 1844 that corporations had: "neither bodies to be punished, nor souls to be condemned; they therefore do as they like.”

Which brings us back to managers like Lex Luthor who use the corporation to shield their criminal acts. A corporation cannot shake a hand, so it stands to reason it can also not wield a gun or in the case of The Man of Steel #5 a space-suited assassin! These are all issues the courts have dealt with since Solomon as corporations have grown to wield immense power and influence in modern society.

In the 1980s of Gordon Gekko, Lex Luthor was turned from mad scientist to fat cat capitalist criminal. Image from DC's The Man of Steel Vol. 1 #4 (November 1986)

To begin our discussion on corporate criminal liability, we should first briefly look at the basics of criminal fault. In criminal law, there are two principal elements that are needed for a crime to occur: the Mens Rea or the "guilty mind" and the Actus Reus, the "guilty act". Finding an Actus Reus of a corporate crime could require just looking to see if some kind of wrong has occurred. The harder part is finding a Mens Rea because it is somewhat complex to attribute a guilty mind to an abstract legal entity. Moreover, how could the prosecution, acting on behalf of the Crown in Canada, prove beyond a reasonable doubt that the corporation committed the crime? As is usually the case, a look at common law is the best way to understand how the courts have grappled with this issue over time.

Let's begin with the case Lennard’s Carrying Company v Asiatic Petroleum [1915] from the UK's House of Lords. Here Lord Haldane held that the guiding principle in English corporate law would be that: 

The corporation was an abstraction. It has no mind of its own any more than it has a body of its own; its active and directing will must consequently be sought in the person of somebody who for some purpose may be called an agent, but who is really the directing mind and will of the corporation, the very ego and centre of the personality of the corporation.

Sound familiar? Here Lord Haldane essentially tows the Coke line and left the corporation untouched with regard to criminal acts. This notion would remain strong in Canadian law until decades later when it started to get chipped away by judges who saw things differently and pushed the law in another direction. For example, in 1941 the Alberta Court of Appeal in R v Fane v Robinson Ltd. set aside an acquittal of two companies where two of the directors and officers conspired to defraud an insurance company. The judge in this case found that the people responsible were acting and directing the corporation and it was here that we saw the germination of what would become the Identification Theory. The Identification Theory merges a Mens Rea with a corporate body using something called the Directing Mind.

For the Identification Theory to work the Directing Mind must use the corporation as a means to commit the crime while at the same time be at the centre of its operations. For example in R v St. Lawrence Corporation [1969] the Ontario Court of Appeal (the highest court of Canada’s largest province and one step below the Supreme Court of Canada) held that the officer or senior official must be a "primary representative through whom the company acts, speaks and thinks." St. Lawrence also remarked how actions taken outside the official responsibility of the leader do not fall within the Identification Theory. So if Lex Luthor was embezzling money from one of his companies then it would be another matter entirely because the company is the victim. In this instance it would be up to the shareholders to sue Luthor on behalf of the company in what is called a Derivative Action. 

Luthor could never understand why Superman didn't want to work for him. Imagine that! Image from DC's The Man of Steel Vol.1 #4 (November 1986)

A good example of the Identification Theory at work is in R v Waterloo Mercury Sales Ltd. [1974] from the Alberta District Court. In this case the sales manager of a car dealership reversed odometers to help sell cars. The dealership had a policy against this clearly fraudulent activity, but it was still not enough to keep it blameless because the individual doing the tampering was the directing mind for the purposes of the criminal activity.

Image from DC's The Man of Steel Vol. 1 #4 (November 1986)  

Since 1985 the most important case relating to corporate criminal responsibility has been R v Canadian Dredge and Dock Ltd. which was heard before the Supreme Court of Canada. In this case several corporations were charged with fraud after colluding in bidding for a contract to dredge Hamilton Harbour at the west end of Lake Ontario. The group's plan was to low-ball one offer and then have the winning company issue contracts to each of the losing partners. Here the court upheld the Identification Theory and stated that when the operating mind, brain area or ego of the corporation was so identified with the act of the individuals then the legal entity (the company) became the source of primary liability. This marked a near entrenchment of the Identification Theory into Canadian law.

And in light of the power corporations have in Canadian society, it should surprise no-one that in 2003 the Canadian parliament passed amendments to the Criminal Code of Canada that redefined the circumstances in which corporations could be held criminally responsible. The current law says that it is no longer simply a Directing Mind that needs to commit the crime, but now it can also include a representative, senior officer or anyone who was knowingly involved in the offence in a specific way, even if they did not actually commit it. The Code also expands liability so that the Mens Rea of the crime may be split into multiple representatives of the corporation and can now include not just directors and officers but also employees, agents and even contractees. 

