meaning of case study in computer

The Ultimate Guide to Qualitative Research - Part 1: The Basics

• Introduction and overview
• What is qualitative research?
• What is qualitative data?
• Examples of qualitative data
• Qualitative vs. quantitative research
• Mixed methods
• Qualitative research preparation
• Theoretical perspective
• Theoretical framework
• Literature reviews

Research question

• Conceptual framework
• Conceptual vs. theoretical framework

Data collection

• Qualitative research methods
• Focus groups
• Observational research

What is a case study?

Applications for case study research, what is a good case study, process of case study design, benefits and limitations of case studies.

• Ethnographical research
• Ethical considerations
• Confidentiality and privacy
• Power dynamics
• Reflexivity

Case studies

Case studies are essential to qualitative research , offering a lens through which researchers can investigate complex phenomena within their real-life contexts. This chapter explores the concept, purpose, applications, examples, and types of case studies and provides guidance on how to conduct case study research effectively.

Whereas quantitative methods look at phenomena at scale, case study research looks at a concept or phenomenon in considerable detail. While analyzing a single case can help understand one perspective regarding the object of research inquiry, analyzing multiple cases can help obtain a more holistic sense of the topic or issue. Let's provide a basic definition of a case study, then explore its characteristics and role in the qualitative research process.

Definition of a case study

A case study in qualitative research is a strategy of inquiry that involves an in-depth investigation of a phenomenon within its real-world context. It provides researchers with the opportunity to acquire an in-depth understanding of intricate details that might not be as apparent or accessible through other methods of research. The specific case or cases being studied can be a single person, group, or organization – demarcating what constitutes a relevant case worth studying depends on the researcher and their research question .

Among qualitative research methods , a case study relies on multiple sources of evidence, such as documents, artifacts, interviews , or observations , to present a complete and nuanced understanding of the phenomenon under investigation. The objective is to illuminate the readers' understanding of the phenomenon beyond its abstract statistical or theoretical explanations.

Characteristics of case studies

Case studies typically possess a number of distinct characteristics that set them apart from other research methods. These characteristics include a focus on holistic description and explanation, flexibility in the design and data collection methods, reliance on multiple sources of evidence, and emphasis on the context in which the phenomenon occurs.

Furthermore, case studies can often involve a longitudinal examination of the case, meaning they study the case over a period of time. These characteristics allow case studies to yield comprehensive, in-depth, and richly contextualized insights about the phenomenon of interest.

The role of case studies in research

Case studies hold a unique position in the broader landscape of research methods aimed at theory development. They are instrumental when the primary research interest is to gain an intensive, detailed understanding of a phenomenon in its real-life context.

In addition, case studies can serve different purposes within research - they can be used for exploratory, descriptive, or explanatory purposes, depending on the research question and objectives. This flexibility and depth make case studies a valuable tool in the toolkit of qualitative researchers.

Remember, a well-conducted case study can offer a rich, insightful contribution to both academic and practical knowledge through theory development or theory verification, thus enhancing our understanding of complex phenomena in their real-world contexts.

What is the purpose of a case study?

Case study research aims for a more comprehensive understanding of phenomena, requiring various research methods to gather information for qualitative analysis . Ultimately, a case study can allow the researcher to gain insight into a particular object of inquiry and develop a theoretical framework relevant to the research inquiry.

Why use case studies in qualitative research?

Using case studies as a research strategy depends mainly on the nature of the research question and the researcher's access to the data.

Conducting case study research provides a level of detail and contextual richness that other research methods might not offer. They are beneficial when there's a need to understand complex social phenomena within their natural contexts.

The explanatory, exploratory, and descriptive roles of case studies

Case studies can take on various roles depending on the research objectives. They can be exploratory when the research aims to discover new phenomena or define new research questions; they are descriptive when the objective is to depict a phenomenon within its context in a detailed manner; and they can be explanatory if the goal is to understand specific relationships within the studied context. Thus, the versatility of case studies allows researchers to approach their topic from different angles, offering multiple ways to uncover and interpret the data .

The impact of case studies on knowledge development

Case studies play a significant role in knowledge development across various disciplines. Analysis of cases provides an avenue for researchers to explore phenomena within their context based on the collected data.

This can result in the production of rich, practical insights that can be instrumental in both theory-building and practice. Case studies allow researchers to delve into the intricacies and complexities of real-life situations, uncovering insights that might otherwise remain hidden.

Types of case studies

In qualitative research , a case study is not a one-size-fits-all approach. Depending on the nature of the research question and the specific objectives of the study, researchers might choose to use different types of case studies. These types differ in their focus, methodology, and the level of detail they provide about the phenomenon under investigation.

Understanding these types is crucial for selecting the most appropriate approach for your research project and effectively achieving your research goals. Let's briefly look at the main types of case studies.

Exploratory case studies

Exploratory case studies are typically conducted to develop a theory or framework around an understudied phenomenon. They can also serve as a precursor to a larger-scale research project. Exploratory case studies are useful when a researcher wants to identify the key issues or questions which can spur more extensive study or be used to develop propositions for further research. These case studies are characterized by flexibility, allowing researchers to explore various aspects of a phenomenon as they emerge, which can also form the foundation for subsequent studies.

Descriptive case studies

Descriptive case studies aim to provide a complete and accurate representation of a phenomenon or event within its context. These case studies are often based on an established theoretical framework, which guides how data is collected and analyzed. The researcher is concerned with describing the phenomenon in detail, as it occurs naturally, without trying to influence or manipulate it.

Explanatory case studies

Explanatory case studies are focused on explanation - they seek to clarify how or why certain phenomena occur. Often used in complex, real-life situations, they can be particularly valuable in clarifying causal relationships among concepts and understanding the interplay between different factors within a specific context.

Intrinsic, instrumental, and collective case studies

These three categories of case studies focus on the nature and purpose of the study. An intrinsic case study is conducted when a researcher has an inherent interest in the case itself. Instrumental case studies are employed when the case is used to provide insight into a particular issue or phenomenon. A collective case study, on the other hand, involves studying multiple cases simultaneously to investigate some general phenomena.

Each type of case study serves a different purpose and has its own strengths and challenges. The selection of the type should be guided by the research question and objectives, as well as the context and constraints of the research.

The flexibility, depth, and contextual richness offered by case studies make this approach an excellent research method for various fields of study. They enable researchers to investigate real-world phenomena within their specific contexts, capturing nuances that other research methods might miss. Across numerous fields, case studies provide valuable insights into complex issues.

Critical information systems research

Case studies provide a detailed understanding of the role and impact of information systems in different contexts. They offer a platform to explore how information systems are designed, implemented, and used and how they interact with various social, economic, and political factors. Case studies in this field often focus on examining the intricate relationship between technology, organizational processes, and user behavior, helping to uncover insights that can inform better system design and implementation.

Health research

Health research is another field where case studies are highly valuable. They offer a way to explore patient experiences, healthcare delivery processes, and the impact of various interventions in a real-world context.

Case studies can provide a deep understanding of a patient's journey, giving insights into the intricacies of disease progression, treatment effects, and the psychosocial aspects of health and illness.

Asthma research studies

Specifically within medical research, studies on asthma often employ case studies to explore the individual and environmental factors that influence asthma development, management, and outcomes. A case study can provide rich, detailed data about individual patients' experiences, from the triggers and symptoms they experience to the effectiveness of various management strategies. This can be crucial for developing patient-centered asthma care approaches.

Other fields

Apart from the fields mentioned, case studies are also extensively used in business and management research, education research, and political sciences, among many others. They provide an opportunity to delve into the intricacies of real-world situations, allowing for a comprehensive understanding of various phenomena.

Case studies, with their depth and contextual focus, offer unique insights across these varied fields. They allow researchers to illuminate the complexities of real-life situations, contributing to both theory and practice.

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Understanding the key elements of case study design is crucial for conducting rigorous and impactful case study research. A well-structured design guides the researcher through the process, ensuring that the study is methodologically sound and its findings are reliable and valid. The main elements of case study design include the research question , propositions, units of analysis, and the logic linking the data to the propositions.

The research question is the foundation of any research study. A good research question guides the direction of the study and informs the selection of the case, the methods of collecting data, and the analysis techniques. A well-formulated research question in case study research is typically clear, focused, and complex enough to merit further detailed examination of the relevant case(s).

Propositions

Propositions, though not necessary in every case study, provide a direction by stating what we might expect to find in the data collected. They guide how data is collected and analyzed by helping researchers focus on specific aspects of the case. They are particularly important in explanatory case studies, which seek to understand the relationships among concepts within the studied phenomenon.

Units of analysis

The unit of analysis refers to the case, or the main entity or entities that are being analyzed in the study. In case study research, the unit of analysis can be an individual, a group, an organization, a decision, an event, or even a time period. It's crucial to clearly define the unit of analysis, as it shapes the qualitative data analysis process by allowing the researcher to analyze a particular case and synthesize analysis across multiple case studies to draw conclusions.

Argumentation

This refers to the inferential model that allows researchers to draw conclusions from the data. The researcher needs to ensure that there is a clear link between the data, the propositions (if any), and the conclusions drawn. This argumentation is what enables the researcher to make valid and credible inferences about the phenomenon under study.

Understanding and carefully considering these elements in the design phase of a case study can significantly enhance the quality of the research. It can help ensure that the study is methodologically sound and its findings contribute meaningful insights about the case.

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Conducting a case study involves several steps, from defining the research question and selecting the case to collecting and analyzing data . This section outlines these key stages, providing a practical guide on how to conduct case study research.

Defining the research question

The first step in case study research is defining a clear, focused research question. This question should guide the entire research process, from case selection to analysis. It's crucial to ensure that the research question is suitable for a case study approach. Typically, such questions are exploratory or descriptive in nature and focus on understanding a phenomenon within its real-life context.

Selecting and defining the case

The selection of the case should be based on the research question and the objectives of the study. It involves choosing a unique example or a set of examples that provide rich, in-depth data about the phenomenon under investigation. After selecting the case, it's crucial to define it clearly, setting the boundaries of the case, including the time period and the specific context.

Previous research can help guide the case study design. When considering a case study, an example of a case could be taken from previous case study research and used to define cases in a new research inquiry. Considering recently published examples can help understand how to select and define cases effectively.

Developing a detailed case study protocol

A case study protocol outlines the procedures and general rules to be followed during the case study. This includes the data collection methods to be used, the sources of data, and the procedures for analysis. Having a detailed case study protocol ensures consistency and reliability in the study.

The protocol should also consider how to work with the people involved in the research context to grant the research team access to collecting data. As mentioned in previous sections of this guide, establishing rapport is an essential component of qualitative research as it shapes the overall potential for collecting and analyzing data.

Collecting data

Gathering data in case study research often involves multiple sources of evidence, including documents, archival records, interviews, observations, and physical artifacts. This allows for a comprehensive understanding of the case. The process for gathering data should be systematic and carefully documented to ensure the reliability and validity of the study.

Analyzing and interpreting data

The next step is analyzing the data. This involves organizing the data , categorizing it into themes or patterns , and interpreting these patterns to answer the research question. The analysis might also involve comparing the findings with prior research or theoretical propositions.

Writing the case study report

The final step is writing the case study report . This should provide a detailed description of the case, the data, the analysis process, and the findings. The report should be clear, organized, and carefully written to ensure that the reader can understand the case and the conclusions drawn from it.

Each of these steps is crucial in ensuring that the case study research is rigorous, reliable, and provides valuable insights about the case.

The type, depth, and quality of data in your study can significantly influence the validity and utility of the study. In case study research, data is usually collected from multiple sources to provide a comprehensive and nuanced understanding of the case. This section will outline the various methods of collecting data used in case study research and discuss considerations for ensuring the quality of the data.

Interviews are a common method of gathering data in case study research. They can provide rich, in-depth data about the perspectives, experiences, and interpretations of the individuals involved in the case. Interviews can be structured , semi-structured , or unstructured , depending on the research question and the degree of flexibility needed.

Observations

Observations involve the researcher observing the case in its natural setting, providing first-hand information about the case and its context. Observations can provide data that might not be revealed in interviews or documents, such as non-verbal cues or contextual information.

Documents and artifacts

Documents and archival records provide a valuable source of data in case study research. They can include reports, letters, memos, meeting minutes, email correspondence, and various public and private documents related to the case.

These records can provide historical context, corroborate evidence from other sources, and offer insights into the case that might not be apparent from interviews or observations.

Physical artifacts refer to any physical evidence related to the case, such as tools, products, or physical environments. These artifacts can provide tangible insights into the case, complementing the data gathered from other sources.

Ensuring the quality of data collection

Determining the quality of data in case study research requires careful planning and execution. It's crucial to ensure that the data is reliable, accurate, and relevant to the research question. This involves selecting appropriate methods of collecting data, properly training interviewers or observers, and systematically recording and storing the data. It also includes considering ethical issues related to collecting and handling data, such as obtaining informed consent and ensuring the privacy and confidentiality of the participants.

Data analysis

Analyzing case study research involves making sense of the rich, detailed data to answer the research question. This process can be challenging due to the volume and complexity of case study data. However, a systematic and rigorous approach to analysis can ensure that the findings are credible and meaningful. This section outlines the main steps and considerations in analyzing data in case study research.

Organizing the data

The first step in the analysis is organizing the data. This involves sorting the data into manageable sections, often according to the data source or the theme. This step can also involve transcribing interviews, digitizing physical artifacts, or organizing observational data.

Categorizing and coding the data

Once the data is organized, the next step is to categorize or code the data. This involves identifying common themes, patterns, or concepts in the data and assigning codes to relevant data segments. Coding can be done manually or with the help of software tools, and in either case, qualitative analysis software can greatly facilitate the entire coding process. Coding helps to reduce the data to a set of themes or categories that can be more easily analyzed.

Identifying patterns and themes

After coding the data, the researcher looks for patterns or themes in the coded data. This involves comparing and contrasting the codes and looking for relationships or patterns among them. The identified patterns and themes should help answer the research question.

Interpreting the data

Once patterns and themes have been identified, the next step is to interpret these findings. This involves explaining what the patterns or themes mean in the context of the research question and the case. This interpretation should be grounded in the data, but it can also involve drawing on theoretical concepts or prior research.

Verification of the data

The last step in the analysis is verification. This involves checking the accuracy and consistency of the analysis process and confirming that the findings are supported by the data. This can involve re-checking the original data, checking the consistency of codes, or seeking feedback from research participants or peers.

Like any research method , case study research has its strengths and limitations. Researchers must be aware of these, as they can influence the design, conduct, and interpretation of the study.

Understanding the strengths and limitations of case study research can also guide researchers in deciding whether this approach is suitable for their research question . This section outlines some of the key strengths and limitations of case study research.

Benefits include the following:

• Rich, detailed data: One of the main strengths of case study research is that it can generate rich, detailed data about the case. This can provide a deep understanding of the case and its context, which can be valuable in exploring complex phenomena.
• Flexibility: Case study research is flexible in terms of design , data collection , and analysis . A sufficient degree of flexibility allows the researcher to adapt the study according to the case and the emerging findings.
• Real-world context: Case study research involves studying the case in its real-world context, which can provide valuable insights into the interplay between the case and its context.
• Multiple sources of evidence: Case study research often involves collecting data from multiple sources , which can enhance the robustness and validity of the findings.

On the other hand, researchers should consider the following limitations:

• Generalizability: A common criticism of case study research is that its findings might not be generalizable to other cases due to the specificity and uniqueness of each case.
• Time and resource intensive: Case study research can be time and resource intensive due to the depth of the investigation and the amount of collected data.
• Complexity of analysis: The rich, detailed data generated in case study research can make analyzing the data challenging.
• Subjectivity: Given the nature of case study research, there may be a higher degree of subjectivity in interpreting the data , so researchers need to reflect on this and transparently convey to audiences how the research was conducted.

Being aware of these strengths and limitations can help researchers design and conduct case study research effectively and interpret and report the findings appropriately.

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Guide to Writing a Computer Science Case Study

First of all, we want to warn you that there is no easy way to write a professional, high quality, impressive computer science case study . It is a time-consuming task which is not easy to deal with. Our goal is to show you some shortcuts to make your time loss less significant and to support you if you are almost ready to give up on finishing this assignment at all. You should not get too discouraged, as you are not the first and not the last student dealing with this type of case study writing. Use our practical tips, and your path to the final result will be at least a little easier.

Collecting and Structuring Information

Many students start writing their case studies literally from scratch. It means that they don’t read much before they begin writing. They are afraid they won’t have enough time to finish a computer science case study, and they don’t get enough valuable information from online and offline sources for their case. Don’t repeat this mistake, as it can make your life much harder very soon. You need to do extensive research first, even if the case study in question concerns your own experience in solving a computer science problem. However, we recommend limiting the time used for gathering and structuring information, because otherwise, you can get stuck in constant browsing on the web, not writing anything.

Set a strict deadline and stick to it.

Defining the Major Question/Problem

Case studies are always about solving some problems. You can’t write a case study about some theoretical situation, without problem statement, and without explaining a solution. It can be a potential solution, it can be a description of a bad solution that causes more problems than the initial situation. In any case, there should be a problem statement and a solution. The good case study also has a part where limitations to the offered solution are explained, because there are no perfect solutions and there are always options.

Choosing and Formatting Sources

When writing a case study in computer science you need to remember that it is a modern field of study and you are supposed to use only the most recent and valid academically approved sources. Don’t talk about some ancient computer history when writing a case about a practical problem and its solution. Pouring some water in your case study is not a good choice, because when it comes to such practical assignments, anyone can see that you didn’t dig too deep. Make sure to choose only valid and recent sources and cite them using the required citation style. What is even more important is to note down all the sources you want to use from the very beginning because later you won’t have enough time to find them online and offline again. To save even more time, use citation generators online.

Take Care About Originality

It is not easy to plagiarize when writing a practical case study because mostly you write about your own experience and it is not on the web yet. However, technical plagiarizing is still possible and it can get you into trouble. To avoid it, cite everything you write when applicable and make sure you check your final draft using an advanced and sophisticated anti-plagiarism software.

Use Professional Case Study Writing Help

If you feel truly stuck with your computer science case study writing, it is a high time to address a reliable case study writing service to help you out. It is ethical, and it is efficient. We address experts in many situations in our daily life, and it is only one more problem that can be solved with the help of paid professionals. You can be an IT genius, and it doesn’t mean that you are supposed to be a perfect academic writer or are an excellent case study composer. Computer science case study writing service will prepare a quality paper based on your requirements and your vision. They will give you some practical tips on how to approach this kind of assignment in the future and you can also use a received case as our sample paper for similar tasks you will face in years to come.

