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The ATF got caught in a lie, then blamed you. Long read.
I am not someone who complained about people getting forms faster, but I am someone who despises fake efficiency / metrics. Believe what you will, but with all the complaining about the ATF, I was a little shocked a lot of people jumped on the bandwagon from the BS they fed people. I am referring to the guns america article, where the ATF claimed they were pushing through form 4s without errors (but you know.... only from after late June) but stopped because people complained. https://www.gunsamerica.com/digest/exclusive-atf-kills-program-fast-tracked-nfa-items/
This is going to be a LONG read, full of information. I highly recommend you read this and get fully pissed off at the ATF, more than you've ever been. Write the your congress critters, whatever. TLDR right here - the ATF is full of crap and got caught falsifying their NFA branch efficiency, at the cost of millions of taxpayer dollars, then blamed you for it.
Look folks. The ATF is pulling a fast one on everyone because people have a massively short attention span. First off, as I have posted a few times, it is my belief the ATF got caught (thanks to people complaining) trying to fake their efficiency by approving new forms fast, and leaving old ones behind. Again, I think it is super awesome that people get forms back quickly, BUT THIS INHERENTLY FIXED NOTHING ABOUT THEIR SYSTEM. All they were doing was approving forms out of order, giving the appearance that some new and improved system had been set in place, when no such thing happened. So let me lay this out with facts and budget requests.
The ATF was approved and given EXTRA money, more than requested by the DOJ, for fiscal year 2019 (October 1, 2018 to September 30, 2019) with one of the specific goals for that extra money to get eforms started asap. This is straight out of the commerce bill passed by congress, which can be found here: https://www.congress.gov/congressional-report/115th-congress/house-report/231/1
Bureau of Alcohol, Tobacco, Firearms and Explosives SALARIES AND EXPENSES The Committee recommends $1,293,776,000 for the salaries and expenses of the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), which is $35,176,000 above fiscal year 2017 and $20,000,000 above the request. ATF's highest priority shall be to combat violent crime and promote public safety. The recommendation maintains current services, and fully funds the requested increases for violent crime reduction task forces and the National Integrated Ballistic Information Network (NIBIN). An increase of not less than $10,000,000 above the request is for the activities of the National Firearms Act (NFA) Branch, Federal Firearms Licensing Center, Federal Explosives Licensing Center, Import Branch, and to develop and implement ATF's next generation eForms system. Investigative Support Services.--The Committee is concerned about the ongoing backlog in processing firearms licensing applications within the 60 day time frame as mandated under current statute. In addition, there is a need for additional resources to meet ongoing associated infrastructure requirements and improve the processing of import applications. The Committee is also concerned about ATF's failure to prioritize improvement of eForms. This electronic filing process was created by ATF to reduce submission and processing times, as well as data entry processing backlogs. Unfortunately, despite the Committee's encouragement to pursue improvements, the system remains antiquated and lacks the kind of innovation and user-friendly features expected. The Committee expects this increase in funding will provide additional resources focused on the aforementioned priorities, and directs ATF to report to the Committee in the expenditure plan required by this Act on how these funds will be allocated. NIBIN.--The Committee is encouraged by the promise of improved crime gun intelligence and information sharing, and expects funding provided in this bill will aid in interdicting crime guns and preventing gun trafficking through the NIBIN. The Committee encourages ATF to establish a NIBIN presence on the Southwest Border. Counter-improvised explosives devices.--The Committee supports the work of the National Center for Explosives Training and Research on countering advanced improvised explosive devices."So, lets get things straight here. The ATF / DOJ initially requested 15 million dollars or so to keep things rolling and business as usual. Congress instead passed a budget that instead gave them 20 MILLION more than requested, with a specific request that they finally get eforms back online like ASAP. The ATF instead turned Eforms 1 on (which is awesome) and said "Lol we are bug testing". Thats that. Now, as you read above, the ATF is expected to give the committee an expenditure plan. Their plan can be found here https://www.justice.gov/jmd/page/file/1034486/download
And on page 43, you can find the information for NFA branch budget, I will paste some highlights -
ATF requests additional funding and FTE for the NFA Division for the timely and effective registration of restricted weapons and to support law enforcement criminal prosecutions. This effort will provide support in processing NFA applications within a 90-day time frame. The NFA Division relies heavily on legacy business applications to automate the current business processes. These legacy applications are partially integrated through antiquated technologies. Over time, NFA has implemented manual business processes to overcome limitations of these business applications. After completion of a business process reengineering effort in FY 2018, NFA intends to replace these legacy business applications with modernized technologies that will automate the new business processes.90 day time frame?? That did not happen at all until June, and not once before that unless there was an expedited reason.