So there you have it: a little bit about corporate criminal acts and Canadian law using Lex Luthor as a prompt. I hope you enjoyed it and even learned a little something with the help of an important comic mini-series.  As for The Man of Steel itself, it was good trade-paperback. A little dated as happens with 80s comics in 2014, but still an enjoyable reading experience. As always, thanks for stopping by and happy reading! 

Exploring the Nebulas: 2013 winner Kim Stanley Robinson's 2312

Welcome to the first edition of Exploring the Nebulas, a new ongoing series from WGTB. In this series we will briefly review novels that have won the Nebula Award, the prize awarded by the Science-Fiction and Fantasy Writers of America as the best novel of that genre each year. The scale used to rate each book is one of three: Good, Great or Legendary and the first winner to be reviewed is also the most recent; 2312 by Kim Stanley Robinson.

2312, Kim Stanley Robinson, Orbit, 2012, pp. 576, C$ 29.00

2312 is Kim Stanley Robinson’s second Nebula win for Best Novel (his previous being Red Mars in 1993) and continues in a similar vein as a more 'high' or even literary science-fictional work. The book is set in the eponymous year and envisions the Solar System as a place where humans have moved to almost every major planet or planetoid available including Mercury, the home of our protagonist Swan Er Hong. Space travel is achieved through massive hollowed-out asteroid-ships called Terrariums that also serve as giant nature reservations or specialised theme parks. Other technological and societal advancements include space elevators on Earth and Mars; a moving city on Mercury; a free and independent Martian republic; a massive Venetian blind-like heat shield above Venus; the insertion of animal genetic material into human beings; as well as changes to human sexual organs. Despite all these amazing achievements, perhaps the most significant advancement is artificial intelligence that has both augmented the human brain and is on the verge of becoming its own political force. The Earth of 2312 is much less amazing and has become the "sad planet" with years of abuse and environmental degradation having left it a poverty stricken mess. Indeed, the damage caused by humanity has led to near extinction for many of its species and this is a major theme of the story. 

For the most part this Nebula winner is good, but is not without its problems. The book is interspersed with quasi-scientific "Excerpts” and “Lists” that provide insight into our future and at times are very interesting. But I also found that they could be distracting and towards the end of the story found them to disrupt the flow of the story which made the book feel longer than it needed to be. In 2312 Robinson also doesn't hide his politics and heartfelt belief that the prevailing economic system that we know, namely "capitalism", needs to be eliminated and the story has an economy of 2312 effectively extinquishing it by use of powerful computers. Personally, I'm highly skeptical that the future will confine capitalism to the domain of hobbyists and collectors as Robinson has, but the author is entitled to his opinion and – while having a significant political aspect to it – 2312 can be enjoyed by someone who doesn't agree with the author's politics.

The biggest problem I have with the book is that while it was very long, the ending was too Deus ex machina for my taste and appeared (paradoxically) rushed. I don't want to spoil the story for those who have not read it, but it's essentially a "who did it" caper, yet ends so abruptly and easily that it gnaws away at the suspension of disbelief every reader carries. Of course, it's likely that the intention of the book was that the journey was to be its own reward, and to this end it was speculative science-fiction done well. Not great, and by the final hundred pages I was ready to move on, but good. As such, it gets that exact rating: 2312 is a Good Nebula winner.   

*At the time of posting 2312 was the most recent recent Nebula Award winner for best novel. The ceremonies for the 2013 books take place in San Jose, at the San Jose Marriott, May 15-18, 2014.  

Exploring the Nebulas: A New Series from WGTB

This year I’m starting a new blog series called: “Exploring the Nebulas”. Being a sci-fi fan, I’ve long understood the importance the Nebula Awards have to readers and writers of science-fiction and fantasy. Yet, while I’ve read a lot of these books, I haven’t yet read them all and have wanted to do so for many years. So to start 2014, I'm setting out to accomplish this goal and will write a short review for this blog after each book.  

Logo of the Nebula Awards.

As I'm not a particularly fast reader, this is a significant time commitment and I may not get it accomplished before the natural life of this blog comes to an end. But I’m going to give it my best and may even cheat by posting reviews of winners I've read within recent memory. I've also decided not to keep any specific time commitment (a book per week for example) or to read them in chronological order, so this should make things a little more manageable. Also, reviews will not be long, and given that each book has already been well received, I will won’t pick them apart. I will however point out where I think they might have been better and note how the genre has evolved from the first winner Frank Herbert's Dune (1965) to its most recent, 2312 (2012) by Kim Stanley Robinson. I’ll also note any sequels, prequels, comics, television shows, films, etc. that are related and of interest to readers of this blog.