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Global Dimensions of Intellectual Property Rights in Science and Technology (1993)

Chapter: 12 a case study on computer programs, 12 a case study on computer programs.

PAMELA SAMUELSON

HISTORICAL OVERVIEW

Phase 1: the 1950s and early 1960s.

When computer programs were first being developed, proprietary rights issues were not of much concern. Software was often developed in academic or other research settings. Much progress in the programming field occurred as a result of informal exchanges of software among academics and other researchers. In the course of such exchanges, a program developed by one person might be extended or improved by a number of colleagues who would send back (or on to others) their revised versions of the software. Computer manufacturers in this period often provided software to customers of their machines to make their major product (i.e., computers) more commercially attractive (which caused the software to be characterized as "bundled" with the hardware).

To the extent that computer programs were distributed in this period by firms for whom proprietary rights in software were important, programs tended to be developed and distributed through restrictive trade secret licensing agreements. In general, these were individually negotiated with customers. The licensing tradition of the early days of the software industry has framed some of the industry expectations about proprietary rights issues, with implications for issues still being litigated today.

In the mid-1960s, as programs began to become more diverse and complex, as more firms began to invest in the development of programs, and as

some began to envision a wider market for software products, a public dialogue began to develop about what kinds of proprietary rights were or should be available for computer programs. The industry had trade secrecy and licensing protection, but some thought more legal protection might be needed.

Phase 2: Mid-1960s and 1970s

Copyright law was one existing intellectual property system into which some in the mid-1960s thought computer programs might potentially fit. Copyright had a number of potential advantages for software: it could provide a relatively long term of protection against unauthorized copying based on a minimal showing of creativity and a simple, inexpensive registration process. 1 Copyright would protect the work's ''expression," but not the "ideas" it contained. Others would be free to use the same ideas in other software, or to develop independently the same or a similar work. All that would be forbidden was the copying of expression from the first author's work.

In 1964, the U.S. Copyright Office considered whether to begin accepting registration of computer programs as copyrightable writings. It decided to do so, but only under its "rule of doubt" and then only on condition that a full text of the program be deposited with the office, which would be available for public review. 2

The Copyright Office's doubt about the copyrightability of programs

arose from a 1908 Supreme Court decision that had held that a piano roll was not an infringing "copy" of copyrighted music, but rather part of a mechanical device. 3 Mechanical devices (and processes) have traditionally been excluded from the copyright domain. 4 Although the office was aware that in machine-readable form, computer programs had a mechanical character, they also had a textual character, which was why the Copyright Office decided to accept them for registration.

The requirement that the full text of the source code of a program be deposited in order for a copyright in the program to be registered was consistent with a long-standing practice of the Copyright Office, 5 as well as with what has long been perceived to be the constitutional purpose of copyright, namely, promoting the creation and dissemination of knowledge. 6

Relatively few programs, however, were registered with the Copyright Office under this policy during the 1960s and 1970s. 7 Several factors may have contributed to this. Some firms may have been deterred by the requirement that the full text of the source code be deposited with the office and made available for public inspection, because this would have dispelled its trade secret status. Some may have thought a registration certificate issued under the rule of doubt might not be worth much. However, the main reason for the low number of copyright registrations was probably that a mass market in software still lay in the future. Copyright is useful mainly to protect mass-marketed products, and trade secrecy is quite adequate for programs with a small number of distributed copies.

Shortly after the Copyright Office issued its policy on the registrability of computer programs, the U.S. Patent Office issued a policy statement concerning its views on the patentability of computer programs. It rejected the idea that computer programs, or the intellectual processes that might be embodied in them, were patentable subject matter. 8 Only if a program was

claimed as part of a traditionally patentable industrial process (i.e., those involving the transformation of matter from one physical state to another) did the Patent Office intend to issue patents for program-related innovations. 9

Patents are typically available for inventive advances in machine designs or other technological products or processes on completion of a rigorous examination procedure conducted by a government agency, based on a detailed specification of what the claimed invention is, how it differs from the prior art, and how the invention can be made. Although patent rights are considerably shorter in duration than copyrights, patent rights are considered stronger because no one may make, use, or sell the claimed invention without the patent owner's permission during the life of the patent. (Patents give rights not just against someone who copies the protected innovation, but even against those who develop it independently.) Also, much of what copyright law would consider to be unprotectable functional content ("ideas") if described in a book can be protected by patent law.

The Patent Office's policy denying the patentability of program innovations was consistent with the recommendations of a presidential commission convened to make suggestions about how the office could more effectively cope with an "age of exploding technology." The commission also recommended that patent protection not be available for computer program innovations. 10

Although there were some appellate decisions in the late 1960s and

early 1970s overturning Patent Office rejections of computer program-related applications, few software developers looked to the patent system for protection after two U.S. Supreme Court decisions in the 1970s ruled that patent protection was not available for algorithms. 11 These decisions were generally regarded as calling into question the patentability of all software innovations, although some continued to pursue patents for their software innovations notwithstanding these decisions. 12

As the 1970s drew to a close, despite the seeming availability of copyright protection for computer programs, the software industry was still relying principally on trade secrecy and licensing agreements. Patents seemed largely, if not totally, unavailable for program innovations. Occasional suggestions were made that a new form of legal protection for computer programs should be devised, but the practice of the day was trade secrecy and licensing, and the discourse about additional protection was focused overwhelmingly on copyright.

During the 1960s and 1970s the computer science research community grew substantially in size. Although more software was being distributed under restrictive licensing agreements, much software, as well as innovative ideas about how to develop software, continued to be exchanged among researchers in this field. The results of much of this research were published and discussed openly at research conferences. Toward the end of this period, a number of important research ideas began to make their way into commercial projects, but this was not seen as an impediment to research by computer scientists because the commercial ventures tended to arise after the research had been published. Researchers during this period did not, for the most part, seek proprietary rights in their software or software ideas, although other rewards (such as tenure or recognition in the field) were available to those whose innovative research was published.

Phase 3: The 1980s

Four significant developments in the 1980s changed the landscape of the software industry and the intellectual property rights concerns of those who developed software. Two were developments in the computing field; two were legal developments.

The first significant computing development was the introduction to the market of the personal computer (PC), a machine made possible by improvements in the design of semiconductor chips, both as memory storage

devices and as processing units. A second was the visible commercial success of some early PC applications software—most notably, Visicalc, and then Lotus 1-2-3—which significantly contributed to the demand for PCs as well as making other software developers aware that fortunes could be made by selling software. With these developments, the base for a large mass market in software was finally in place.

During this period, computer manufacturers began to realize that it was to their advantage to encourage others to develop application programs that could be executed on their brand of computers. One form of encouragement involved making available to software developers whatever interface information would be necessary for development of application programs that could interact with the operating system software provided with the vendor's computers (information that might otherwise have been maintained as a trade secret). Another form of encouragement was pioneered by Apple Computer, which recognized the potential value to consumers (and ultimately to Apple) of having a relatively consistent "look and feel" to the applications programs developed to run on Apple computers. Apple developed detailed guidelines for applications developers to aid in the construction of this consistent look and feel.

The first important legal development—one which was in place when the first successful mass-marketed software applications were introduced into the market—was passage of amendments to the copyright statute in 1980 to resolve the lingering doubt about whether copyright protection was available for computer programs. 13 These amendments were adopted on the recommendation of the National Commission on New Technological Uses of Copyrighted Works (CONTU), which Congress had established to study a number of "new technology" issues affecting copyrighted works. The CONTU report emphasized the written nature of program texts, which made them seem so much like written texts that had long been protected by copyright law. The CONTU report noted the successful expansion of the boundaries of copyright over the years to take in other new technology products, such as photographs, motion pictures, and sound recordings. It predicted that computer programs could also be accommodated in the copyright regime. 14

Copyright law was perceived by CONTU as the best alternative for protection of computer programs under existing intellectual property regimes. Trade secrecy, CONTU noted, was inherently unsuited for mass-marketed products because the first sale of the product on the open market would dispel the secret. CONTU observed that Supreme Court rulings had cast

doubts on the availability of patent protection for software. CONTU's confidence in copyright protection for computer programs was also partly based on an economic study it had commissioned. This economic study regarded copyright as suitable for protecting software against unauthorized copying after sale of the first copy of it in the marketplace, while fostering the development of independently created programs. The CONTU majority expressed confidence that judges would be able to draw lines between protected expression and unprotected ideas embodied in computer programs, just as they did routinely with other kinds of copyrighted works.

A strong dissenting view was expressed by the novelist John Hersey, one of the members of the CONTU commission, who regarded programs as too mechanical to be protected by copyright law. Hersey warned that the software industry had no intention to cease the use of trade secrecy for software. Dual assertion of trade secrecy and copyright seemed to him incompatible with copyright's historical function of promoting the dissemination of knowledge.

Another development during this period was that the Copyright Office dropped its earlier requirement that the full text of source code be deposited with it. Now only the first and last 25 pages of source code had to be deposited to register a program. The office also decided it had no objection if the copyright owner blacked out some portions of the deposited source code so as not to reveal trade secrets. This new policy was said to be consistent with the new copyright statute that protected both published and unpublished works alike, in contrast to the prior statutes that had protected mainly published works. 15

With the enactment of the software copyright amendments, software developers had a legal remedy in the event that someone began to mass-market exact or near-exact copies of the developers' programs in competition with the owner of the copyright in the program. Unsurprisingly, the first software copyright cases involved exact copying of the whole or substantial portions of program code, and in them, the courts found copyright infringement. Copyright litigation in the mid- and late 1980s began to grapple with questions about what, besides program code, copyright protects about computer programs. Because the "second-generation" litigation affects the current legal framework for the protection of computer programs, the issues raised by these cases will be dealt with in the next section.

As CONTU Commissioner Hersey anticipated, software developers did not give up their claims to the valuable trade secrets embodied in their programs after enactment of the 1980 amendments to the copyright statute.

To protect those secrets, developers began distributing their products in machine-readable form, often relying on "shrink-wrap" licensing agreements to limit consumer rights in the software. 16 Serious questions exist about the enforceability of shrink-wrap licenses, some because of their dubious contractual character 17 and some because of provisions that aim to deprive consumers of rights conferred by the copyright statute. 18 That has not led, however, to their disuse.

One common trade secret-related provision of shrink-wrap licenses, as well as of many negotiated licenses, is a prohibition against decompilation or disassembly of the program code. Such provisions are relied on as the basis of software developer assertions that notwithstanding the mass distribution of a program, the program should be treated as unpublished copyrighted works as to which virtually no fair use defenses can be raised. 19

Those who seek to prevent decompilation of programs tend to assert that since decompilation involves making an unauthorized copy of the program, it constitutes an improper means of obtaining trade secrets in the program. Under this theory, decompilation of program code results in three unlawful acts: copyright infringement (because of the unauthorized copy made during the decompilation process), trade secret misappropriation (because the secret has been obtained by improper means, i.e., by copyright

infringement), and a breach of the licensing agreement (which prohibits decompilation).

Under this theory, copyright law would become the legal instrument by which trade secrecy could be maintained in a mass-marketed product, rather than a law that promotes the dissemination of knowledge. Others regard decompilation as a fair use of a mass-marketed program and, shrink-wrap restrictions to the contrary, as unenforceable. This issue has been litigated in the United States, but has not yet been resolved definitively. 20 The issue remains controversial both within the United States and abroad.

A second important legal development in the early 1980s—although one that took some time to become apparent—was a substantial shift in the U.S. Patent and Trademark Office (PTO) policy concerning the patentability of computer program-related inventions. This change occurred after the 1981 decision by the U.S. Supreme Court in Diamond v. Diehr, which ruled that a rubber curing process, one element of which was a computer program, was a patentable process. On its face, the Diehr decision seemed consistent with the 1966 Patent Office policy and seemed, therefore, not likely to lead to a significant change in patent policy regarding software innovations. 21 By the mid-1980s, however, the PTO had come to construe the Court's ruling broadly and started issuing a wide variety of computer program-related patents. Only "mathematical algorithms in the abstract" were now thought unpatentable. Word of the PTO's new receptivity to software patent applications spread within the patent bar and gradually to software developers.

During the early and mid-1980s, both the computer science field and the software industry grew very significantly. Innovative ideas in computer science and related research fields were widely published and disseminated. Software was still exchanged by researchers, but a new sensitivity to intellectual property rights began to arise, with general recognition that unauthorized copying of software might infringe copyrights, especially if done with a commercial purpose. This was not perceived as presenting a serious obstacle to research, for it was generally understood that a reimplementation of the program (writing one's own code) would be

noninfringing. 22 Also, much of the software (and ideas about software) exchanged by researchers during the early and mid-1980s occurred outside the commercial marketplace. Increasingly, the exchanges took place with the aid of government-subsidized networks of computers.

Software firms often benefited from the plentiful availability of research about software, as well as from the availability of highly trained researchers who could be recruited as employees. Software developers began investing more heavily in research and development work. Some of the results of this research was published and/or exchanged at technical conferences, but much was kept as a trade secret and incorporated in new products.

By the late 1980s, concerns began arising in the computer science and related fields, as well as in the software industry and the legal community, about the degree of intellectual property protection needed to promote a continuation of the high level of innovation in the software industry. 23 Although most software development firms, researchers, and manufacturers of computers designed to be compatible with the leading firms' machines seemed to think that copyright (complemented by trade secrecy) was adequate to their needs, the changing self-perception of several major computer manufacturers led them to push for more and "stronger" protection. (This concern has been shared by some successful software firms whose most popular programs were being "cloned" by competitors.) Having come to realize that software was where the principal money of the future would be made, these computer firms began reconceiving themselves as software developers. As they did so, their perspective on software protection issues changed as well. If they were going to invest in software development, they wanted "strong'' protection for it. They have, as a consequence, become among the most vocal advocates of strong copyright, as well as of patent protection for computer programs. 24

CURRENT LEGAL APPROACHES IN THE UNITED STATES

Software developers in the United States are currently protecting software products through one or more of the following legal protection mechanisms: copyright, trade secret, and/or patent law. Licensing agreements often supplement these forms of protection. Some software licensing agreements are negotiated with individual customers; others are printed forms found under the plastic shrink-wrap of a mass-marketed package. 25 Few developers rely on only one form of legal protection. Developers seem to differ somewhat on the mix of legal protection mechanisms they employ as well as on the degree of protection they expect from each legal device.

Although the availability of intellectual property protection has unquestionably contributed to the growth and prosperity of the U.S. software industry, some in the industry and in the research community are concerned that innovation and competition in this industry will be impeded rather than enhanced if existing intellectual property rights are construed very broadly. 26 Others, however, worry that courts may not construe intellectual property rights broadly enough to protect what is most valuable about software, and if too little protection is available, there may be insufficient incentives to invest in software development; hence innovation and competition may be retarded through underprotection. 27 Still others (mainly lawyers) are confident that the software industry will continue to prosper and grow under the existing intellectual property regimes as the courts "fill out" the details of software protection on a case-by-case basis as they have been doing for the past several years. 28

What's Not Controversial

Although the main purpose of the discussion of current approaches is to give an overview of the principal intellectual property issues about which there is controversy in the technical and legal communities, it may be wise to begin with a recognition of a number of intellectual property issues as to which there is today no significant controversy. Describing only the aspects of the legal environment as to which controversies exist would risk creating a misimpression about the satisfaction many software developers and lawyers have with some aspects of intellectual property rights they now use to protect their and their clients' products.

One uncontroversial aspect of the current legal environment is the use of copyright to protect against exact or near-exact copying of program code. Another is the use of copyright to protect certain aspects of user interfaces, such as videogame graphics, that are easily identifiable as "expressive" in a traditional copyright sense. Also relatively uncontroversial is the use of copyright protection for low-level structural details of programs, such as the instruction-by-instruction sequence of the code. 29

The use of trade secret protection for the source code of programs and other internally held documents concerning program design and the like is similarly uncontroversial. So too is the use of licensing agreements negotiated with individual customers under which trade secret software is made available to licensees when the number of licensees is relatively small and when there is a reasonable prospect of ensuring that licensees will take adequate measures to protect the secrecy of the software. Patent protection for industrial processes that have computer program elements, such as the rubber curing process in the Diehr case, is also uncontroversial.

Substantial controversies exist, however, about the application of copyright law to protect other aspects of software, about patent protection for other kinds of software innovations, about the enforceability of shrink-wrap licensing agreements, and about the manner in which the various forms of legal protection seemingly available to software developers interrelate in the protection of program elements (e.g., the extent to which copyright and trade secret protection can coexist in mass-marketed software).

Controversies Arising From Whelan v. Jaslow

Because quite a number of the most contentious copyright issues arise from the Whelan v. Jaslow decision, this subsection focuses on that case. In the summer of 1986, the Third Circuit Court of Appeals affirmed a trial court decision in favor of Whelan Associates in its software copyright lawsuit against Jaslow Dental Laboratories. 30 Jaslow's program for managing dental lab business functions used some of the same data and file structures as Whelan's program (to which Jaslow had access), and five subroutines of Jaslow's program functioned very similarly to Whelan's. The trial court inferred that there were substantial similarities in the underlying structure of the two programs based largely on a comparison of similarities in the user interfaces of the two programs, even though user interface similarities were not the basis for the infringement claim. Jaslow's principal defense was that Whelan's copyright protected only against exact copying of program code, and since there were no literal similarities between the programs, no copyright infringement had occurred.

In its opinion on this appeal, the Third Circuit stated that copyright protection was available for the "structure, sequence, and organization" (sso) of a program, not just the program code. (The court did not distinguish between high- and low-level structural features of a program.) The court analogized copyright protection for program sso to the copyright protection available for such things as detailed plot sequences in novels. The court also emphasized that the coding of a program was a minor part of the cost of development of a program. The court expressed fear that if copyright protection was not accorded to sso, there would be insufficient incentives to invest in the development of software.

The Third Circuit's Whelan decision also quoted with approval from that part of the trial court opinion stating that similarities in the manner in which programs functioned could serve as a basis for a finding of copyright infringement. Although recognizing that user interface similarities did not necessarily mean that two programs had similar underlying structures (thereby correcting an error the trial judge had made), the appellate court thought that user interface similarities might still be some evidence of underlying structural similarities. In conjunction with other evidence in the case, the Third Circuit decided that infringement had properly been found.