Page 44 and 45 of FY 2019 budget.
eForms Modernization This enhancement is required for NFA system modernization to address limitations in the NFRTR database as well as modernization of eForms for full automation processing and legacy 45 system upgrades. Current requirements for this modernization are approximately $6.9 million recurring through FY 2021. In 2018, the President’s Budget included $1 million for a Business Process Re-engineering effort. When that effort is complete, ATF will develop an Acquisition Strategy for a software development effort using an Agile Methodology and issue the contract to a vendor. We expect the vendor to deliver a minimally viable product within 6 months that will be ready for the public to use. It is expected to take three years to fully complete this project. A significant benefit of Agile Development is that it allows for the implementation of small modules on an ongoing basis, providing users incremental increases in functionality. This significantly reduces the risk of failure, while providing the best value for the taxpayers.Thats right folks. Right here, the ATF admitted its going to take years to get Eforms back online, potentially through 2021. Keep on waiting, eform 4s!
ATF's current eForms portal allows the firearms industry to file non-tax paid application forms electronically rather than via paper. eForms needs to be extended to individual taxpayers and members of the public. Electronic filing will permit ATF to process applications submissions more efficiently and with significantly reduced processing times. With the requested funding in FY 2019, eForms will be able to encompass all NFA forms as well as forms related to the importation of firearms and ammunition.Page 46:
ATF Legal Instrument Examiners process NFA applications. ATF currently has 29 examiners on board, and based on volume projections of applications, ATF is requesting 13 additional examiners to reach a total staffing need of 42. This level of examiner FTEs is needed for ATF to meet DOJ performance measure of 90 days.Boom. Right there. With this extra money, WE CAN HAVE EFORMS FOR ALL NFA FORMS in a FEW YEARS! With this extra money, we can hire more people and get wait times down below 90 days! Did. Not. Happen.
So, its late June, and the ATF is basically three months away from the end of the fiscal year. They've hired extra staffers. They've got the money. And a commitment to get under 90 day approvals. Hmmmmmmmmmmmmm. Suddenly, form 4s are coming back in record times! HOW BIZARRE!
Now let's look at the FY 2020 budget request by the ATF, submitted in March 2019 mind you.
There is not even one mention of eforms (eforms were mentioned 18 times in the 2019 budget request), bringing down wait times, nothing. Just that the department is backed up still, and less than 3% of applications were done in under 90 days in 2018. We have no 2019 data from them yet, but you can bet your ass that it was supposed to be higher than 3%, especially with their new examiners. So, now when the data becomes available, the ATF can say, "See? you gave us more money, and (made up number) 10% made it in under 90 days! We just need more money!!!"
ATF’s FY 2019 budget request, which totals $1,316,678,000 for Salaries and Expenses
ATF’s FY 2020 budget request totals $1.368 billion for Salaries and Expenses (S&E)
52 million more dollars, more than likely losing the alcohol and tobacco portions of their bureau, but keeping prior funding and requesting more. No more hiring, nothing. Wait times are not going to improve folks. This was all a facade to try to get as many forms as possible in under 90 days before getting caught in an effort to make it appear as if the extra money they were allocated was used efficiently. Literally less than 1% of ATF employees deal with NFA forms. 49 examiners (now that hiring was done), over 5100 employees. Christ, before the hiring, less than HALF A PERCENT dealt with it.