As well as documenting winners, I’ll also read and review significant runners-up or books that with 20/20 hindsight might have won the prize instead. The best example of these would be George R.R. Martin’s, A Game of Thrones, A Clash of Kings and A Storm of Swords which were nominated for the Nebula Award for Best Novel in 1996, 1997 and 2001 respectively but did not win. These novels are now (arguably) more famous than any other winner or nominee thanks in large part to the popular HBO television series Game of Thrones. 

Title card of HBO's popular television show Game of Thrones. This led to a resurgence of George R.R. Martin's books with A Game of Thrones reaching #1 on the New York Times Bestsellers List in July 2011, 15 years after its initial release.  

What are the Nebula Awards? 

The Nebula Awards stand at the pinnacle of American science-fiction and fantasy writing. They are voted on each year by members of the Science Fiction and Fantasy Writers of America (SFWA), a professional association that works to advance the interests of its members. To qualify for membership, one must have sold one novel or script or three short stories and membership is not exclusive to Americans. The SFWA's Nebula Awards are – along with their International cousins the Hugo Awards – presented each year to the winner. The five categories for the Nebulas include: Best Novel, Novella, Novelette, Short Story and Script. Perhaps unsurprisingly, while the first Nebula for Best Novel was awarded in 1966 and the first Hugo in 1954, there has since been considerable overlap, with the winner of the Nebula Award having won the corresponding Hugo on 22 occasions. 

The Nebula Awards for 2013 will be awarded In San Jose, California in May 2014 and I'll certainly follow that contest closely. In the meanwhile, I hope you enjoy Exploring the Nebulas and when the reviews are up, please feel free to voice any opinions you have about the reviewed book. And as always, thanks for reading WGTB.   

Celebrating J.R.R. Tolkien

John Ronald Reuel Tolkien was born on January 3, 1892 in Bloemfontein, Orange Free State in what is now the Republic of South Africa. The son of an English banker and homemaker, Ronald's (as he was called by his family) father passed away when he was three years old on an extended visit to England. The sudden loss of a livelihood for the family meant Ronald's family would not return to Africa, and soon found themselves living with maternal grandparents in the Birmingham suburb of Kings Heath. 

The Tolkien monogram

As a boy, Tolkien would often venture off and explore the hills and valleys of the Midlands of England, with these childhood adventures undoubtedly leaving a lasting and indelible impact on his imagination. When a monetary gift enabled young Ronald to attend the King Edward's School in Birmingham, his mother relocated the family to that city and gave the young student an important opportunity to learn at a very prestigious school. Already attending a Roman Catholic church (mother Mabel had been received into the Catholic faith in 1900) Tolkien soon came under the guidance of one of the priests of the Birmingham Oratory and a Catholic education would always have considerable weight on the thinking of Tolkien. He remained a devout Roman Catholic until the end of his days.

J.R.R. Tolkien in a Great War uniform of the British Army.

When he was just 16 years old, Ronald met Edith Mary Bratt, the 19 year old daughter of a Handsworth shoemaker. Shortly before his 21st birthday, Ronald wrote her a letter and proposed marriage. Already betrothed to another, Edith never-the-less returned the ring to her previous suitor and the couple were married on the 22nd of March 1916. Although there had already been two years of the "War To End All Wars", Tolkien elected to finish his degree before taking a commission as a Second Lieutenant in the Lancashire Fusiliers, a local infantry regiment. He was later transferred to the 11th Service Battalion of the British Expeditionary Force in 1916 and after arriving in France was moved again, this time to the front where he participated in the massive Somme Offensive.

He would not be there long though. In late October 1916 Tolkien contracted trench fever, a lice-borne illness that was endemic to those horrible conditions. This may have been a blessing in disguise because it was at the Somme and specifically Beaumont Hamel that Tolkien would lose many of the friends with whom he had joined the army. It was also during his recovery that he started work on stories that would later become the First Age of Middle-Earth, which included many massive and catastrophic battles between the forces of good and evil.

After the war and his recovery, Tolkien took a job with the Oxford English Dictionary before finding an academic position as a Reader (Lecturer) at the University of Leeds in 1920. Five years later he moved south to Oxford and was named the Rawlinson and Bosworth Professor of Anglo-Saxon and a Fellow of Pembroke College. It was at Oxford that he would encounter that less-than-exciting student paper on which he wrote: "In a hole in the ground there lived a Hobbit." The finished manuscript of The Hobbit would eventually find its way into the hands of publisher Stanley Unwin (with the help of a favourable review by Stanley's son, Rayner) and onto book shelves by September 1937. 