Although a number of controversies have arisen out of the Whelan opinion, the aspect of the opinion that has received the greatest attention is the test the court used for determining copyright infringement in computer

program cases. The " Whelan test" regards the general purpose or function of a program as its unprotectable "idea." All else about the program is, under the Whelan test, protectable "expression'' unless there is only one or a very small number of ways to achieve the function (in which case idea and expression are said to be "merged," and what would otherwise be expression is treated as an idea). The sole defense this test contemplates for one who has copied anything more detailed than the general function of another program is that copying that detail was "necessary" to perform that program function. If there is in the marketplace another program that does the function differently, courts applying the Whelan test have generally been persuaded that the copying was unjustified and that what was taken must have been "expressive."

Although the Whelan test has been used in a number of subsequent cases, including the well-publicized Lotus v. Paperback case, 31 some judges have rejected it as inconsistent with copyright law and tradition, or have found ways to distinguish the Whelan case when employing its test would have resulted in a finding of infringement. 32

Many commentators assert that the Whelan test interprets copyright

protection too expansively. 33 Although the court in Whelan did not seem to realize it, the Whelan test would give much broader copyright protection to computer programs than has traditionally been given to novels and plays, which are among the artistic and fanciful works generally accorded a broader scope of protection than functional kinds of writings (of which programs would seem to be an example). 34 The Whelan test would forbid reuse of many things people in the field tend to regard as ideas. 35 Some commentators have suggested that because innovation in software tends to be of a more incremental character than in some other fields, and especially given the long duration of copyright protection, the Whelan interpretation of the scope of copyright is likely to substantially overprotect software. 36

One lawyer-economist, Professor Peter Menell, has observed that the model of innovation used by the economists who did the study of software for CONTU is now considered to be an outmoded approach. 37 Those econo-

mists focused on a model that considered what incentives would be needed for development of individual programs in isolation. Today, economists would consider what protection would be needed to foster innovation of a more cumulative and incremental kind, such as has largely typified the software field. In addition, the economists on whose work CONTU relied did not anticipate the networking potential of software and consequently did not study what provisions the law should make in response to this phenomenon. Menell has suggested that with the aid of their now more refined model of innovation, economists today might make somewhat different recommendations on software protection than they did in the late 1970s for CONTU. 38

As a matter of copyright law, the principal problem with the Whelan test is its incompatibility with the copyright statute, the case law properly interpreting it, and traditional principles of copyright law. The copyright statute provides that not only ideas, but also processes, procedures, systems, and methods of operation, are unprotectable elements of copyrighted works. 39 This provision codifies some long-standing principles derived from U.S. copyright case law, such as the Supreme Court's century-old Baker v. Selden decision that ruled that a second author did not infringe a first author's copyright when he put into his own book substantially similar ledger sheets to those in the first author's book. The reason the Court gave for its ruling was that Selden's copyright did not give him exclusive rights to the bookkeeping system, but only to his explanation or description of it. 40 The ordering and arrangement of columns and headings on the ledger sheets were part of the system; to get exclusive rights in this, the Court said that Selden would have to get a patent.

The statutory exclusion from copyright protection for methods, processes, and the like was added to the copyright statute in part to ensure that the scope of copyright in computer programs would not be construed too broadly. Yet, in cases in which the Whelan test has been employed, the courts have tended to find the presence of protectable "expression" when they perceive there to be more than a couple of ways to perform some function, seeming not to realize that there may be more than one "method" or "system" or "process" for doing something, none of which is properly protected by copyright law. The Whelan test does not attempt to exclude

methods or processes from the scope of copyright protection, and its recognition of functionality as a limitation on the scope of copyright is triggered only when there are no alternative ways to perform program functions.

Whelan has been invoked by plaintiffs not only in cases involving similarities in the internal structural design features of programs, but also in many other kinds of cases. sso can be construed to include internal interface specifications of a program, the layout of elements in a user interface, and the sequence of screen displays when program functions are executed, among other things. Even the manner in which a program functions can be said to be protectable by copyright law under Whelan . The case law on these issues and other software issues is in conflict, and resolution of these controversies cannot be expected very soon.

Traditionalist Versus Strong Protectionist View of What Copyright Law Does and Does Not Protect in Computer Programs

Traditional principles of copyright law, when applied to computer programs, would tend to yield only a "thin" scope of protection for them. Unquestionably, copyright protection would exist for the code of the program and the kinds of expressive displays generated when program instructions are executed, such as explanatory text and fanciful graphics, which are readily perceptible as traditional subject matters of copyright law. A traditionalist would regard copyright protection as not extending to functional elements of a program, whether at a high or low level of abstraction, or to the functional behavior that programs exhibit. Nor would copyright protection be available for the applied know-how embodied in programs, including program logic. 41 Copyright protection would also not be available for algorithms or other structural abstractions in software that are constituent elements of a process, method, or system embodied in a program.

Efficient ways of implementing a function would also not be protectable by copyright law under the traditionalist view, nor would aspects of software design that make the software easier to use (because this bears on program functionality). The traditionalist would also not regard making a limited number of copies of a program to study it and extract interface information or other ideas from the program as infringing conduct, because computer programs are a kind of work for which it is necessary to make a copy to "read" the text of the work. 42 Developing a program that incorporates interface information derived from decompilation would also, in the traditionalist view, be noninfringing conduct.

If decompilation and the use of interface information derived from the study of decompiled code were to be infringing acts, the traditionalist would regard copyright as having been turned inside out, for instead of promoting the dissemination of knowledge as has been its traditional purpose, copyright law would become the principal means by which trade secrets would be maintained in widely distributed copyrighted works. Instead of protecting only expressive elements of programs, copyright would become like a patent: a means by which to get exclusive rights to the configuration of a machine—without meeting stringent patent standards or following the strict procedures required to obtain patent protection. This too would seem to turn copyright inside out.

Because interfaces, algorithms, logic, and functionalities of programs are aspects of programs that make them valuable, it is understandable that some of those who seek to maximize their financial returns on software investments have argued that "strong" copyright protection is or should be available for all valuable features of programs, either as part of program sso or under the Whelan "there's-another-way-to-do-it" test. 43 Congress seems to have intended for copyright law to be interpreted as to programs on a case-by-case basis, and if courts determine that valuable features should be considered "expressive," the strong protectionists would applaud this common law evolution. If traditional concepts of copyright law and its purposes do not provide an adequate degree of protection for software innovation, they see it as natural that copyright should grow to provide it. Strong protectionists tend to regard traditionalists as sentimental Luddites who do not appreciate that what matters is for software to get the degree of protection it needs from the law so that the industry will thrive.

Although some cases, most notably the Whelan and Lotus decisions, have adopted the strong protectionist view, traditionalists will tend to regard these decisions as flawed and unlikely to be affirmed in the long run because they are inconsistent with the expressed legislative intent to have traditional principles of copyright law applied to software. Some copyright traditionalists favor patent protection for software innovations on the ground that the valuable functional elements of programs do need protection to create proper incentives for investing in software innovations, but that this protection should come from patent law, not from copyright law.

Controversy Over "Software Patents"

Although some perceive patents as a way to protect valuable aspects of programs that cannot be protected by copyright law, those who argue for patents for software innovations do not rely on the "gap-filling" concern alone. As a legal matter, proponents of software patents point out that the patent statute makes new, nonobvious, and useful "processes" patentable. Programs themselves are processes; they also embody processes. 44 Computer hardware is clearly patentable, and it is a commonplace in the computing field that any tasks for which a program can be written can also be implemented in hardware. This too would seem to support the patentability of software.

Proponents also argue that protecting program innovations by patent law is consistent with the constitutional purpose of patent law, which is to promote progress in the "useful arts." Computer program innovations are technological in nature, which is said to make them part of the useful arts to which the Constitution refers. Proponents insist that patent law has the same potential for promoting progress in the software field as it has had for promoting progress in other technological fields. They regard attacks on patents for software innovations as reflective of the passing of the frontier in the software industry, a painful transition period for some, but one necessary if the industry is to have sufficient incentives to invest in software development.

Some within the software industry and the technical community, however, oppose patents for software innovations. 45 Opponents tend to make two kinds of arguments against software patents, often without distinguishing between them. One set of arguments questions the ability of the PTO to deal well with software patent applications. Another set raises more fundamental questions about software patents. Even assuming that the PTO could begin to do a good job at issuing software patents, some question whether

innovation in the software field will be properly promoted if patents become widely available for software innovations. The main points of both sets of arguments are developed below.

Much of the discussion in the technical community has focused on "bad" software patents that have been issued by the PTO. Some patents are considered bad because the innovation was, unbeknownst to the PTO, already in the state of the art prior to the date of invention claimed in the patent. Others are considered bad because critics assert that the innovations they embody are too obvious to be deserving of patent protection. Still others are said to be bad because they are tantamount to a claim for performing a particular function by computer or to a claim for a law of nature, neither of which is regarded as patentable subject matter. Complaints abound that the PTO, after decades of not keeping up with developments in this field, is so far out of touch with what has been and is happening in the field as to be unable to make appropriate judgments on novelty and nonobviousness issues. Other complaints relate to the office's inadequate classification scheme for software and lack of examiners with suitable education and experience in computer science and related fields to make appropriate judgments on software patent issues. 46

A somewhat different point is made by those who assert that the software industry has grown to its current size and prosperity without the aid of patents, which causes them to question the need for patents to promote innovation in this industry. 47 The highly exclusionary nature of patents (any use of the innovation without the patentee's permission is infringing) contrasts sharply with the tradition of independent reinvention in this field. The high expense associated with obtaining and enforcing patents raises concerns about the increased barriers to entry that may be created by the patenting of software innovations. Since much of the innovation in this industry has come from small firms, policies that inhibit entry by small firms may not promote innovation in this field in the long run. Similar questions arise as to whether patents will promote a proper degree of innovation in an incremental industry such as the software industry. It would be possible to undertake an economic study of conditions that have promoted and are promoting progress in the software industry to serve as a basis for a policy decision on software patents, but this has not been done to date.

Some computer scientists and mathematicians are also concerned about patents that have been issuing for algorithms, 48 which they regard as dis-

coveries of fundamental truths that should not be owned by anyone. Because any use of a patented algorithm within the scope of the claims—whether by an academic or a commercial programmer, whether one knew of the patent or not—may be an infringement, some worry that research on algorithms will be slowed down by the issuance of algorithm patents. One mathematical society has recently issued a report opposing the patenting of algorithms. 49 Others, including Richard Stallman, have formed a League for Programming Freedom.

There is substantial case law to support the software patent opponent position, notwithstanding the PTO change in policy. 50 Three U.S. Supreme Court decisions have stated that computer program algorithms are unpatentable subject matter. Other case law affirms the unpatentability of processes that involve the manipulation of information rather than the transformation of matter from one physical state to another.

One other concern worth mentioning if both patents and copyrights are used to protect computer program innovations is whether a meaningful boundary line can be drawn between the patent and copyright domains as regards software. 51 A joint report of the U.S. PTO and the Copyright Office optimistically concludes that no significant problems will arise from the coexistence of these two forms of protection for software because copyright law will only protect program "expression" whereas patent law will only protect program "processes." 52

Notwithstanding this report, I continue to be concerned with the patent/ copyright interface because of the expansive interpretations some cases, particularly Whelan, have given to the scope of copyright protection for programs. This prefigures a significant overlap of copyright and patent law as to software innovations. This overlap would undermine important economic and public policy goals of the patent system, which generally leaves in the public domain those innovations not novel or nonobvious enough to be patented. Mere "originality" in a copyright sense is not enough to make an innovation in the useful arts protectable under U.S. law. 53

A concrete example may help illustrate this concern. Some patent lawyers report getting patents on data structures for computer programs.

The Whelan decision relied in part on similarities in data structures to prove copyright infringement. Are data structures "expressive" or "useful"? When one wants to protect a data structure of a program by copyright, does one merely call it part of the sso of the program, whereas if one wants to patent it, one calls it a method (i.e., a process) of organizing data for accomplishing certain results? What if anything does copyright's exclusion from protection of processes embodied in copyrighted works mean as applied to data structures? No clear answer to these questions emerges from the case law.

Nature of Computer Programs and Exploration of a Modified Copyright Approach

It may be that the deeper problem is that computer programs, by their very nature, challenge or contradict some fundamental assumptions of the existing intellectual property regimes. Underlying the existing regimes of copyright and patent law are some deeply embedded assumptions about the very different nature of two kinds of innovations that are thought to need very different kinds of protection owing to some important differences in the economic consequences of their protection. 54

In the United States, these assumptions derive largely from the U.S. Constitution, which specifically empowers Congress "to promote the progress of science [i.e., knowledge] and useful arts [i.e., technology], by securing for limited times to authors and inventors the exclusive right to their respective writings and discoveries." 55 This clause has historically been parsed as two separate clauses packaged together for convenience: one giving Congress power to enact laws aimed at promoting the progress of knowledge by giving authors exclusive rights in their writings, and the other giving Congress power to promote technological progress by giving inventors exclusive rights in their technological discoveries. Copyright law implements the first power, and patent law the second.

Owing partly to the distinctions between writings and machines, which the constitutional clause itself set up, copyright law has excluded machines

and other technological subject matters from its domain. 56 Even when described in a copyrighted book, an innovation in the useful arts was considered beyond the scope of copyright protection. The Supreme Court's Baker v. Selden decision reflects this view of the constitutional allocation. Similarly, patent law has historically excluded printed matter (i.e., the contents of writings) from its domain, notwithstanding the fact that printed matter may be a product of a manufacturing process. 57 Also excluded from the patent domain have been methods of organizing, displaying, and manipulating information (i.e., processes that might be embodied in writings, for example mathematical formulas), notwithstanding the fact that "processes" are named in the statute as patentable subject matter. They were not, however, perceived to be "in the useful arts" within the meaning of the constitutional clause.

The constitutional clause has been understood as both a grant of power and a limitation on power. Congress cannot, for example, grant perpetual patent rights to inventors, for that would violate the "limited times" provision of the Constitution. Courts have also sometimes ruled that Congress cannot, under this clause, grant exclusive rights to anyone but authors and inventors. In the late nineteenth century, the Supreme Court struck down the first federal trademark statute on the ground that Congress did not have power to grant rights under this clause to owners of trademarks who were neither "authors" nor "inventors." 58 A similar view was expressed in last year's Feist Publications v. Rural Telephone Services decision by the Supreme Court, which repeatedly stated that Congress could not constitutionally protect the white pages of telephone books through copyright law because to be an "author" within the meaning of the Constitution required some creativity in expression that white pages lacked. 59

Still other Supreme Court decisions have suggested that Congress could not constitutionally grant exclusive rights to innovators in the useful arts who were not true "inventors." 60 Certain economic assumptions are connected with this view, including the assumption that more modest innovations in the useful arts (the work of a mere mechanic) will be forthcoming without the grant of the exclusive rights of a patent, but that the incentives of patent rights are necessary to make people invest in making significant technological advances and share the results of their work with the public instead of keeping them secret.

One reason the United States does not have a copyright-like form of protection for industrial designs, as do many other countries, is because of lingering questions about the constitutionality of such legislation. In addition, concerns exist that the economic consequences of protecting uninventive technological advances will be harmful. So powerful are the prevailing patent and copyright paradigms that when Congress was in the process of considering the adoption of a copyright-like form of intellectual property protection for semiconductor chip designs, there was considerable debate about whether Congress had constitutional power to enact such a law. It finally decided it did have such power under the commerce clause, but even then was not certain.

As this discussion reveals, the U.S. intellectual property law has long assumed that something is either a writing (in which case it is protectable, if at all, by copyright law) or a machine (in which case it is protectable, if at all, by patent law), but cannot be both at the same time. However, as Professor Randall Davis has so concisely said, software is "a machine whose medium of construction happens to be text." 61 Davis regards the act of creating computer programs as inevitably one of both authorship and invention. There may be little or nothing about a computer program that is not, at base, functional in nature, and nothing about it that does not have roots in the text. Because of this, it will inevitably be difficult to draw meaningful boundaries for patents and copyrights as applied to computer programs.

Another aspect of computer programs that challenges the assumptions of existing intellectual property systems is reflected in another of Professor Davis's observations, namely, that "programs are not only texts; they also behave." 62 Much of the dynamic behavior of computer programs is highly functional in nature. If one followed traditional copyright principles, this functional behavior—no matter how valuable it might be—would be considered outside the scope of copyright law. 63 Although the functionality of program behavior might seem at first glance to mean that patent protection would be the obvious form of legal protection for it, as a practical matter, drafting patent claims that would adequately capture program behavior as an invention is infeasible. There are at least two reasons for this: it is partly because programs are able to exhibit such a large number and variety of states that claims could not reasonably cover them, and partly because of

the ''gestalt"-like character of program behavior, something that makes a more copyright-like approach desirable.

Some legal scholars have argued that because of their hybrid character as both writings and machines, computer programs need a somewhat different legal treatment than either traditional patent or copyright law would provide. 64 They have warned of distortions in the existing legal systems likely to occur if one attempts to integrate such a hybrid into the traditional systems as if it were no different from the traditional subject matters of these systems. 65 Even if the copyright and patent laws could be made to perform their tasks with greater predictability than is currently the case, these authors warn that such regimes may not provide the kind of protection that software innovators really need, for most computer programs will be legally obvious for patent purposes, and programs are, over time, likely to be assimilated within copyright in a manner similar to that given to "factual" and "functional" literary works that have only "thin" protection against piracy. 66

Professor Reichman has reported on the recurrent oscillations between states of under- and overprotection when legal systems have tried to cope with another kind of legal hybrid, namely, industrial designs (sometimes referred to as "industrial art"). Much the same pattern seems to be emerging in regard to computer programs, which are, in effect, "industrial literature." 67

The larger problems these hybrids present is that of protecting valuable forms of applied know-how embodied in incremental innovation that cannot successfully be maintained as trade secrets:

[M]uch of today's most advanced technology enjoys a less favorable competitive position than that of conventional machinery because the unpatentable, intangible know-how responsible for its commercial value becomes embodied in products that are distributed on the open market. A product of the new technologies, such as a computer program, an integrated circuit

design, or even a biogenetically altered organism may thus bear its know-how on its face, a condition that renders it as vulnerable to rapid appropriation by second-comers as any published literary or artistic work.