Folks, stop blaming other NFA item owners for this ending. I know it sucks its over, but it was going to end eventually. Just be happy for those who got forms back quickly. and lets pray for speedy approvals for those still waiting on forms from 2018 for God sake. I am not one of those people).
(I wrote the original post in the NFA reddit. Someone suggested I post it here.)
Third Party Food Delivery (Pros and Cons)
Although the feedbacks were great, they were scattered.
So I spent the last 3 weeks researching and compiling all the data I could gather of the 4 most popular platforms (GrubHub, DoorDash, UberEats, and Postmates).
Today, I've decided to share with you everything I have learned.
If you're not into reading (because I sure don't... xD), I've also made a video that's a lot more comprehensive than what I will be posting below. https://www.youtube.com/watch?v=gHXM7BvAuW0&t=273s
So here it goes:
Pros: 1. Marketing: GrubHub alone had over 22 million users in 2019. DoorDash had over 19 million users in 2019. Because these platforms have such a large user base, it's easy to see how they can help generate business for restaurants. Unlike promoting on Google Ads or Facebook Ads, advertising on these platforms put you directly in front of hungry customers. In addition, aside from catering to local customers, tourists who visit your city will also seek out your restaurant via these food delivery platforms.
- Business Boost: McDonald saw 19% ($4 billion) of its total revenue coming in from its third party delivery partners. According to the NPD Group, an American market research company, restaurants should expect a 20% increase from these delivery platforms. As more and more people utilize these services, restaurants can expect an even bigger increase in sales. On this subreddit, people have seen an increase in revenue between 5-30%. Putting yourself on these delivery platforms will definitely increase your revenue. No doubt about that. Also, food delivery allows you generate more revenue without the need to expand your restaurant capacity.
- Convenience: These food delivery apps provide convenience to customers and restaurant operators alike. Customers who have disability or are stranded at work can utilize these platforms to order yummy food from restaurants. Restaurant operators don't need to worry about hiring their own in-house drivers, driver insurance, company car, and the need to host their own online delivery platform (ChowNow). When the weather is horrible outside, customers are less inclined to go out, but you can still reach them with these delivery services. Let's take the current situation for example, restaurants are forced to close down due to COVID 19, but they can still run their business with delivery and takeout. Without these delivery platforms, most of us will really be struggling to make ends meet.
Cons: 1. High Commission Fees: The commmission fees can range from 15-30%, but the with the average hovering around 25%. Some restaurants partnering with Uber Eats have reported to paying as high as 30% in commission fees. The profit margin in the restaurant industry is around 5% so yes these commission fees are way too high and will eat into your profit margin. If you're in the quick service restaurant industry, you might not suffer as much as those in the full service restaurant industry.
- POS Integration: POS systems were never designed with these third party delivery apps in mind. They can't receive orders from multiple third party delivery platforms. You will need 1 tablet to run each of these delivery apps and then enter all the orders individually into your POS system. Some may argue that you don't need to partner with all of the third party delivery apps. Other argue that you should partner with as many as you can to put yourself out there in the public. One solution to this problem is to integrate a software that's designed to streamline and integrate all third party delivery orders into your POS system. This way the orders from these platforms will automatically show up on your POS system (Upserve).
- Delivery Flaws: Sometimes the food is made, but are just sitting there on the counter for a long time before somebody finally comes to pick it up. In worse case scenario, nobody comes to pick it up. Why? Because customer who ordered it is probably 10 miles away from your restaurant so the couriers refuse to drive that far for little money. If the food is cold, spilled, or late, the restaurant gets the blame and also garnered a bad review. According to a study by Off-Premise Insights in 2018, 82% of the customers blame the restaurants for any bad experience with their online orders, and not the delivery companies.
- Quality: Convenience. Kills. Quality. Some food are just not meant to be delivered and won't survive the long journey to the consumers especially on a summer day. What happens if a customer gets food poison? Well, remember that 82% of the customers pin their blames on the restaurants. And if you look at the Terms of Services on those third party delivery platforms they explicitly deny any responsibilities if something goes wrong.