Tolkien in Oxford during his later years

The Hobbit would go on to significant acclaim and when Mr. Unwin asked for a sequel, Tolkien set about completing the manuscripts for what would eventually become the darker and more mature The Lord of the Rings. This volume used one of the minor items found in The Hobbit as its key plot device and ended with the dark lord Sauron overthrown by the combined forces of good led by the wizard Gandalf, Frodo Baggins of the Shire (another Hobbit) and the rightful claimant to the throne of two ancient kingdoms. Originally intended as a one volume book, it was subsequently divided into three separate volumes with the final volume The Return of the King released in October 1955. In subsequent years The Lord of the Rings would garner astonishing levels of popularity and is currently the second best-selling single volume book of all time, behind only Charles Dickens' A Tale of Two Cities. It has also been subsequently transformed into films (both live-action and animated), comic books, theatre shows and other media.
  

The Eagle and Child in Oxford was the pub where the Inklings would often meet to talk about their books. Photo by Author.

In 1977, four years after his death on September 2nd 1973, The Silmarillion, a collection of the tales of Tolkien's First Age of Middle-Earth, was edited by his son Christopher and Canadian Guy Gavriel Kay, and released for readers. This volume, much more dense and historical than The Lord of the Rings never-the-less remains my favourite book. In late 2011 while visiting Oxford, I had the good fortune of having a pint in one of the pubs where Tolkien's group of friends, the "Inklings", met regularly to discuss literature and religion among other things. It was a highlight of my time living in England and I'll be certainly be raising a pint of Ale for him again tonight, as I celebrate what would be J.R.R. Tolkien's 122nd birthday. 

All that is gold does not glitter,

Not all those who wander are lost;

The old that is strong does not wither,

Deep roots are not reached by the frost.

From the ashes a fire shall be woken,

A light from the shadows shall spring;

Renewed shall be blade that was broken,

The crownless again shall be king

WGTB Reviews Robotech Voltron #1

The first novel I ever attempted to write was a Star Trek/Star Wars crossover. I was a teenager and the story began with heroes Kirk and Spock blasting through a wormhole where they came across an Imperial Star Destroyer and found themselves in a shooting battle. This type of story – a property crossover – wasn't original and had been tried many times over, especially in comic books. For example, when Marvel owned the licences to the Hasbro properties GI Joe and Transformers, they produced a four part crossover mini-series in 1986. More recently, Star Trek: The Next Generation crossed with the BBC’s Dr. Who in 2012 in an eight issue mini-series by IDW. And just a couple months ago, IDW further announced that it was going back to the Hasbro well with Joes and Autobots being mashed together again, this time in an ongoing series beginning in the summer of 2014. 

Dynamite Entertainment's Robotech Voltron Vol.1 #1 (December 2013) Written by Tommy Yune, art and letters by Digital Art Chefs Team, pencils and digital inks by Elmer Damaso, Production Manager: James L. Parabay. Supervisor for colours and letters: Melvin Calingo 

So it was with these past comics in mind – as well as a dose of cautious nostalgia for two properties I loved as a kid – that I picked up Voltron Robotech #1, the first issue of a new five issue mini-series by Dynamite Entertainment. To this day I still read and enjoy the 1980s Comico Robotech comics and have always wanted to see Voltron as a comic book. (I do not know of another Voltron comic series.) That said, the aforementioned caution comes from the fact that while both properties are anime, other than that they don’t have a whole lot in common. Voltron for instance takes place in a distant future or universe that has a magical quality to it, while Robotech is a harder and more military-focused science-fiction. Below are two pages from the comic dealing with the Voltron and Robotech properties respectively.  

This page focuses on the Voltron aspect of the comic...

...and this one the Robotech.

So how did a comic merging the two properties together do? Well, while I’m always a little hesitant to judge a series on the merits of one issue, I have to say for the most part I was underwhelmed by this comic. Sure, in this short introduction to the story, the creators needed to re-establish two universes – no easy task – but I found much of the opening aspects of the comic rather unnecessary. For example, the first three pages consist of the old Voltron Peter Cullen TV voice over, and this could have been easily finished in the splash. From there I found the rest of the book sparse with its written story-telling almost devoid of captions that would have been very helpful in explaining how these two diverse stories were coming together. Blending two established canons is very difficult, and the book should have errored on the side of more information rather than what they did in issue #1. 
   

What on Earth indeed?

That said, the art of this book is good and has a classic anime feel to it. The colour palette is rich, as would be expected of this sort of book, and there are no surprises with the panels looking much like anything that's been seen a hundred times before in either Voltron or Robotech. Because of this, if you're inclined to read this type of comic, I'm not going out on a limb in telling you that you already know exactly what you're getting.  