From this perspective, a major problem with the kinds of innovative know-how underlying important new technologies is that they do not lend themselves to secrecy even when they represent the fruit of enormous investment in research and development. Because third parties can rapidly duplicate the embodied information and offer virtually the same products at lower prices than those of the originators, there is no secure interval of lead time in which to recuperate the originators' initial investment or their losses from unsuccessful essays, not to mention the goal of turning a profit. 68

From a behavioral standpoint, investors in applied scientific know-how find the copyright paradigm attractive because of its inherent disposition to supply artificial lead time to all comers without regard to innovative merit and without requiring originators to preselect the products that are most worthy of protection. 69

Full copyright protection, however, with its broad notion of equivalents geared to derivative expressions of an author's personality is likely to disrupt the workings of the competitive market for industrial products. For this and other reasons, Professor Reichman argues that a modified copyright approach to the protection of computer programs (and other legal hybrids) would be a preferable framework for protecting the applied know-how they embody than either the patent or the copyright regime would presently provide. Similar arguments can be made for a modified form of copyright protection for the dynamic behavior of programs. A modified copyright approach might involve a short duration of protection for original valuable functional components of programs. It could be framed to supplement full copyright protection for program code and traditionally expressive elements of text and graphics displayed when programs execute, features of software that do not present the same dangers of competitive disruption from full copyright protection.

The United States is, in large measure, already undergoing the development of a sui generis law for protection of computer software through case-by-case decisions in copyright lawsuits. Devising a modified copyright approach to protecting certain valuable components that are not suitably protected under the current copyright regime would have the advantage of allowing a conception of the software protection problem as a whole, rather than on a piecemeal basis as occurs in case-by-case litigation in which the

skills of certain attorneys and certain facts may end up causing the law to develop in a skewed manner. 70

There are, however, a number of reasons said to weigh against sui generis legislation for software, among them the international consensus that has developed on the use of copyright law to protect software and the trend toward broader use of patents for software innovations. Some also question whether Congress would be able to devise a more appropriate sui generis system for protecting software than that currently provided by copyright. Some are also opposed to sui generis legislation for new technology products such as semiconductor chips and software on the ground that new intellectual property regimes will make intellectual property law more complicated, confusing, and uncertain.

Although there are many today who ardently oppose sui generis legislation for computer programs, these same people may well become among the most ardent proponents of such legislation if the U.S. Supreme Court, for example, construes the scope of copyright protection for programs to be quite thin, and reiterates its rulings in Benson, Flook, and Diehr that patent protection is unavailable for algorithms and other information processes embodied in software.

INTERNATIONAL PERSPECTIVES

After adopting copyright as a form of legal protection for computer programs, the United States campaigned vigorously around the world to persuade other nations to protect computer programs by copyright law as well. These efforts have been largely successful. Although copyright is now an international norm for the protection of computer software, the fine details of what copyright protection for software means, apart from protection against exact copying of program code, remain somewhat unclear in other nations, just as in the United States.

Other industrialized nations have also tended to follow the U.S. lead concerning the protection of computer program-related inventions by patent

law. 71 Some countries that in the early 1960s were receptive to the patenting of software innovations became less receptive after the Gottschalk v. Benson decision by the U.S. Supreme Court. Some even adopted legislation excluding computer programs from patent protection. More recently, these countries are beginning to issue more program-related patents, once again paralleling U.S. experience, although as in the United States, the standards for patentability of program-related inventions are somewhat unclear. 72 If the United States and Japan continue to issue a large number of computer program-related patents, it seems quite likely other nations will follow suit.

There has been strong pressure in recent years to include relatively specific provisions about intellectual property issues (including those affecting computer programs) as part of the international trade issues within the framework of the General Agreement on Tariffs and Trade (GATT). 73 For a time, the United States was a strong supporter of this approach to resolution of disharmonies among nations on intellectual property issues affecting software. The impetus for this seems to have slackened, however, after U.S. negotiators became aware of a lesser degree of consensus among U.S. software developers on certain key issues than they had thought was the case. Since the adoption of its directive on software copyright law, the European Community (EC) has begun pressing for international adoption of its position on a number of important software issues, including its copyright rule on decompilation of program code.

There is a clear need, given the international nature of the market for software, for a substantial international consensus on software protection issues. However, because there are so many hotly contested issues concerning the extent of copyright and the availability of patent protection for computer programs yet to be resolved, it may be premature to include very specific rules on these subjects in the GATT framework.

Prior to the adoption of the 1991 European Directive on the Protection of Computer Programs, there was general acceptance in Europe of copyright as a form of legal protection for computer programs. A number of nations had interpreted existing copyright statutes as covering programs. Others took legislative action to extend copyright protection to software. There was, however, some divergence in approach among the member nations of the EC in the interpretation of copyright law to computer software. 74

France, for example, although protecting programs under its copyright law, put software in the same category as industrial art, a category of work that is generally protected in Europe for 25 years instead of the life plus 50-year term that is the norm for literary and other artistic works. German courts concluded that to satisfy the "originality" standard of its copyright law, the author of a program needed to demonstrate that the program was the result of more than an average programmer's skill, a seemingly patentlike standard. In 'addition, Switzerland (a non-EC member but European nonetheless) nearly adopted an approach that treated both semiconductor chip designs and computer programs under a new copyright-like law.

Because of these differences and because it was apparent that computer programs would become an increasingly important item of commerce in the European Community, the EC undertook in the late 1980s to develop a policy concerning intellectual property protection for computer programs to which member nations should harmonize their laws. There was some support within the EC for creating a new law for the protection of software, but the directorate favoring a copyright approach won this internal struggle over what form of protection was appropriate for software.

In December 1988 the EC issued a draft directive on copyright protection for computer programs. This directive was intended to spell out in considerable detail in what respects member states should have uniform rules on copyright protection for programs. (The European civil law tradition generally prefers specificity in statutory formulations, in contrast with the U.S. common law tradition, which often prefers case-by-case adjudication of disputes as a way to fill in the details of a legal protection scheme.)

The draft directive on computer programs was the subject of intense debate within the European Community, as well as the object of some intense lobbying by major U.S. firms who were concerned about a number of issues, but particularly about what rule would be adopted concerning decompilation of program code and protection of the internal interfaces of

programs. Some U.S. firms, among them IBM Corp., strongly opposed any provision that would allow decompilation of program code and sought to have interfaces protected; other U.S. firms, such as Sun Microsystems, sought a rule that would permit decompilation and would deny protection to internal interfaces. 75

The final EC directive published in 1991 endorses the view that computer programs should be protected under member states' copyright laws as literary works and given at least 50 years of protection against unauthorized copying. 76 It permits decompilation of program code only if and to the extent necessary to obtain information to create an interoperable program. The inclusion in another program of information necessary to achieve interoperability seems, under the final directive, to be lawful.

The final EC directive states that "ideas" and "principles" embodied in programs are not protectable by copyright, but does not provide examples of what these terms might mean. The directive contains no exclusion from protection of such things as processes, procedures, methods of operation, and systems, as the U.S. statute provides. Nor does it clearly exclude protection of algorithms, interfaces, and program logic, as an earlier draft would have done. Rather, the final directive indicates that to the extent algorithms, logic, and interfaces are ideas, they are unprotectable by copyright law. In this regard, the directive seems, quite uncharacteristically for its civil law tradition, to leave much detail about how copyright law will be applied to programs to be resolved by litigation.

Having just finished the process of debating the EC directive about copyright protection of computer programs, intellectual property specialists in the EC have no interest in debating the merits of any sui generis approach to software protection, even though the only issue the EC directive really resolved may have been that of interoperability. Member states will likely have to address another controversial issue—whether or to what extent user interests in standardization of user interfaces should limit the scope of copyright

protection for programs—as they act on yet another EC directive, one that aims to standardize user interfaces of computer programs. Some U.S. firms may perceive this latter directive as an effort to appropriate valuable U.S. product features.

Japan was the first major industrialized nation to consider adoption of a sui generis approach to the protection of computer programs. 77 Its Ministry of International Trade and Industry (MITI) published a proposal that would have given 15 years of protection against unauthorized copying to computer programs that could meet a copyright-like originality standard under a copyright-like registration regime. MITI attempted to justify its proposed different treatment for computer programs as one appropriate to the different character of programs, compared with traditional copyrighted works. 78 The new legal framework was said to respond and be tailored to the special character of programs. American firms, however, viewed the MITI proposal, particularly its compulsory license provisions, as an effort by the Japanese to appropriate the valuable products of the U.S. software industry. Partly as a result of U.S. pressure, the MITI proposal was rejected by the Japanese government, and the alternative copyright proposal made by the ministry with jurisdiction over copyright law was adopted.

Notwithstanding their inclusion in copyright law, computer programs are a special category of protected work under Japanese law. Limiting the scope of copyright protection for programs is a provision indicating that program languages, rules, and algorithms are not protected by copyright law. 79 Japanese case law under this copyright statute has proceeded along lines similar to U.S. case law, with regard to exact and near-exact copying of program code and graphical aspects of videogame programs, 80 but there have been some Japanese court decisions interpreting the exclusion from protection provisions in a manner seemingly at odds with some U.S. Decisions.

The Tokyo High Court, for example, has opined that the processing flow of a program (an aspect of a program said to be protectable by U.S. law in the Whelan case) is an algorithm within the meaning of the copyright limitation provision. 81 Another seems to bear out Professor Karjala's prediction that Japanese courts would interpret the programming language limitation to permit firms to make compatible software. 82 There is one Japanese decision that can be read to prohibit reverse engineering of program code, but because this case involved not only disassembly of program code but also distribution of a clearly infringing program, the legality of intermediate copying to discern such things as interface information is unclear in Japan. 83

Other Nations

The United States has been pressing a number of nations to give "proper respect" to U.S. intellectual property products, including computer programs. In some cases, as in its dealings with the People's Republic of China, the United States has been pressing for new legislation to protect software under copyright law. In some cases, as in its dealings with Thailand, the United States has been pressing for more vigorous enforcement of intellectual property laws as they affect U.S. intellectual property products. In other cases, as in its dealings with Brazil, the United States pressed for repeal of sui generis legislation that disadvantaged U.S. software producers, compared with Brazilian developers. The United States has achieved some success in these efforts. Despite these successes, piracy of U.S.-produced software and other intellectual property products remains a substantial source of concern.

FUTURE CHALLENGES

Many of the challenges posed by use of existing intellectual property laws to protect computer programs have been discussed in previous sections. This may, however, only map the landscape of legal issues of widespread concern today. Below are some suggestions about issues as to which computer programs may present legal difficulties in the future.

Advanced Software Systems

It has thus far been exceedingly difficult for the legal system to resolve even relatively simple disputes about software intellectual property rights, such as those involved in the Lotus v. Paperback Software case. This does not bode well for how the courts are likely to deal with more complex problems presented by more complex software in future cases. The difficulties arise partly from the lack of familiarity of judges with the technical nature of computers and software, and partly from the lack of close analogies within the body of copyright precedents from which resolutions of software issues might be drawn. The more complex the software, the greater is the likelihood that specially trained judges will be needed to resolve intellectual property disputes about the software. Some advanced software systems are also likely to be sufficiently different from traditional kinds of copyrighted works that the analogical distance between the precedents and a software innovation may make it difficult to predict how copyright law should be applied to it. What copyright protection should be available, for example, to a user interface that responds to verbal commands, gestures, or movements of eyeballs?

Digital Media

The digital medium itself may require adaptation of the models underlying existing intellectual property systems. 84 Copyright law is built largely on the assumption that authors and publishers can control the manufacture and distribution of copies of protected works emanating from a central source. The ease with which digital works can be copied, redistributed, and used by multiple users, as well as the compactness and relative invisibility of works in digital form, have already created substantial incentives for developers of digital media products to focus their commercialization efforts on controlling the uses of digital works, rather than on the distribution of copies, as has more commonly been the rule in copyright industries.

Rules designed for controlling the production and distribution of copies may be difficult to adapt to a system in which uses need to be controlled. Some digital library and hypertext publishing systems seem to be designed to bypass copyright law (and its public policy safeguards, such as the fair use rule) and establish norms of use through restrictive access licensing

agreements. 85 Whether the law will eventually be used to regulate conditions imposed on access to these systems, as it has regulated access to such communication media as broadcasting, remains to be seen. However, the increasing convergence of intellectual property policy, broadcast and telecommunications policy, and other aspects of information policy seems inevitable.

There are already millions of people connected to networks of computers, who are thereby enabled to communicate with one another with relative ease, speed, and reliability. Plans are afoot to add millions more and to allow a wide variety of information services to those connected to the networks, some of which are commercial and some of which are noncommercial in nature. Because networks of this type and scope are a new phenomenon, it would seem quite likely that some new intellectual property issues will arise as the use of computer networks expands. The more commercial the uses of the networks, the more likely intellectual property disputes are to occur.

More of the content distributed over computer networks is copyrighted than its distributors seem to realize, but even as to content that has been recognized as copyrighted, there is a widespread belief among those who communicate over the net that at least noncommercial distributions of content—no matter the number of recipients—are "fair uses" of the content. Some lawyers would agree with this; others would not. Those responsible for the maintenance of the network may need to be concerned about potential liability until this issue is resolved.

A different set of problems may arise when commercial uses are made of content distributed over the net. Here the most likely disputes are those concerning how broad a scope of derivative work rights copyright owners should have. Some owners of copyrights can be expected to resist allowing anyone but themselves (or those licensed by them) to derive any financial benefit from creating a product or service that is built upon the value of their underlying work. Yet value-added services may be highly desirable to consumers, and the ability of outsiders to offer these products and services may spur beneficial competition. At the moment, the case law generally regards a copyright owner's derivative work right as infringed only if a recognizable block of expression is incorporated into another work. 86 How-

ever, the ability of software developers to provide value-added products and services that derive value from the underlying work without copying expression from it may lead some copyright owners to seek to extend the scope of derivative work rights.

Patents and Information Infrastructure of the Future

If patents are issued for all manner of software innovations, they are likely to play an important role in the development of the information infrastructure of the future. Patents have already been issued for hypertext navigation systems, for such things as latent semantic indexing algorithms, and for other software innovations that might be used in the construction of a new information infrastructure. Although it is easy to develop a list of the possible pros and cons of patent protection in this domain, as in the more general debate about software patents, it is worth noting that patents have not played a significant role in the information infrastructure of the past or of the present. How patents would affect the development of the new information infrastructure has not been given the study this subject may deserve.

Conflicts Between Information Haves and Have-Nots on an International Scale

When the United States was a developing nation and a net importer of intellectual property products, it did not respect copyright interests of any authors but its own. Charles Dickens may have made some money from the U.S. tours at which he spoke at public meetings, but he never made a dime from the publication of his works in the United States. Now that the United States is a developed nation and a net exporter of intellectual property products, its perspective on the rights of developing nations to determine for themselves what intellectual property rights to accord to the products of firms of the United States and other developed nations has changed. Given the greater importance nowadays of intellectual property products, both to the United States and to the world economy, it is foreseeable that there will be many occasions on which developed and developing nations will have disagreements on intellectual property issues.

The United States will face a considerable challenge in persuading other nations to subscribe to the same detailed rules that it has for dealing with intellectual property issues affecting computer programs. It may be easier for the United States to deter outright ''piracy" (unauthorized copying of the whole or substantially the whole of copyrighted works) of U.S. intellectual property products than to convince other nations that they must adopt the same rules as the United States has for protecting software.

It is also well for U.S. policymakers and U.S. firms to contemplate the possibility that U.S. firms may not always have the leading position in the world market for software products that they enjoy today. When pushing for very "strong" intellectual property protection for software today in the expectation that this will help to preserve the U.S. advantage in the world market, U.S. policymakers should be careful not to push for adoption of rules today that may substantially disadvantage them in the world market of the future if, for reasons not foreseen today, the United States loses the lead it currently enjoys in the software market.

As technological developments multiply around the globe—even as the patenting of human genes comes under serious discussion—nations, companies, and researchers find themselves in conflict over intellectual property rights (IPRs). Now, an international group of experts presents the first multidisciplinary look at IPRs in an age of explosive growth in science and technology.

This thought-provoking volume offers an update on current international IPR negotiations and includes case studies on software, computer chips, optoelectronics, and biotechnology—areas characterized by high development cost and easy reproducibility. The volume covers these and other issues:

• Modern economic theory as a basis for approaching international IPRs.
• U.S. intellectual property practices versus those in Japan, India, the European Community, and the developing and newly industrializing countries.
• Trends in science and technology and how they affect IPRs.
• Pros and cons of a uniform international IPRs regime versus a system reflecting national differences.

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• Knowledge Base
• Methodology
• Case Study | Definition, Examples & Methods

Case Study | Definition, Examples & Methods

Published on 5 May 2022 by Shona McCombes . Revised on 30 January 2023.

A case study is a detailed study of a specific subject, such as a person, group, place, event, organisation, or phenomenon. Case studies are commonly used in social, educational, clinical, and business research.

A case study research design usually involves qualitative methods , but quantitative methods are sometimes also used. Case studies are good for describing , comparing, evaluating, and understanding different aspects of a research problem .

Table of contents

When to do a case study, step 1: select a case, step 2: build a theoretical framework, step 3: collect your data, step 4: describe and analyse the case.

A case study is an appropriate research design when you want to gain concrete, contextual, in-depth knowledge about a specific real-world subject. It allows you to explore the key characteristics, meanings, and implications of the case.

Case studies are often a good choice in a thesis or dissertation . They keep your project focused and manageable when you don’t have the time or resources to do large-scale research.

You might use just one complex case study where you explore a single subject in depth, or conduct multiple case studies to compare and illuminate different aspects of your research problem.

Prevent plagiarism, run a free check.

Once you have developed your problem statement and research questions , you should be ready to choose the specific case that you want to focus on. A good case study should have the potential to:

• Provide new or unexpected insights into the subject
• Challenge or complicate existing assumptions and theories
• Propose practical courses of action to resolve a problem
• Open up new directions for future research

Unlike quantitative or experimental research, a strong case study does not require a random or representative sample. In fact, case studies often deliberately focus on unusual, neglected, or outlying cases which may shed new light on the research problem.

If you find yourself aiming to simultaneously investigate and solve an issue, consider conducting action research . As its name suggests, action research conducts research and takes action at the same time, and is highly iterative and flexible. 

However, you can also choose a more common or representative case to exemplify a particular category, experience, or phenomenon.

While case studies focus more on concrete details than general theories, they should usually have some connection with theory in the field. This way the case study is not just an isolated description, but is integrated into existing knowledge about the topic. It might aim to:

• Exemplify a theory by showing how it explains the case under investigation
• Expand on a theory by uncovering new concepts and ideas that need to be incorporated
• Challenge a theory by exploring an outlier case that doesn’t fit with established assumptions

To ensure that your analysis of the case has a solid academic grounding, you should conduct a literature review of sources related to the topic and develop a theoretical framework . This means identifying key concepts and theories to guide your analysis and interpretation.