- Lack of Upselling: We all know that most of the profits don't come from the meals. They come from beverages, appetizers, and desserts that we're able to upset while the customers are in our establishment. Very rarely do customers order coke or any type of dessert when they order delivery. If you sell alcoholic beverages, which has a high profit margin, you'll be disappointed to know that numerous cities prohibit the delivery of alcoholic beverages.
- Less tips: Most people who order takeout don't leave tips. On these delivery platforms, users are given the choice to leave tips.....to the drivers. There's no option where they can actually tips the restaurant establishment. Your staffs are going to resent you for having them to work harder for less tips. This results in employee turnover. And we all know how expensive and time consuming it is to train a staff.
- Cannibalization: The number of on-premise dining is slowly being cannibalized by the number of off-premise dining. As more people resort to eating at the comfort of their home with Netflix, they are less inclined to eat out. A 2018 survey reported by Morgan Stanley showed that "50% of consumers use delivery apps to directly replace visiting the actual restaurant." Looking at the current trend of the restaurant industry, off-premise dining will soon surpass that of on-premise dining. And that's very bad news because we all know that even as off-premise dining is on the rise, our profit margin will continue to shrink since delivery has always been less profitable as our dine-in orders.
- Kitchen Backlog: Delivery orders can easily overwhelm your kitchen especially when you're partnering with all 4 of these popular delivery apps. Sure, you can turn them off during peak hours and only use them during off-peak hours, but you can never predict when a large group of customers will suddenly walk through your door. Sometimes your off-premise customers will clash with your on-premise customers. There are several negative Yelp reviews (you can see it on my YouTube video) where the customers are tired of waiting for so long while the couriers go in and out the door with bags of food, or that the servers are less attentive because they're busy packaging the delivery orders.
- Food Stealing: Yeah, it's real. And it's quite common as well. In a 2019 survey conducted by US Foods, an American food service distributor, 54% of the 500 food delivery drivers surveyed admitted to being tempted by the smell of the customer's food, and 30% of the drivers confessed to eating the food they're suppose to be delivering. That's like 1 in 4 drivers! You can find some to these disturbing videos on YouTube as well.
- Shady Business Practices: There are too many to go into detail here so I'm just going to list them here and if you want to know the details then please head to my YouTube video. (DoorDash courier's tipping policy, delivery companies delivering without restaurants' consent, price inflation/increasing your digital menu prices on their platforms without your permission, GrubHub domain fiasco, GrubHub/Yelp call charges lawsuit.
- Environmental Impact: Even if you don't care about the environment I'm just gonna put it here anyway. Food delivery is on the rise, and so is the mountain of trash these food packagings are generating. The World Economic Forum estimated that people throw away 40 billion plastic utensils every year in the US alone, and 120 billion pieces in India annually. 79% of the world's plastic is not recycled, harming wild lives and clogging infrastructures. In 2019, UberEats stepped up their environment effort and initiated an "Utensil Opt-In" policy whereby consumers must personally request for straw, cutlery, and other miscellaneous items if they want them.
- Lack of Loyalty: I'm not talking about the lack of loyalty for the restaurant establishments. I'm talking about the lack of loyalty among these third party delivery platforms. Consumers typically go to apps that are offering free deliveries or some type of discount promotions. As you can see, users are being treated so well by these delivery companies while their restaurant partners get the short end of the stick. And how can these delivery companies afford to hand out free deliveries so generously? Oh yeah, it's because the restaurants have to pay 15-30% in commission fee to compensate for that side of loss.
Do you think it's a good idea to partner with these third party delivery services?
They're sure to help you generate more revenue, but does this revenue mean profit to your or does it end in a loss?
There are 2 camps of restaurant operators: 1. Advocates. Those who think that if "you can't beat them. You join them." There's no doubt that off-premise dining is on the rise and if you don't get into it you'll get left behind.
- Critics. Those who don't want the hassle of dealing with these third party delivery companies and know full well that partnering with them will ultimately lead them to bankruptcy.
Thanks for reading, and stay safe! :)