All above images from Robotech Voltron #1 (December 2013) 

But overall the story just lacked a coherent punch to really excite me. Make no mistake, I'm very forgiving of these first issues and will pick up the second. But this is largely on the strength of my affection towards these properties rather than the first issue. Things could turn around, but as things stand it's unlikely I’ll buy #3. For that to happen the second issue will have to have much stronger story-telling and give us more of the great characters we know from both of these properties. Combining these two properties was a cool idea, but because it's otherwise a lacklustre comic book, issue #1 of Robotech Voltron only gets 2.5/5 STARS.

Merry Christmas from WGTB!

I would like to wish all of my readers a very Merry Christmas and Happy New Year. 

May your holiday be filled with good cheer and fun with family and friends. And may your 2014 be filled with lots of great sci-fi stories and comic books. Talk to you soon!

Image from National Publications (DC Comics) Comic Cavalcade #9 (Winter 1945)

WGTB Reviews Two Generals

I remember back in 2005 when I prepared a eulogy for my grandfather. I wanted to write something that was both short and enjoyable, yet grasped the gravitas of a long and distinguished aviation career that began as a fighter pilot in the early 1940s. Coming from small town Saskatchewan, Grandpa learned to fly in Canada before heading to Britain and eventually fighting over North Africa and Europe, ultimately surviving the war and returning to a career as a bush and corporate pilot. Being a humble man, Grandpa never bragged about his remarkable career but would occasionally sprinkle his conversations with fascinating stories about the various adventures he had during the war at Christmas and Easter dinners or at the mutual birthday parties we celebrated (I was born on his 57th birthday).  

Two Generals, Scott Chantler, McClelland & Stewart, 2010, pp. 145, C$ 27.99

I mention Grandpa because he came to mind as I read Two Generals, a graphic book by Canadian writer and artist Scott Chantler. In Two Generals Chantler tells the story of his own grandfather, Law Chantler and Law's best friend Jack Chrysler who both fought in the same war my grandfather did. Grandpa is also the reason that, while I don't normally review books almost four years old, I had to write this piece to tell my readers how much I enjoyed it.

Two Generals is a story about two friends serving in the Second World War. The book was written and drawn by one of these men's grandsons. All images from Two Generals.

As mentioned, Two Generals tells the story of two good friends. Not generals, but commissioned officers from Canada during the Second World War. From their origins in small Ontario towns, the two friends head off -- one married and the other a charming bachelor -- to do their part to end Hitler’s tyranny and win the war for King and country. Throughout the story we follow the lads and their experiences as they join the army, head to England, drink and enjoy themselves in London, train for battle and then, after waiting and waiting, finally launch towards France. As members of the Highland Light Infantry of Canada, the men arrive during “Operation Overlord” (better known as the D-Day invasion) and after helping secure Juno Beach, head into occupied France where they experience the same highs, lows and horrors that so many of their friends and colleagues did during that hellish time.

The book is mostly grey, olive green and white, with red used to illustrate danger-focused points.

The story is both a tribute to the two soldiers and educational experience about the horrors and frustrations of war. The art, while not especially complex has a delightful story-telling quality and matches the flow of the dialogue and overall narrative seamlessly. It also selectively uses the colour red to mark points of hazard, which is very effective and gives the reader a sense of foreboding and danger as it happens. All of this makes it a very accessible book for a non-comic book reader and my father for example, not having read a comic book since the 1960s, was able to pick up Two Generals and get into the story immediately. And of course part of this book's charm is that it's a great story. We often hear about the bonds people forge during the toils of war – this is something I knew about my Grandpa – he loved his squadron buddies as much as anyone in his family. How these types of friendship are formed in very clear from this story and when the author describes how Law and Jack's friendship came to an abrupt end towards the end, it literally brought a tear to my eye. It was that sad. 

While focusing on the army, Two Generals doesn't ignore the overall horror that all those fighting faced.

Simply put, this book is a credit to the comic book medium and a great way to introduce any reader to both comics and the history of the Second World War. It doesn't glorify wars, rather explains what happens to many of the people who go off to fight in them. My only problem with the book is that it seems to have a slightly higher price-point than needed, and this might dissuade buyers. This issue won't really be a problem for teachers and libraries, and is probably mitigated by the fact that it's available in softcover now, but if you're looking to spend a little more than you might normally for a trade paperback, then I highly recommend Two Generals. I guarantee you'll read it again and might even share it with someone who's interested in WWII. 4.5/5 STARS