There are many different research methods you can use to collect data on your subject. Case studies tend to focus on qualitative data using methods such as interviews, observations, and analysis of primary and secondary sources (e.g., newspaper articles, photographs, official records). Sometimes a case study will also collect quantitative data .

The aim is to gain as thorough an understanding as possible of the case and its context.

In writing up the case study, you need to bring together all the relevant aspects to give as complete a picture as possible of the subject.

How you report your findings depends on the type of research you are doing. Some case studies are structured like a standard scientific paper or thesis, with separate sections or chapters for the methods , results , and discussion .

Others are written in a more narrative style, aiming to explore the case from various angles and analyse its meanings and implications (for example, by using textual analysis or discourse analysis ).

In all cases, though, make sure to give contextual details about the case, connect it back to the literature and theory, and discuss how it fits into wider patterns or debates.

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McCombes, S. (2023, January 30). Case Study | Definition, Examples & Methods. Scribbr. Retrieved 21 May 2024, from https://www.scribbr.co.uk/research-methods/case-studies/

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51 The Case Study: What it is and What it Does

John Gerring is Professor of Political Science, Boston University.

• Published: 05 September 2013
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This article presents a reconstructed definition of the case study approach to research. This definition emphasizes comparative politics, which has been closely linked to this method since its creation. The article uses this definition as a basis to explore a series of contrasts between cross-case study and case study research. This article attempts to provide better understanding of this persisting methodological debate as a matter of tradeoffs, which may also contribute to destroying the boundaries that have separated these rival genres within the subfield of comparative politics.

Two centuries after Le Play’s pioneering work, the various disciplines of the social sciences continue to produce a vast number of case studies, many of which have entered the pantheon of classic works. Judging by the large volume of recent scholarly output the case study research design plays a central role in anthropology, archeology, business, education, history, medicine, political science, psychology, social work, and sociology (Gerring 2007 a , ch. 1 ). Even in economics and political economy, fields not usually noted for their receptiveness to case-based work, there has been something of a renaissance. Recent studies of economic growth have turned to case studies of unusual countries such as Botswana, Korea, and Mauritius. 1 Debates on the relationship between trade and growth and the IMF and growth have likewise combined cross-national regression evidence with in-depth (quantitativ and qualitative) case analysis ( Srinivasan and Bhagwati 1999 ; Vreeland 2003 ). Work on ethnic politics and ethnic conflict has exploited within-country variation or small-N cross-country comparisons ( Abadie and Gardeazabal 2003 ; Chandra 2004 ; Posner 2004 ). By the standard of praxis, therefore, it would appear that the method of the case study is solidly ensconced, perhaps even thriving. Arguably, we are witnessing a movement away from a variable-centered approach to causality in the social sciences and towards a case-based approach.

Indeed, the statistical analysis of cross-case observational data has been subjected to increasing scrutiny in recent years. It no longer seems self-evident, even to nomothetically inclined scholars, that non-experimental data drawn from nation-states, cities, social movements, civil conflicts, or other complex phenomena should be treated in standard regression formats. The complaints are myriad, and oftreviewed. 2 They include: (a) the problem of arriving at an adequate specification of the causal model, given a plethora of plausible models, and the associated problem of modeling interactions among these covariates; (b) identification problems, which cannot always be corrected by instrumental variable techniques; (c) the problem of “extreme” counterfactuals, i.e. extrapolating or interpolating results from a general model where the extrapolations extend beyond the observable data points; (d) problems posed by influential cases; (e) the arbitrariness of standard significance tests; (f) the misleading precision of point estimates in the context of “curve-fitting” models; (g) the problem of finding an appropriate estimator and modeling temporal autocorrelation in pooled time series; (h) the difficulty of identifying causal mechanisms; and last, but certainly not least, (i) the ubiquitous problem of faulty data drawn from a variety of questionable sources. Most of these difficulties may be understood as the by-product of causal variables that offer limited variation through time and cases that are extremely heterogeneous.

A principal factor driving the general discontent with cross-case observational research is a new-found interest in experimental models of social scientific research. Following the pioneering work of Donald Campbell (1988 ; Cook and Campbell 1979 ) and Donald Rubin (1974) , methodologists have taken a hard look at the regression model and discovered something rather obvious but at the same time crucially important: this research bears only a faint relationship to the true experiment, for all the reasons noted above. The current excitement generated by matching estimators, natural experiments, and field experiments may be understood as a move toward a quasi-experimental, and frequently case-based analysis of causal relations. Arguably, this is because the experimental ideal is often better approximated by a small number of cases that are closely related to one another, or by a single case observed over time, than by a large sample of heterogeneous units.

A third factor militating towards case-based analysis is the development of a series of alternatives to the standard linear/additive model of cross-case analysis, thus establishing a more variegated set of tools to capture the complexity of social behavior (see Brady and Collier 2004 ). Charles Ragin and associates have shown us how to deal with situations where multiple causal paths lead to the same set of outcomes, a series of techniques known as Qualitative Comparative Analysis (QCA) (“Symposium: Qualitative Comparative Analysis” 2004). Andrew Abbott has worked out a method that maps causal sequences across cases, known as optimal sequence matching ( Abbott 2001 ; Abbott and Forrest 1986 ; Abbott and Tsay 2000 ). Bear Braumoeller, Gary Goertz, Jack Levy, and Harvey Starr have defended the importance of necessary-condition arguments in the social sciences, and have shown how these arguments might be analyzed ( Braumoeller and Goertz 2000 ; Goertz 2003 ; Goertz and Levy forthcoming; Goertz and Starr 2003 ). James Fearon, Ned Lebow, Philip Tetlock, and others have explored the role of counterfactual thought experiments in the analysis of individual case histories ( Fearon 1991 ; Lebow 2000 ; Tetlock and Belkin 1996 ). Colin Elman has developed a typological method of analyzing cases ( Elman 2005 ). David Collier, Jack Goldstone, Peter Hall, James Mahoney, and Dietrich Rueschemeyer have worked to revitalize the comparative and comparative-historical methods ( Collier 1993 ; Goldstone 1997 ; Hall 2003 ; Mahoney and Rueschemeyer 2003 ). And scores of researchers have attacked the problem of how to convert the relevant details of a temporally constructed narrative into standardized formats so that cases can be meaningfully compared (Abell 1987 , 2004 ; Abbott 1992 ; Buthe 2002 ; Griffin 1993 ). While not all of these techniques are, strictly speaking, case study techniques—since they sometimes involve a large number of cases—they do move us closer to a case-based understanding of causation insofar as they preserve the texture and detail of individual cases, features that are often lost in large-N cross-case analysis.

A fourth factor concerns the recent marriage of rational choice tools with case study analysis, sometimes referred to as an “analytic narrative” ( Bates et al. 1998 ). Whether the technique is qualitative or quantitative, scholars equipped with economic models are turning, increasingly, to case studies in order to test the theoretical predictions of a general model, investigate causal mechanisms, and/or explain the features of a key case.

Finally, epistemological shifts in recent decades have enhanced the attractiveness of the case study format. The “positivist” model of explanation, which informed work in the social sciences through most of the twentieth century, tended to downplay the importance of causal mechanisms in the analysis of causal relations. Famously, Milton Friedman (1953) argued that the only criterion of a model was to be found in its accurate prediction of outcomes. The verisimilitude of the model, its accurate depiction of reality, was beside the point. In recent years, this explanatory trope has come under challenge from “realists,” who claim (among other things) that causal analysis should pay close attention to causal mechanisms (e.g. Bunge 1997 ; Little 1998 ). Within political science and sociology, the identification of a specific mechanism—a causal pathway—has come to be seen as integral to causal analysis, regardless of whether the model in question is formal or informal or whether the evidence is qualitative or quantitative ( Achen 2002 ; Elster 1998 ; George and Bennett 2005 ; Hedstrom and Swedberg 1998 ). Given this new-found (or at least newly self-conscious) interest in mechanisms, it is not surprising that social scientists would turn to case studies as a mode of causal investigation.

For all the reasons stated above, one might intuit that social science is moving towards a case-based understanding of causal relations. Yet, this movement, insofar as it exists, has scarcely been acknowledged, and would certainly be challenged by many close observers—including some of those cited in the foregoing passages.

The fact is that the case study research design is still viewed by most methodologists with extreme circumspection. A work that focuses its attention on a single example of a broader phenomenon is apt to be described as a “mere” case study, and is often identified with loosely framed and non-generalizable theories, biased case selection, informal and undisciplined research designs, weak empirical leverage (too many variables and too few cases), subjective conclusions, non-replicability, and causal determinism. To some, the term case study is an ambiguous designation covering a multitude of “inferential felonies.” 3

The quasi-mystical qualities associated with the case study persist to this day. In the field of psychology, a gulf separates “scientists” engaged in cross-case research and “practitioners” engaged in clinical research, usually focused on several cases ( Hersen and Barlow 1976 , 21). In the fields of political science and sociology, case study researchers are acknowledged to be on the “soft” side of hard disciplines. And across fields, the persisting case study orientations of anthropology, education, law, social work, and various other fields and subfields relegate them to the non-rigorous, non-systematic, non-scientific, non-positivist end of the academic spectrum.

The methodological status of the case study is still, officially, suspect. Even among its defenders there is confusion over the virtues and vices of this ambiguous research design. Practitioners continue to ply their trade but have difficulty articulating what it is they are doing, methodologically speaking. The case study survives in a curious methodological limbo.

This leads to a paradox: although much of what we know about the empirical world has been generated by case studies and case studies continue to constitute a large proportion of work generated by the social science disciplines, the case study method is poorly understood.

How can we make sense of the profound disjuncture between the acknowledged contributions of this genre to the various disciplines of social science and its maligned status within these disciplines? If case studies are methodologically flawed, why do they persist? Should they be rehabilitated, or suppressed? How fruitful is this style of research?

In this chapter, I provide a reconstructed definition of the case study approach to research with special emphasis on comparative politics, a field that has been closely identified with this method since its birth. Based on this definition, I then explore a series of contrasts between case study and cross-case study research. These contrasts are intended to illuminate the characteristic strengths and weaknesses (“affinities”) of these two research designs, not to vindicate one or the other. The effort of this chapter is to understand this persisting methodological debate as a matter of tradeoffs. Case studies and cross-case studies explore the world in different ways. Yet, properly constituted, there is no reason that case study results cannot be synthesized with results gained from cross-case analysis, and vice versa. My hope, therefore, is that this chapter will contribute to breaking down the boundaries that have separated these rival genres within the subfield of comparative politics.

1 Definitions

The key term of this chapter is, admittedly, a definitional morass. To refer to a work as a “case study” might mean: that its method is qualitative, small-N; that the research is holistic, thick (a more or less comprehensive examination of a phenomenon); that it utilizes a particular type of evidence (e.g. ethnographic, clinical, non-experimental, non-survey based, participant observation, process tracing, historical, textual, or field research); that its method of evidence gathering is naturalistic (a “real-life context”); that the research investigates the properties of a single observation; or that the research investigates the properties of a single phenomenon, instance, or example. Evidently, researchers have many things in mind when they talk about case study research. Confusion is compounded by the existence of a large number of near-synonyms—single unit, single subject, single case, N = 1, case based, case control, case history, case method, case record, case work, clinical research, and so forth. As a result of this profusion of terms and meanings, proponents and opponents of the case study marshal a wide range of arguments but do not seem any closer to agreement than when this debate was first broached several decades ago.

Can we reconstruct this concept in a clearer, more productive fashion? In order to do so we must understand how the key terms—case and case study—are situated within a neighborhood of related terms. In this crowded semantic field, each term is defined in relation to others. And in the context of a specific work or research terrain, they all take their meaning from a specific inference. (The reader should bear in mind that any change in the inference, and the meaning of all the key terms will probably change.) My attempt here will be to provide a single, determinate, definition of these key terms. Of course, researchers may choose to define these terms in many different ways. However, for purposes of methodological discussion it is helpful to enforce a uniform vocabulary.

Let us stipulate that a case connotes a spatially delimited phenomenon (a unit) observed at a single point in time or over some period of time. It comprises the sort of phenomena that an inference attempts to explain. Thus, in a study that attempts to explain certain features of nation-states, cases are comprised of nation-states (across some temporal frame). In a study that attempts to explain the behavior of individuals, individuals comprise the cases. And so forth. Each case may provide a single observation or multiple (within-case) observations.

For students of comparative politics, the archetypal case is the dominant political unit of our time, the nation-state. However, the study of smaller social and political units (regions, cities, villages, communities, social groups, families) or specific institutions (political parties, interest groups, businesses) is equally common in other subfields, and perhaps increasingly so in comparative politics. Whatever the chosen unit, the methodological issues attached to the case study have nothing to do with the size of the individual cases. A case may be created out of any phenomenon so long as it has identifiable boundaries and comprises the primary object of an inference.

Note that the spatial boundaries of a case are often more apparent than its temporal boundaries. We know, more or less, where a country begins and ends, even though we may have difficulty explaining when a country begins and ends. Yet, some temporal boundaries must be assumed. This is particularly important when cases consist of discrete events—crises, revolutions, legislative acts, and so forth—within a single unit. Occasionally, the temporal boundaries of a case are more obvious than its spatial boundaries. This is true when the phenomena under study are eventful but the unit undergoing the event is amorphous. For example, if one is studying terrorist attacks it may not be clear how the spatial unit of analysis should be understood, but the events themselves may be well bounded.

A case study may be understood as the intensive study of a single case for the purpose of understanding a larger class of cases (a population). Case study research may incorporate several cases. However, at a certain point it will no longer be possible to investigate those cases intensively. At the point where the emphasis of a study shifts from the individual case to a sample of cases we shall say that a study is cross-case . Evidently, the distinction between a case study and cross-case study is a continuum. The fewer cases there are, and the more intensively they are studied, the more a work merits the appellation case study. Even so, this proves to be a useful distinction, for much follows from it.

A few additional terms will now be formally defined.

An observation is the most basic element of any empirical endeavor. Conventionally, the number of observations in an analysis is referred to with the letter N . (Confusingly, N may also be used to designate the number of cases in a study, a usage that I shall try to avoid.) A single observation may be understood as containing several dimensions, each of which may be measured (across disparate observations) as a variable. Where the proposition is causal, these may be subdivided into dependent (Y) and independent (X) variables. The dependent variable refers to the outcome of an investigation. The independent variable refers to the explanatory (causal) factor, that which the outcome is supposedly dependent on.

Note that a case may consist of a single observation (N = 1). This would be true, for example, in a cross-sectional analysis of multiple cases. In a case study, however, the case under study always provides more than one observation. These may be constructed diachronically (by observing the case or some subset of within-case units through time) or synchronically (by observing within-case variation at a single point in time).

This is a clue to the fact that case studies and cross-case usually operate at different levels of analysis. The case study is typically focused on within-case variation (if there a cross-case component it is probably secondary). The cross-case study, as the name suggests, is typically focused on cross-case variation (if there is also within-case variation, it is secondary in importance). They have the same object in view—the explanation of a population of cases—but they go about this task differently.

A sample consists of whatever cases are subjected to formal analysis; they are the immediate subject of a study or case study. (Confusingly, the sample may also refer to the observations under study, and will be so used at various points in this narrative. But at present, we treat the sample as consisting of cases.) Technically, one might say that in a case study the sample consists of the case or cases that are subjected to intensive study. However, usually when one uses the term sample one is implying that the number of cases is rather large. Thus, “sample-based work” will be understood as referring to large-N cross-case methods—the opposite of case study work. Again, the only feature distinguishing the case study format from a sample-based (or “cross-case”) research design is the number of cases falling within the sample—one or a few versus many. Case studies, like large-N samples, seek to represent, in all ways relevant to the proposition at hand, a population of cases. A series of case studies might therefore be referred to as a sample if they are relatively brief and relatively numerous; it is a matter of emphasis and of degree. The more case studies one has, the less intensively each one is studied, and the more confident one is in their representativeness (of some broader population), the more likely one is to describe them as a sample rather than a series of case studies. For practical reasons—unless, that is, a study is extraordinarily long—the case study research format is usually limited to a dozen cases or less. A single case is not at all unusual.

The sample rests within a population of cases to which a given proposition refers. The population of an inference is thus equivalent to the breadth or scope of a proposition. (I use the terms proposition , hypothesis , inference , and argument interchangeably.) Note that most samples are not exhaustive; hence the use of the term sample, referring to sampling from a population. Occasionally, however, the sample equals the population of an inference; all potential cases are studied.

For those familiar with the rectangular form of a dataset it may be helpful to conceptualize observations as rows, variables as columns, and cases as either groups of observations or individual observations.

2 What is a Case Study Good For? Case Study versus Cross-case Analysis

I have argued that the case study approach to research is most usefully defined as the intensive study of a single unit or a small number of units (the cases), for the purpose of understanding a larger class of similar units (a population of cases). This is put forth as a minimal definition of the topic. 4 I now proceed to discuss the non -definitional attributes of the case study—attributes that are often, but not invariably, associated with the case study method. These will be understood as methodological affinities flowing from a minimal definition of the concept. 5

The case study research design exhibits characteristic strengths and weaknesses relative to its large-N cross-case cousin. These tradeoffs derive, first of all, from basic research goals such as (1) whether the study is oriented toward hypothesis generating or hypothesis testing, (2) whether internal or external validity is prioritized, (3) whether insight into causal mechanisms or causal effects is more valuable, and (4) whether the scope of the causal inference is deep or broad. These tradeoffs also hinge on the shape of the empirical universe, i.e. (5) whether the population of cases under study is heterogeneous or homogeneous, (6) whether the causal relationship of interest is strong or weak, (7) whether useful variation on key parameters within that population is rare or common, and (8) whether available data are concentrated or dispersed.

Along each of these dimensions, case study research has an affinity for the first factor and cross-case research has an affinity for the second, as summarized in Table 51.1 . To clarify, these tradeoffs represent methodological affinities , not invariant laws. Exceptions can be found to each one. Even so, these general tendencies are often noted in case study research and have been reproduced in multiple disciplines and subdisciplines over the course of many decades.

It should be stressed that each of these tradeoffs carries a ceteris paribus caveat. Case studies are more useful for generating new hypotheses, all other things being equal . The reader must bear in mind that many additional factors also rightly influence a writer’s choice of research design, and they may lean in the other direction. Ceteris are not always paribus. One should not jump to conclusions about the research design appropriate to a given setting without considering the entire range of issues involved—some of which may be more important than others.

3 Hypothesis: Generating versus Testing

Social science research involves a quest for new theories as well as a testing of existing theories; it is comprised of both “conjectures” and “refutations.” 6 Regrettably, social science methodology has focused almost exclusively on the latter. The conjectural element of social science is usually dismissed as a matter of guesswork, inspiration, or luck—a leap of faith, and hence a poor subject for methodological reflection. 7 Yet, it will readily be granted that many works of social science, including most of the acknowledged classics, are seminal rather than definitive. Their classic status derives from the introduction of a new idea or a new perspective that is subsequently subjected to more rigorous (and refutable) analysis. Indeed, it is difficult to devise a program of falsification the first time a new theory is proposed. Path-breaking research, almost by definition, is protean. Subsequent research on that topic tends to be more definitive insofar as its primary task is limited: to verify or falsify a pre-existing hypothesis. Thus, the world of social science may be usefully divided according to the predominant goal undertaken in a given study, either hypothesis generating or hypothesis testing . There are two moments of empirical research, a lightbulb moment and a skeptical moment, each of which is essential to the progress of a discipline. 8

Case studies enjoy a natural advantage in research of an exploratory nature. Several millennia ago, Hippocrates reported what were, arguably, the first case studies ever conducted. They were fourteen in number. 9 Darwin’s insights into the process of human evolution came after his travels to a few select locations, notably Easter Island. Freud’s revolutionary work on human psychology was constructed from a close observation of fewer than a dozen clinical cases. Piaget formulated his theory of human cognitive development while watching his own two children as they passed from childhood to adulthood. Lévi-Strauss’s structuralist theory of human cultures built on the analysis of several North and South American tribes. Douglass North’s neo-institutionalist theory of economic development was constructed largely through a close analysis of a handful of early developing states (primarily England, the Netherlands, and the United States). 10 Many other examples might be cited of seminal ideas that derived from the intensive study of a few key cases.

Evidently, the sheer number of examples of a given phenomenon does not, by itself, produce insight. It may only confuse. How many times did Newton observe apples fall before he recognized the nature of gravity? This is an apocryphal example, but it illustrates a central point: case studies may be more useful than cross-case studies when a subject is being encountered for the first time or is being considered in a fundamentally new way. After reviewing the case study approach to medical research, one researcher finds that although case reports are commonly regarded as the lowest or weakest form of evidence, they are nonetheless understood to comprise “the first line of evidence.” The hallmark of case reporting, according to Jan Vandenbroucke, “is to recognize the unexpected.” This is where discovery begins. 11

The advantages that case studies offer in work of an exploratory nature may also serve as impediments in work of a confirmatory/disconfirmatory nature. Let us briefly explore why this might be so. 12

Traditionally, scientific methodology has been defined by a segregation of conjecture and refutation. One should not be allowed to contaminate the other. 13 Yet, in the real world of social science, inspiration is often associated with perspiration. “Lightbulb” moments arise from a close engagement with the particular facts of a particular case. Inspiration is more likely to occur in the laboratory than in the shower.

The circular quality of conjecture and refutation is particularly apparent in case study research. Charles Ragin notes that case study research is all about “casing”—defining the topic, including the hypothesis(es) of primary interest, the outcome, and the set of cases that offer relevant information vis-à-vis the hypothesis. 14 A study of the French Revolution may be conceptualized as a study of revolution, of social revolution, of revolt, of political violence, and so forth. Each of these topics entails a different population and a different set of causal factors. A good deal of authorial intervention is necessary in the course of defining a case study topic, for there is a great deal of evidentiary leeway. Yet, the “subjectivity” of case study research allows for the generation of a great number of hypotheses, insights that might not be apparent to the cross-case researcher who works with a thinner set of empirical data across a large number of cases and with a more determinate (fixed) definition of cases, variables, and outcomes. It is the very fuzziness of case studies that grants them an advantage in research at the exploratory stage, for the single-case study allows one to test a multitude of hypotheses in a rough-and-ready way. Nor is this an entirely “conjectural” process. The relationships discovered among different elements of a single case have a prima facie causal connection: they are all at the scene of the crime. This is revelatory when one is at an early stage of analysis, for at that point there is no identifiable suspect and the crime itself may be difficult to discern. The fact that A , B , and C are present at the expected times and places (relative to some outcome of interest) is sufficient to establish them as independent variables. Proximal evidence is all that is required. Hence, the common identification of case studies as “plausibility probes,” “pilot studies,” “heuristic studies,” “exploratory” and “theory-building” exercises. 15

A large-N cross-study, by contrast, generally allows for the testing of only a few hypotheses but does so with a somewhat greater degree of confidence, as is appropriate to work whose primary purpose is to test an extant theory. There is less room for authorial intervention because evidence gathered from a cross-case research design can be interpreted in a limited number of ways. It is therefore more reliable. Another way of stating the point is to say that while case studies lean toward Type 1 errors (falsely rejecting the null hypothesis), cross-case studies lean toward Type 2 errors (failing to reject the false null hypothesis). This explains why case studies are more likely to be paradigm generating, while cross-case studies toil in the prosaic but highly structured field of normal science.

I do not mean to suggest that case studies never serve to confirm or disconfirm hypotheses. Evidence drawn from a single case may falsify a necessary or sufficient hypothesis, as discussed below. Additionally, case studies are often useful for the purpose of elucidating causal mechanisms, and this obviously affects the plausibility of an X/Y relationship. However, general theories rarely offer the kind of detailed and determinate predictions on within-case variation that would allow one to reject a hypothesis through pattern matching (without additional cross-case evidence). Theory testing is not the case study’s strong suit. The selection of “crucial” cases is at pains to overcome the fact that the cross-case N is minimal. Thus, one is unlikely to reject a hypothesis, or to consider it definitively proved, on the basis of the study of a single case.

Harry Eckstein himself acknowledges that his argument for case studies as a form of theory confirmation is largely hypothetical. At the time of writing, several decades ago, he could not point to any social science study where a crucial case study had performed the heroic role assigned to it. 16 I suspect that this is still more or less true. Indeed, it is true even of experimental case studies in the natural sciences. “We must recognize,” note Donald Campbell and Julian Stanley,

that continuous, multiple experimentation is more typical of science than once-and-for-all definitive experiments. The experiments we do today, if successful, will need replication and cross-validation at other times under other conditions before they can become an established part of science … [E]ven though we recognize experimentation as the basic language of proof … we should not expect that “crucial experiments” which pit opposing theories will be likely to have clear-cut outcomes. When one finds, for example, that competent observers advocate strongly divergent points of view, it seems likely on a priori grounds that both have observed something valid about the natural situation, and that both represent a part of the truth. The stronger the controversy, the more likely this is. Thus we might expect in such cases an experimental outcome with mixed results, or with the balance of truth varying subtly from experiment to experiment. The more mature focus…avoids crucial experiments and instead studies dimensional relationships and interactions along many degrees of the experimental variables. 17

A single case study is still a single shot—a single example of a larger phenomenon.

The tradeoff between hypothesis generating and hypothesis testing helps us to reconcile the enthusiasm of case study researchers and the skepticism of case study critics. They are both right, for the looseness of case study research is a boon to new conceptualizations just as it is a bane to falsification.

4 Validity: Internal versus External

Questions of validity are often distinguished according to those that are internal to the sample under study and those that are external (i.e. applying to a broader—unstudied—population). Cross-case research is always more representative of the population of interest than case study research, so long as some sensible procedure of case selection is followed (presumably some version of random sampling). Case study research suffers problems of representativeness because it includes, by definition, only a small number of cases of some more general phenomenon. Are the men chosen by Robert Lane typical of white, immigrant, working-class, American males? 18 Is Middletown representative of other cities in America? 19 These sorts of questions forever haunt case study research. This means that case study research is generally weaker with respect to external validity than its cross-case cousin.

The corresponding virtue of case study research is its internal validity. Often, though not invariably, it is easier to establish the veracity of a causal relationship pertaining to a single case (or a small number of cases) than for a larger set of cases. Case study researchers share the bias of experimentalists in this regard: they tend to be more disturbed by threats to within-sample validity than by threats to out-of-sample validity. Thus, it seems appropriate to regard the tradeoff between external and internal validity, like other tradeoffs, as intrinsic to the cross-case/single-case choice of research design.

5 Causal Insight: Causal Mechanisms versus Causal Effects

A third tradeoff concerns the sort of insight into causation that a researcher intends to achieve. Two goals may be usefully distinguished. The first concerns an estimate of the causal effect ; the second concerns the investigation of a causal mechanism (i.e. pathway from X to Y).

By causal effect I refer to two things: (a) the magnitude of a causal relationship (the expected effect on Y of a given change in X across a population of cases) and (b) the relative precision or uncertainty associated with that point estimate. Evidently, it is difficult to arrive at a reliable estimate of causal effects across a population of cases by looking at only a single case or a small number of cases. (The one exception would be an experiment in which a given case can be tested repeatedly, returning to a virgin condition after each test. But here one faces inevitable questions about the representativeness of that much-studied case.) 20 Thus, the estimate of a causal effect is almost always grounded in cross-case evidence.

It is now well established that causal arguments depend not only on measuring causal effects, but also on the identification of a causal mechanism. 21   X must be connected with Y in a plausible fashion; otherwise, it is unclear whether a pattern of covariation is truly causal in nature, or what the causal interaction might be. Moreover, without a clear understanding of the causal pathway(s) at work in a causal relationship it is impossible to accurately specify the model, to identify possible instruments for the regressor of interest (if there are problems of endogeneity), or to interpret the results. 22 Thus, causal mechanisms are presumed in every estimate of a mean (average) causal effect.

In the task of investigating causal mechanisms, cross-case studies are often not so illuminating. It has become a common criticism of large-N cross-national research—e.g. into the causes of growth, democracy, civil war, and other national-level outcomes—that such studies demonstrate correlations between inputs and outputs without clarifying the reasons for those correlations (i.e. clear causal pathways). We learn, for example, that infant mortality is strongly correlated with state failure; 23 but it is quite another matter to interpret this finding, which is consistent with a number of different causal mechanisms. Sudden increases in infant mortality might be the product of famine, of social unrest, of new disease vectors, of government repression, and of countless other factors, some of which might be expected to impact the stability of states, and others of which are more likely to be a result of state instability.

Case studies, if well constructed, may allow one to peer into the box of causality to locate the intermediate factors lying between some structural cause and its purported effect. Ideally, they allow one to “see” X and Y interact—Hume’s billiard ball crossing the table and hitting a second ball. 24 Barney Glaser and Anselm Strauss point out that in fieldwork “general relations are often discovered in vivo ; that is, the field worker literally sees them occur.” 25 When studying decisional behavior case study research may offer insight into the intentions, the reasoning capabilities, and the information-processing procedures of the actors involved in a given setting. Thus, Dennis Chong uses in-depth interviews with a very small sample of respondents in order to better understand the process by which people reach decisions about civil liberties issues. Chong comments:

One of the advantages of the in-depth interview over the mass survey is that it records more fully how subjects arrive at their opinions. While we cannot actually observe the underlying mental process that gives rise to their responses, we can witness many of its outward manifestations. The way subjects ramble, hesitate, stumble, and meander as they formulate their answers tips us off to how they are thinking and reasoning through political issues. 26

Similarly, the investigation of a single case may allow one to test the causal implications of a theory, thus providing corroborating evidence for a causal argument. This is sometimes referred to as pattern matching ( Campbell 1988 ).

Dietrich Rueschemeyer and John Stephens offer an example of how an examination of causal mechanisms may call into question a general theory based on cross-case evidence. The thesis of interest concerns the role of British colonialism in fostering democracy among postcolonial regimes. In particular, the authors investigate the diffusion hypothesis, that democracy was enhanced by “the transfer of British governmental and representative institutions and the tutoring of the colonial people in the ways of British government.” On the basis of in-depth analysis of several cases the authors report:

We did find evidence of this diffusion effect in the British settler colonies of North America and the Antipodes; but in the West Indies, the historical record points to a different connection between British rule and democracy. There the British colonial administration opposed suffrage extension, and only the white elites were “tutored” in the representative institutions. But, critically, we argued on the basis of the contrast with Central America, British colonialism did prevent the local plantation elites from controlling the local state and responding to the labor rebellion of the 1930s with massive repression. Against the adamant opposition of that elite, the British colonial rulers responded with concessions which allowed for the growth of the party– union complexes rooted in the black middle and working classes, which formed the backbone of the later movement for democracy and independence. Thus, the narrative histories of these cases indicate that the robust statistical relation between British colonialism and democracy is produced only in part by diffusion. The interaction of class forces, state power, and colonial policy must be brought in to fully account for the statistical result. 27

Whether or not Rueschemeyer and Stephens are correct in their conclusions need not concern us here. What is critical, however, is that any attempt to deal with this question of causal mechanisms is heavily reliant on evidence drawn from case studies. In this instance, as in many others, the question of causal pathways is simply too difficult, requiring too many poorly measured or unmeasurable variables, to allow for accurate cross-sectional analysis. 28

To be sure, causal mechanisms do not always require explicit attention. They may be quite obvious. And in other circumstances, they may be amenable to cross-case investigation. For example, a sizeable literature addresses the causal relationship between trade openness and the welfare state. The usual empirical finding is that more open economies are associated with higher social welfare spending. The question then becomes why such a robust correlation exists. What are the plausible interconnections between trade openness and social welfare spending? One possible causal path, suggested by David Cameron, 29 is that increased trade openness leads to greater domestic economic vulnerability to external shocks (due, for instance, to changing terms of trade). If so, one should find a robust correlation between annual variations in a country’s terms of trade (a measure of economic vulnerability) and social welfare spending. As it happens, the correlation is not robust and this leads some commentators to doubt whether the putative causal mechanism proposed by David Cameron and many others is actually at work. 30 Thus, in instances where an intervening variable can be effectively operationalized across a large sample of cases it may be possible to test causal mechanisms without resorting to case study investigation. 31

Even so, the opportunities for investigating causal pathways are generally more apparent in a case study format. Consider the contrast between formulating a standardized survey for a large group of respondents and formulating an in-depth interview with a single subject or a small set of subjects, such as that undertaken by Dennis Chong in the previous example. In the latter situation, the researcher is able to probe into details that would be impossible to delve into, let alone anticipate, in a standardized survey. She may also be in a better position to make judgements as to the veracity and reliability of the respondent. Tracing causal mechanisms is about cultivating sensitivity to a local context. Often, these local contexts are essential to cross-case testing. Yet, the same factors that render case studies useful for micro-level investigation also make them less useful for measuring mean (average) causal effects. It is a classic tradeoff.

6 Scope of Proposition: Deep versus Broad

The utility of a case study mode of analysis is in part a product of the scope of the causal argument that a researcher wishes to prove or demonstrate. Arguments that strive for great breadth are usually in greater need of cross-case evidence; causal arguments restricted to a small set of cases can more plausibly subsist on the basis of a single-case study. The extensive/intensive tradeoff is fairly commonsensical. 32 A case study of France probably offers more useful evidence for an argument about Europe than for an argument about the whole world. Propositional breadth and evidentiary breadth generally go hand in hand.

Granted, there are a variety of ways in which single-case studies can credibly claim to provide evidence for causal propositions of broad reach—e.g. by choosing cases that are especially representative of the phenomenon under study (“typical” cases) or by choosing cases that represent the most difficult scenario for a given proposition and are thus biased against the attainment of certain results (“crucial” cases). Even so, a proposition with a narrow scope is more conducive to case study analysis than a proposition with a broad purview, all other things being equal. The breadth of an inference thus constitutes one factor, among many, in determining the utility of the case study mode of analysis. This is reflected in the hesitancy of many case study researchers to invoke determinate causal propositions with great reach—“covering laws,” in the idiom of philosophy of science.

By the same token, one of the primary virtues of the case study method is the depth of analysis that it offers. One may think of depth as referring to the detail, richness, completeness, wholeness, or the degree of variance in an outcome that is accounted for by an explanation. The case study researcher’s complaint about the thinness of cross-case analysis is well taken; such studies often have little to say about individual cases. Otherwise stated, cross-case studies are likely to explain only a small portion of the variance with respect to a given outcome. They approach that outcome at a very general level. Typically, a cross-case study aims only to explain the occurrence/non-occurrence of a revolution, while a case study might also strive to explain specific features of that event—why it occurred when it did and in the way that it did. Case studies are thus rightly identified with “holistic” analysis and with the “thick” description of events. 33

Whether to strive for breadth or depth is not a question that can be answered in any definitive way. All we can safely conclude is that researchers invariably face a choice between knowing more about less, or less about more. The case study method may be defended, as well as criticized, along these lines. 34 Indeed, arguments about the “contextual sensitivity” of case studies are perhaps more precisely (and fairly) understood as arguments about depth and breadth. The case study researcher who feels that cross-case research on a topic is insensitive to context is usually not arguing that nothing at all is consistent across the chosen cases. Rather, the case study researcher’s complaint is that much more could be said—accurately—about the phenomenon in question with a reduction in inferential scope. 35

Indeed, I believe that a number of traditional issues related to case study research can be understood as the product of this basic tradeoff. For example, case study research is often lauded for its holistic approach to the study of social phenomena in which behavior is observed in natural settings. Cross-case research, by contrast, is criticized for its construction of artificial research designs that decontextualize the realm of social behavior by employing abstract variables that seem to bear little relationship to the phenomena of interest. 36 These associated congratulations and critiques may be understood as a conscious choice on the part of case study researchers to privilege depth over breadth.

7 The Population of Cases: Heterogeneous versus Homogeneous

The choice between a case study and cross-case style of analysis is driven not only by the goals of the researcher, as reviewed above, but also by the shape of the empirical universe that the researcher is attempting to understand. Consider, for starters, that the logic of cross-case analysis is premised on some degree of cross-unit comparability (unit homogeneity). Cases must be similar to each other in whatever respects might affect the causal relationship that the writer is investigating, or such differences must be controlled for. Uncontrolled heterogeneity means that cases are “apples and oranges;” one cannot learn anything about underlying causal processes by comparing their histories. The underlying factors of interest mean different things in different contexts (conceptual stretching) or the X/Y relationship of interest is different in different contexts (unit heterogeneity).

Case study researchers are often suspicious of large-sample research, which, they suspect, contains heterogeneous cases whose differences cannot easily be modeled. “Variable-oriented” research is said to involve unrealistic “homogenizing assumptions.” 37 In the field of international relations, for example, it is common to classify cases according to whether they are deterrence failures or deterrence successes. However, Alexander George and Richard Smoke point out that “the separation of the dependent variable into only two subclasses, deterrence success and deterrence failure,” neglects the great variety of ways in which deterrence can fail. Deterrence, in their view, has many independent causal paths (causal equifinality), and these paths may be obscured when a study lumps heterogeneous cases into a common sample. 38

Another example, drawn from clinical work in psychology, concerns heterogeneity among a sample of individuals. Michel Hersen and David Barlow explain:

Descriptions of results from 50 cases provide a more convincing demonstration of the effectiveness of a given technique than separate descriptions of 50 individual cases. The major difficulty with this approach, however, is that the category in which these clients are classified most always becomes unmanageably heterogeneous. “Neurotics,” [for example], …may have less in common than any group of people one would choose randomly. When cases are described individually, however, a clinician stands a better chance of gleaning some important information, since specific problems and specific procedures are usually described in more detail. When one lumps cases together in broadly defined categories, individual case descriptions are lost and the ensuing report of percentage success becomes meaningless. 39

Under circumstances of extreme case heterogeneity, the researcher may decide that she is better off focusing on a single case or a small number of relatively homogeneous cases. Within-case evidence, or cross-case evidence drawn from a handful of most-similar cases, may be more useful than cross-case evidence, even though the ultimate interest of the investigator is in a broader population of cases. (Suppose one has a population of very heterogeneous cases, one or two of which undergo quasi-experimental transformations. Probably, one gains greater insight into causal patterns throughout the population by examining these cases in detail than by undertaking some large-N cross-case analysis.) By the same token, if the cases available for study are relatively homogeneous, then the methodological argument for cross-case analysis is correspondingly strong. The inclusion of additional cases is unlikely to compromise the results of the investigation because these additional cases are sufficiently similar to provide useful information.

The issue of population heterogeneity/homogeneity may be understood, therefore, as a tradeoff between N (observations) and K (variables). If, in the quest to explain a particular phenomenon, each potential case offers only one observation and also requires one control variable (to neutralize heterogeneities in the resulting sample), then one loses degrees of freedom with each additional case. There is no point in using cross-case analysis or in extending a two-case study to further cases. If, on the other hand, each additional case is relatively cheap—if no control variables are needed or if the additional case offers more than one useful observation (through time)—then a cross-case research design may be warranted. 40 To put the matter more simply, when adjacent cases are unit homogeneous the addition of more cases is easy, for there is no (or very little) heterogeneity to model. When adjacent cases are heterogeneous additional cases are expensive, for every added heterogeneous element must be correctly modeled, and each modeling adjustment requires a separate (and probably unverifiable) assumption. The more background assumptions are required in order to make a causal inference, the more tenuous that inference is; it is not simply a question of attaining statistical significance. The ceteris paribus assumption at the core of all causal analysis is brought into question. In any case, the argument between case study and cross-case research designs is not about causal complexity per se (in the sense in which this concept is usually employed), but rather about the tradeoff between N and K in a particular empirical realm, and about the ability to model case heterogeneity through statistical legerdemain. 41

Before concluding this discussion it is important to point out that researchers’ judgements about case comparability are not, strictly speaking, matters that can be empirically verified. To be sure, one can look—and ought to look—for empirical patterns among potential cases. If those patterns are strong then the assumption of case comparability seems reasonably secure, and if they are not then there are grounds for doubt. However, debates about case comparability usually concern borderline instances. Consider that many phenomena of interest to social scientists are not rigidly bounded. If one is studying democracies there is always the question of how to define a democracy, and therefore of determining how high or low the threshold for inclusion in the sample should be. Researchers have different ideas about this, and these ideas can hardly be tested in a rigorous fashion. Similarly, there are longstanding disputes about whether it makes sense to lump poor and rich societies together in a single sample, or whether these constitute distinct populations. Again, the borderline between poor and rich (or “developed” and “undeveloped”) is blurry, and the notion of hiving off one from the other for separate analysis questionable, and unresolvable on purely empirical grounds. There is no safe (or “conservative”) way to proceed. A final sticking point concerns the cultural/historical component of social phenomena. Many case study researchers feel that to compare societies with vastly different cultures and historical trajectories is meaningless. Yet, many cross-case researchers feel that to restrict one’s analytic focus to a single cultural or geographic region is highly arbitrary, and equally meaningless. In these situations, it is evidently the choice of the researcher how to understand case homogeneity/heterogeneity across the potential populations of an inference. Where do like cases end and unlike cases begin?

Because this issue is not, strictly speaking, empirical it may be referred to as an ontological element of research design. An ontology is a vision of the world as it really is, a more or less coherent set of assumptions about how the world works, a research Weltanschauung analogous to a Kuhnian paradigm. 42 While it seems odd to bring ontological issues into a discussion of social science methodology it may be granted that social science research is not a purely empirical endeavor. What one finds is contingent upon what one looks for, and what one looks for is to some extent contingent upon what one expects to find. Stereotypically, case study researchers tend to have a “lumpy” vision of the world; they see countries, communities, and persons as highly individualized phenomena. Cross-case researchers, by contrast, have a less differentiated vision of the world; they are more likely to believe that things are pretty much the same everywhere, at least as respects basic causal processes. These basic assumptions, or ontologies, drive many of the choices made by researchers when scoping out appropriate ground for research.

8 Causal Strength: Strong versus Weak

Regardless of whether the population is homogeneous or heterogeneous, causal relationships are easier to study if the causal effect is strong, rather than weak. Causal “strength,” as I use the term here, refers to the magnitude and consistency of X’s effect on Y across a population of cases. (It invokes both the shape of the evidence at hand and whatever priors might be relevant to an interpretation of that evidence.) Where X has a strong effect on Y it will be relatively easy to study this relationship. Weak relationships, by contrast, are often difficult to discern. This much is commonsensical, and applies to all research designs.

For our purposes, what is significant is that weak causal relationships are particularly opaque when encountered in a case study format. Thus, there is a methodological affinity between weak causal relationships and large-N cross-case analysis, and between strong causal relationships and case study analysis.

This point is clearest at the extremes. The strongest species of causal relationships may be referred to as deterministic , where X is assumed to be necessary and/or sufficient for Y’s occurrence. A necessary and sufficient cause accounts for all of the variation on Y. A sufficient cause accounts for all of the variation in certain instances of Y. A necessary cause accounts, by itself, for the absence of Y. In all three situations, the relationship is usually assumed to be perfectly consistent, i.e. invariant. There are no exceptions.

It should be clear why case study research designs have an easier time addressing causes of this type. Consider that a deterministic causal proposition can be dis proved with a single case. 43 For example, the reigning theory of political stability once stipulated that only in countries that were relatively homogeneous, or where existing heterogeneity was mitigated by cross-cutting cleavages, would social peace endure. 44 Arend Lijphart’s case study of the Netherlands, a country with reinforcing social cleavages and very little social conflict, disproved this deterministic theory on the basis of a single case. 45 (One may dispute whether the original theory is correctly understood as deterministic. However, if it is , then it has been decisively refuted by a single case study.) Proving an invariant causal argument generally requires more cases. However, it is not nearly as complicated as proving a probabilistic argument for the simple reason that one assumes invariant relationships; consequently, the single case under study carries more weight.

Magnitude and consistency—the two components of causal strength—are usually matters of degree. It follows that the more tenuous the connection between X and Y, the more difficult it will be to address in a case study format. This is because the causal mechanisms connecting X with Y are less likely to be detectable in a single case when the total impact is slight or highly irregular. It is no surprise, therefore, that the case study research design has, from the very beginning, been associated with causal arguments that are deterministic, while cross-case research has been associated with causal arguments that are assumed to be minimal in strength and “probabilistic” in consistency. 46 (Strictly speaking, causal magnitude and consistency are independent features of a causal relationship. However, because they tend to covary, and because we tend to conceptualize them in tandem, I treat them as components of a single dimension.)

Now, let us now consider an example drawn from the other extreme. There is generally assumed to be a weak relationship between regime type and economic performance. Democracy, if it has any effect on economic growth at all, probably has only a slight effect over the near-to-medium term, and this effect is probably characterized by many exceptions (cases that do not fit the general pattern). This is because many things other than democracy affect a country’s growth performance and because there may be a significant stochastic component in economic growth (factors that cannot be modeled in a general way). Because of the diffuse nature of this relationship it will probably be difficult to gain insight by looking at a single case. Weak relationships are difficult to observe in one instance. Note that even if there seems to be a strong relationship between democracy and economic growth in a given country it may be questioned whether this case is actually typical of the larger population of interest, given that we have already stipulated that the typical magnitude of this relationship is diminutive and irregular. Of course, the weakness of democracy’s presumed relationship to growth is also a handicap in cross-case analysis. A good deal of criticism has been directed toward studies of this type, where findings are rarely robust. 47 Even so, it seems clear that if there is a relationship between democracy and growth it is more likely to be perceptible in a large cross-case setting. The positive hypothesis, as well as the null hypothesis, is better approached in a sample rather than in a case.

9 Useful Variation: Rare versus Common

When analyzing causal relationships we must be concerned not only with the strength of an X/Y relationship but also with the distribution of evidence across available cases. Specifically, we must be concerned with the distribution of useful variation —understood as variation (temporal or spatial) on relevant parameters that might yield clues about a causal relationship. It follows that where useful variation is rare—i.e. limited to a few cases—the case study format recommends itself. Where, on the other hand, useful variation is common, a cross-case method of analysis may be more defensible.

Consider a phenomenon like social revolution, an outcome that occurs very rarely. The empirical distribution on this variable, if we count each country-year as an observation, consists of thousands of non-revolutions (0) and just a few revolutions (1). Intuitively, it seems clear that the few “revolutionary” cases are of great interest. We need to know as much as possible about them, for they exemplify all the variation that we have at our disposal. In this circumstance, a case study mode of analysis is difficult to avoid, though it might be combined with a large-N cross-case analysis. As it happens, many outcomes of interest to social scientists are quite rare, so the issue is by no means trivial. 48

By way of contrast, consider a phenomenon like turnover, understood as a situation where a ruling party or coalition is voted out of office. Turnover occurs within most democratic countries on a regular basis, so the distribution of observations on this variable (incumbency/turnover) is relatively even across the universe of country-years. There are lots of instances of both outcomes. Under these circumstances a cross-case research design seems plausible, for the variation across cases is regularly distributed.

Another sort of variation concerns that which might occur within a given case. Suppose that only one or two cases within a large population exhibit quasi-experimental qualities: the factor of special interest varies, and there is no corresponding change in other factors that might affect the outcome. Clearly, we are likely to learn a great deal from studying this particular case—perhaps a lot more than we might learn from studying hundreds of additional cases that deviate from the experimental ideal. But again, if many cases have this experimental quality, there is little point in restricting ourselves to a single example; a cross-case research design may be justified.

A final sort of variation concerns the characteristics exhibited by a case relative to a particular theory that is under investigation. Suppose that a case provides a “crucial” test for a theory: it fits that theory’s predictions so perfectly and so precisely that no other explanation could plausibly account for the performance of the case. If no other crucial cases present themselves, then an intensive study of this particular case is de rigueur. Of course, if many such cases lie within the population then it may be possible to study them all at once (with some sort of numeric reduction of the relevant parameters).

The general point here is that the distribution of useful variation across a population of cases matters a great deal in the choice between case study and cross-case research designs.

10 Data Availability: Concentrated versus Dispersed

I have left the most prosaic factor for last. Sometimes, one’s choice of research design is driven by the quality and quantity of information that is currently available, or could be easily gathered, on a given question. This is a practical matter, and is distinct from the actual (ontological) shape of the world. It concerns, rather, what we know about the former at a given point in time. 49 The question of evidence may be posed as follows: How much do we know about the cases at hand that might be relevant to the causal question of interest, and how precise, certain, and case comparable is that data? An evidence-rich environment is one where all relevant factors are measurable, where these measurements are relatively precise, where they are rendered in comparable terms across cases, and where one can be relatively confident that the information is, indeed, accurate. An evidence-poor environment is the opposite.

The question of available evidence impinges upon choices in research design when one considers its distribution across a population of cases. If relevant information is concentrated in a single case, or if it is contained in incommensurable formats across a population of cases, then a case study mode of analysis is almost unavoidable. If, on the other hand, it is evenly distributed across the population—i.e. we are equally well informed about all cases—and is case comparable, then there is little to recommend a narrow focus. (I employ data, evidence, and information as synonyms in this section.)

Consider the simplest sort of example, where information is truly limited to one or a few cases. Accurate historical data on infant mortality and other indices of human development are currently available for only a handful of countries (these include Chile, Egypt, India, Jamaica, Mauritius, Sri Lanka, the United States, and several European countries). 50 This data problem is not likely to be rectified in future years, as it is exceedingly difficult to measure infant mortality except by public or private records. Consequently, anyone studying this general subject is likely to rely heavily on these cases, where in-depth analysis is possible and profitable. Indeed, it is not clear whether any large-N cross-case analysis is possible prior to the twentieth century. Here, a case study format is virtually prescribed, and a cross-case format proscribed.

Other problems of evidence are more subtle. Let us dwell for the moment on the question of data comparability. In their study of social security spending, Mulligan, Gil, and Sala-i-Martin note that

although our spending and design numbers are of good quality, there are some missing observations and, even with all the observations, it is difficult to reduce the variety of elderly subsidies to one or two numbers. For this reason, case studies are an important part of our analysis, since those studies do not require numbers that are comparable across a large number of countries. Our case study analysis utilizes data from a variety of country-specific sources, so we do not have to reduce “social security” or “democracy” to one single number. 51

Here, the incommensurability of the evidence militates towards a case study format. In the event that the authors (or subsequent analysts) discover a coding system that provides reasonably valid cross-case measures of social security, democracy, and other relevant concepts then our state of knowledge about the subject is changed, and a cross-case research design is rendered more plausible.

Importantly, the state of evidence on a topic is never entirely fixed. Investigators may gather additional data, recode existing data, or discover new repositories of data. Thus, when discussing the question of evidence one must consider the quality and quantity of evidence that could be gathered on a given question, given sufficient time and resources. Here it is appropriate to observe that collecting new data, and correcting existing data, is usually easier in a case study format than in a large-N cross-case format. It will be difficult to rectify data problems if one’s cases number in the hundreds or thousands. There are simply too many data points to allow for this.

One might consider this issue in the context of recent work on democracy. There is general skepticism among scholars with respect to the viability of extant global indicators intended to capture this complex concept (e.g. by Freedom House and by the Polity IV data project). 52 Measurement error, aggregation problems, and questions of conceptual validity are rampant. When dealing with a single country or a single continent it is possible to overcome some of these faults by manually recoding the countries of interest. 53 The case study format often gives the researcher an opportunity to fact-check, to consult multiple sources, to go back to primary materials, and to overcome whatever biases may affect the secondary literature. Needless to say, this is not a feasible approach for an individual investigator if one’s project encompasses every country in the world. The best one can usually manage, under the circumstances, is some form of convergent validation (by which different indices of the same concept are compared) or small adjustments in the coding intended to correct for aggregation problems or measurement error. 54

For the same reason, the collection of original data is typically more difficult in cross-case analysis than in case study analysis, involving greater expense, greater difficulties in identifying and coding cases, learning foreign languages, traveling, and so forth. Whatever can be done for a set of cases can usually be done more easily for a single case.

It should be kept in mind that many of the countries of concern to anthropologists, economists, historians, political scientists, and sociologists are still terra incognita. Outside the OECD, and with the exception of a few large countries that have received careful attention from scholars (e.g. India, Brazil, China), most countries of the world are not well covered by the social science literature. Any statement that one might wish to make about, say, Botswana, will be difficult to verify if one has recourse only to secondary materials. And these—very limited—secondary sources are not necessarily of the most reliable sort. Thus, if one wishes to say something about political patterns obtaining in roughly 90 percent of the world’s countries and if one wishes to go beyond matters that can be captured in standard statistics collected by the World Bank and the IMF and other agencies (and these can also be very sketchy when lesser-studied countries are concerned) one is more or less obliged to conduct a case study. Of course, one could, in principle, gather similar information across all relevant cases. However, such an enterprise faces formidable logistical difficulties. Thus, for practical reasons, case studies are sometimes the most defensible alternative when the researcher is faced with an information-poor environment.

However, this point is easily turned on its head. Datasets are now available to study many problems of concern to the social sciences. Thus, it may not be necessary to collect original information for one’s book, article, or dissertation. Sometimes in-depth single-case analysis is more time consuming than cross-case analysis. If so, there is no informational advantage to a case study format. Indeed, it may be easier to utilize existing information for a cross-case analysis, particularly when a case study format imposes hurdles of its own—e.g. travel to distant climes, risk of personal injury, expense, and so forth. It is interesting to note that some observers consider case studies to be “relatively more expensive in time and resources.” 55

Whatever the specific logistical hurdles, it is a general truth that the shape of the evidence—that which is currently available and that which might feasibly be collected by an author—often has a strong influence on an investigator’s choice of research designs. Where the evidence for particular cases is richer and more accurate there is a strong prima facie argument for a case study format focused on those cases. Where, by contrast, the relevant evidence is equally good for all potential cases, and is comparable across those cases, there is no reason to shy away from cross-case analysis. Indeed, there may be little to gain from case study formats.

11 Conclusions

At the outset, I took note of the severe disjuncture that has opened up between an often-maligned methodology and a heavily practiced method. The case study is disrespected but nonetheless regularly employed. Indeed, it remains the workhorse of most disciplines and subfields in the social sciences. How, then, can one make sense of this schizophrenia between methodological theory and praxis?

The torment of the case study begins with its definitional penumbra. Frequently, this key term is conflated with a set of disparate methodological traits that are not definitionally entailed. My first objective, therefore, was to craft a narrower and more useful concept for purposes of methodological discussion. The case study, I argued, is best defined as an intensive study of a single case with an aim to generalize across a larger set of cases. It follows from this definition that case studies may be small-or large-N, qualitative or quantitative, experimental or observational, synchronic or diachronic. It also follows that the case study research design comports with any macrotheoretical framework or paradigm—e.g. behavioralism, rational choice, institutionalism, or interpretivism. It is not epistemologically distinct. What differentiates the case study from the cross-case study is simply its way of defining observations, not its analysis of those observations or its method of modeling causal relations. The case study research design constructs its observations from a single case or a small number of cases, while cross-case research designs construct observations across multiple cases. Cross-case and case study research operate, for the most part, at different levels of analysis.

The travails of the case study are not simply definitional. They are also rooted in an insufficient appreciation of the methodological tradeoffs that this method calls forth. At least eight characteristic strengths and weaknesses must be considered. Ceteris paribus, case studies are more useful when the strategy of research is exploratory rather than confirmatory/disconfirmatory, when internal validity is given preference over external validity, when insight into causal mechanisms is prioritized over insight into causal effects, when propositional depth is prized over breadth, when the population of interest is heterogeneous rather than homogeneous, when causal relationships are strong rather than weak, when useful information about key parameters is available only for a few cases, and when the available data are concentrated rather than dispersed.

Although I do not have the space to discuss other issues in this venue, it is worth mentioning that other considerations may also come into play in a researcher’s choice between a case study and cross-case study research format. However, these additional issues—e.g. causal complexity and the state of research on a topic—do not appear to have clear methodological affinities. They may augur one way, or the other.

My objective throughout this chapter is to restore a greater sense of meaning, purpose, and integrity to the case study method. It is hoped that by offering a narrower and more carefully bounded definition of this method the case study may be rescued from some of its most persistent ambiguities. And it is hoped that the characteristic strengths of this method, as well as its limitations, will be more apparent to producers and consumers of case study research. The case study is a useful tool for some research objectives, but not all.

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Acemoglu, Johnson, and Robinson (2003) , Chernoff and Warner (2002) , Rodrik (2003) . See also studies focused on particular firms or regions, e.g. Coase ( 1959 ; 2000 ).

For general discussion of the following points see Achen (1986) , Freedman (1991) , Kittel ( 1999 , 2005 ), Kittel and Winner (2005) , Manski (1993) , Winship and Morgan (1999) , Winship and Sobel (2004) .

Achen and Snidal ( 1989 , 160). See also Geddes ( 1990 ; 2003 ), Goldthorpe (1997) , King, Keohane, and Verba (1994) , Lieberson ( 1985 , 107–15; 1992 ; 1994 ), Lijphart ( 1971 , 683–4), Odell (2004) , Sekhon (2004) , Smelser ( 1973 , 45, 57). It should be noted that these writers, while critical of the case study format, are not necessarily opposed to case studies per se (that is to say, they should not be classified as opponents of the case study).

My intention is to include only those attributes commonly associated with the case study method that are always implied by our use of the term, excluding those attributes that are sometimes violated by standard usage. Thus, I chose not to include “ethnography” as a defining feature of the case study, since many case studies (so called) are not ethnographic. For further discussion of minimal definitions see Gerring (2001 , ch. 4 ), Gerring and Barresi (2003) , Sartori (1976) .

These additional attributes might also be understood as comprising an ideal-type (“maximal”) definition of the topic ( Gerring 2001 , ch. 4 ; Gerring and Barresi 2003 ).

Popper (1969) .

Karl Popper (quoted in King, Keohane, and Verba 1994 , 14) writes: “there is no such thing as a logical method of having new ideas…Discovery contains ‘an irrational element,’ or a ‘creative intuition.”’ One recent collection of essays and interviews takes new ideas as its special focus ( Munck and Snyder 2007 ), though it may be doubted whether there are generalizable results.

Gerring (2001 , ch. 10 ). The tradeoff between these two styles of research is implicit in Achen and Snidal (1989) , who criticize the case study for its deficits in the latter genre but also acknowledge the benefits of the case study along the former dimension (1989, 167–8). Reichenbach also distinguished between a “context of discovery,” and a “context of justification.” Likewise, Peirce’s concept of abduction recognizes the importance of a generative component in science.

Bonoma ( 1985 , 199). Some of the following examples are discussed in Patton (2002 , 245).

North and Weingast (1989) ; North and Thomas (1973) .

Vandenbroucke ( 2001 , 331).

For discussion of this trade-off in the context of economic growth theory see Temple ( 1999 , 120).

Geddes (2003) , King, Keohane, and Verba (1994) , Popper ( 1934 /1968).

Ragin (1992) .

Eckstein (1975) , Ragin ( 1992 ; 1997 ), Rueschemeyer and Stephens (1997) .

Eckstein (1975) .

Campbell and Stanley ( 1963 , 3).

Lane (1962) .

Lynd and Lynd (1929/1956) .

Note that the intensive study of a single unit may be a perfectly appropriate way to estimate causal effects within that unit . Thus, if one is interested in the relationship between welfare benefits and work effort in the United States one might obtain a more accurate assessment by examining data drawn from the USA alone, rather than crossnationally. However, since the resulting generalization does not extend beyond the unit in question it is not a case study in the usual sense.

Achen (2002) , Dessler (1991) , Elster (1998) , George and Bennett (2005) , Gerring (2005) , Hedstrom and Swedberg (1998) , Mahoney (2001) , Tilly (2001) .

In a discussion of instrumental variables in two-stage least-squares analysis, Angrist and Krueger ( 2001 : 8) note that “good instruments often come from detailed knowledge of the economic mechanism, institutions determining the regressor of interest.”

Goldstone et al. (2000) .

This has something to do with the existence of process-tracing evidence, a matter discussed below. But it is not necessarily predicated on this sort of evidence. Sensitive time-series data, another specialty of the case study, is also relevant to the question of causal mechanisms.

Glaser and Strauss ( 1967 , 40).

Chong ( 1993 , 868). For other examples of in-depth interviewing see Hochschild (1981) , Lane (1962) .

Rueschemeyer and Stephens ( 1997 , 62).

Other good examples of within-case research that shed light on a broader theory can be found in Martin (1992) ; Martin and Swank (2004) ; Thies (2001) ; Young (1999) .

Cameron (1978) .

Alesina, Glaeser, and Sacerdote (2001) .

For additional examples of this nature, see Feng (2003) ; Papyrakis and Gerlagh (2003) ; Ross (2001) .

Eckstein ( 1975 , 122).

I am using the term “thick” in a somewhat different way than in Geertz (1973) .

See Ragin ( 2000 , 22).

Ragin (1987 , ch. 2 ). Herbert Blumer’s (1969 , ch. 7 ) complaints, however, are more far-reaching.

Orum, Feagin, and Sjoberg ( 1991 , 7).

Ragin ( 2000 , 35). See also Abbott (1990) ; Bendix (1963) ; Meehl (1954) ; Przeworski and Teune ( 1970 , 8–9); Ragin ( 1987 ; 2004 , 124); Znaniecki (1934 , 250–1).

George and Smoke (1974 , 514).

Hersen and Barlow (1976 , 11).

Shalev (1998) .

To be sure, if adjacent cases are identical , the phenomenon of interest is invariant then the researcher gains nothing at all by studying more examples of a phenomenon, for the results obtained with the first case will simply be replicated. However, virtually all phenomena of interest to social scientists have some degree of heterogeneity (cases are not identical), some stochastic element. Thus, the theoretical possibility of identical, invariant cases is rarely met in practice.

Gutting (1980) ; Hall (2003) ; Kuhn ( 1962 /1970); Wolin (1968) .

Dion (1998) .

Almond (1956) ; Bentley ( 1908 /1967); Lipset ( 1960 /1963); Truman (1951) .

Lijphart (1968) ; see also Lijphart (1969) . For additional examples of case studies disconfirming general propositions of a deterministic nature see Allen (1965) ; Lipset, Trow, and Coleman (1956) ; Njolstad (1990) ; discussion in Rogowski (1995) .

Znaniecki (1934) . See also discussion in Robinson (1951) .

Kittel ( 1999 ; 2005 ); Kittel and Winner (2005) ; Levine and Renelt (1992) ; Temple (1999) .

Consider the following topics and their—extremely rare—instances of variation: early industrialization (England, the Netherlands), fascism (Germany, Italy), the use of nuclear weapons (United States), world war (WWI, WWII), single non-transferable vote electoral systems (Jordan, Taiwan, Vanuatu, pre-reform Japan), electoral system reforms within established democracies (France, Italy, Japan, New Zealand, Thailand). The problem of “rareness” is less common where parameters are scalar, rather than dichotomous. But there are still plenty of examples of phenomena whose distributions are skewed by a few outliers, e.g. population (China, India), personal wealth (Bill Gates, Warren Buffett), ethnic heterogeneity (Papua New Guinea).

Of course, what we know about the potential cases is not independent of the underlying reality; it is, nonetheless, not entirely dependent on that reality.

Gerring (2007 b ) .

Mulligan, Gil, and Sala-i-Martin (2002 , 13).

Bollen (1993) ; Bowman, Lehoucq, and Mahoney (2005) ; Munck and Verkuilen (2002) ; Treier and Jackman (2005) .

Bowman, Lehoucq, and Mahoney (2005) .

Bollen (1993) ; Treier and Jackman (2005) .

Stoecker ( 1991 , 91).

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Designing and Conducting Case Studies

This guide examines case studies, a form of qualitative descriptive research that is used to look at individuals, a small group of participants, or a group as a whole. Researchers collect data about participants using participant and direct observations, interviews, protocols, tests, examinations of records, and collections of writing samples. Starting with a definition of the case study, the guide moves to a brief history of this research method. Using several well documented case studies, the guide then looks at applications and methods including data collection and analysis. A discussion of ways to handle validity, reliability, and generalizability follows, with special attention to case studies as they are applied to composition studies. Finally, this guide examines the strengths and weaknesses of case studies.

Definition and Overview

Case study refers to the collection and presentation of detailed information about a particular participant or small group, frequently including the accounts of subjects themselves. A form of qualitative descriptive research, the case study looks intensely at an individual or small participant pool, drawing conclusions only about that participant or group and only in that specific context. Researchers do not focus on the discovery of a universal, generalizable truth, nor do they typically look for cause-effect relationships; instead, emphasis is placed on exploration and description.

Case studies typically examine the interplay of all variables in order to provide as complete an understanding of an event or situation as possible. This type of comprehensive understanding is arrived at through a process known as thick description, which involves an in-depth description of the entity being evaluated, the circumstances under which it is used, the characteristics of the people involved in it, and the nature of the community in which it is located. Thick description also involves interpreting the meaning of demographic and descriptive data such as cultural norms and mores, community values, ingrained attitudes, and motives.

Unlike quantitative methods of research, like the survey, which focus on the questions of who, what, where, how much, and how many, and archival analysis, which often situates the participant in some form of historical context, case studies are the preferred strategy when how or why questions are asked. Likewise, they are the preferred method when the researcher has little control over the events, and when there is a contemporary focus within a real life context. In addition, unlike more specifically directed experiments, case studies require a problem that seeks a holistic understanding of the event or situation in question using inductive logic--reasoning from specific to more general terms.

In scholarly circles, case studies are frequently discussed within the context of qualitative research and naturalistic inquiry. Case studies are often referred to interchangeably with ethnography, field study, and participant observation. The underlying philosophical assumptions in the case are similar to these types of qualitative research because each takes place in a natural setting (such as a classroom, neighborhood, or private home), and strives for a more holistic interpretation of the event or situation under study.

Unlike more statistically-based studies which search for quantifiable data, the goal of a case study is to offer new variables and questions for further research. F.H. Giddings, a sociologist in the early part of the century, compares statistical methods to the case study on the basis that the former are concerned with the distribution of a particular trait, or a small number of traits, in a population, whereas the case study is concerned with the whole variety of traits to be found in a particular instance" (Hammersley 95).

Case studies are not a new form of research; naturalistic inquiry was the primary research tool until the development of the scientific method. The fields of sociology and anthropology are credited with the primary shaping of the concept as we know it today. However, case study research has drawn from a number of other areas as well: the clinical methods of doctors; the casework technique being developed by social workers; the methods of historians and anthropologists, plus the qualitative descriptions provided by quantitative researchers like LePlay; and, in the case of Robert Park, the techniques of newspaper reporters and novelists.

Park was an ex-newspaper reporter and editor who became very influential in developing sociological case studies at the University of Chicago in the 1920s. As a newspaper professional he coined the term "scientific" or "depth" reporting: the description of local events in a way that pointed to major social trends. Park viewed the sociologist as "merely a more accurate, responsible, and scientific reporter." Park stressed the variety and value of human experience. He believed that sociology sought to arrive at natural, but fluid, laws and generalizations in regard to human nature and society. These laws weren't static laws of the kind sought by many positivists and natural law theorists, but rather, they were laws of becoming--with a constant possibility of change. Park encouraged students to get out of the library, to quit looking at papers and books, and to view the constant experiment of human experience. He writes, "Go and sit in the lounges of the luxury hotels and on the doorsteps of the flophouses; sit on the Gold Coast settees and on the slum shakedowns; sit in the Orchestra Hall and in the Star and Garter Burlesque. In short, gentlemen [sic], go get the seats of your pants dirty in real research."

But over the years, case studies have drawn their share of criticism. In fact, the method had its detractors from the start. In the 1920s, the debate between pro-qualitative and pro-quantitative became quite heated. Case studies, when compared to statistics, were considered by many to be unscientific. From the 1930's on, the rise of positivism had a growing influence on quantitative methods in sociology. People wanted static, generalizable laws in science. The sociological positivists were looking for stable laws of social phenomena. They criticized case study research because it failed to provide evidence of inter subjective agreement. Also, they condemned it because of the few number of cases studied and that the under-standardized character of their descriptions made generalization impossible. By the 1950s, quantitative methods, in the form of survey research, had become the dominant sociological approach and case study had become a minority practice.

Educational Applications

The 1950's marked the dawning of a new era in case study research, namely that of the utilization of the case study as a teaching method. "Instituted at Harvard Business School in the 1950s as a primary method of teaching, cases have since been used in classrooms and lecture halls alike, either as part of a course of study or as the main focus of the course to which other teaching material is added" (Armisted 1984). The basic purpose of instituting the case method as a teaching strategy was "to transfer much of the responsibility for learning from the teacher on to the student, whose role, as a result, shifts away from passive absorption toward active construction" (Boehrer 1990). Through careful examination and discussion of various cases, "students learn to identify actual problems, to recognize key players and their agendas, and to become aware of those aspects of the situation that contribute to the problem" (Merseth 1991). In addition, students are encouraged to "generate their own analysis of the problems under consideration, to develop their own solutions, and to practically apply their own knowledge of theory to these problems" (Boyce 1993). Along the way, students also develop "the power to analyze and to master a tangled circumstance by identifying and delineating important factors; the ability to utilize ideas, to test them against facts, and to throw them into fresh combinations" (Merseth 1991).

In addition to the practical application and testing of scholarly knowledge, case discussions can also help students prepare for real-world problems, situations and crises by providing an approximation of various professional environments (i.e. classroom, board room, courtroom, or hospital). Thus, through the examination of specific cases, students are given the opportunity to work out their own professional issues through the trials, tribulations, experiences, and research findings of others. An obvious advantage to this mode of instruction is that it allows students the exposure to settings and contexts that they might not otherwise experience. For example, a student interested in studying the effects of poverty on minority secondary student's grade point averages and S.A.T. scores could access and analyze information from schools as geographically diverse as Los Angeles, New York City, Miami, and New Mexico without ever having to leave the classroom.

The case study method also incorporates the idea that students can learn from one another "by engaging with each other and with each other's ideas, by asserting something and then having it questioned, challenged and thrown back at them so that they can reflect on what they hear, and then refine what they say" (Boehrer 1990). In summary, students can direct their own learning by formulating questions and taking responsibility for the study.

Types and Design Concerns

Researchers use multiple methods and approaches to conduct case studies.

Types of Case Studies

Under the more generalized category of case study exist several subdivisions, each of which is custom selected for use depending upon the goals and/or objectives of the investigator. These types of case study include the following:

Illustrative Case Studies These are primarily descriptive studies. They typically utilize one or two instances of an event to show what a situation is like. Illustrative case studies serve primarily to make the unfamiliar familiar and to give readers a common language about the topic in question.

Exploratory (or pilot) Case Studies These are condensed case studies performed before implementing a large scale investigation. Their basic function is to help identify questions and select types of measurement prior to the main investigation. The primary pitfall of this type of study is that initial findings may seem convincing enough to be released prematurely as conclusions.

Cumulative Case Studies These serve to aggregate information from several sites collected at different times. The idea behind these studies is the collection of past studies will allow for greater generalization without additional cost or time being expended on new, possibly repetitive studies.

Critical Instance Case Studies These examine one or more sites for either the purpose of examining a situation of unique interest with little to no interest in generalizability, or to call into question or challenge a highly generalized or universal assertion. This method is useful for answering cause and effect questions.

Identifying a Theoretical Perspective

Much of the case study's design is inherently determined for researchers, depending on the field from which they are working. In composition studies, researchers are typically working from a qualitative, descriptive standpoint. In contrast, physicists will approach their research from a more quantitative perspective. Still, in designing the study, researchers need to make explicit the questions to be explored and the theoretical perspective from which they will approach the case. The three most commonly adopted theories are listed below:

Individual Theories These focus primarily on the individual development, cognitive behavior, personality, learning and disability, and interpersonal interactions of a particular subject.

Organizational Theories These focus on bureaucracies, institutions, organizational structure and functions, or excellence in organizational performance.

Social Theories These focus on urban development, group behavior, cultural institutions, or marketplace functions.

Two examples of case studies are used consistently throughout this chapter. The first, a study produced by Berkenkotter, Huckin, and Ackerman (1988), looks at a first year graduate student's initiation into an academic writing program. The study uses participant-observer and linguistic data collecting techniques to assess the student's knowledge of appropriate discourse conventions. Using the pseudonym Nate to refer to the subject, the study sought to illuminate the particular experience rather than to generalize about the experience of fledgling academic writers collectively.

For example, in Berkenkotter, Huckin, and Ackerman's (1988) study we are told that the researchers are interested in disciplinary communities. In the first paragraph, they ask what constitutes membership in a disciplinary community and how achieving membership might affect a writer's understanding and production of texts. In the third paragraph they state that researchers must negotiate their claims "within the context of his sub specialty's accepted knowledge and methodology." In the next paragraph they ask, "How is literacy acquired? What is the process through which novices gain community membership? And what factors either aid or hinder students learning the requisite linguistic behaviors?" This introductory section ends with a paragraph in which the study's authors claim that during the course of the study, the subject, Nate, successfully makes the transition from "skilled novice" to become an initiated member of the academic discourse community and that his texts exhibit linguistic changes which indicate this transition. In the next section the authors make explicit the sociolinguistic theoretical and methodological assumptions on which the study is based (1988). Thus the reader has a good understanding of the authors' theoretical background and purpose in conducting the study even before it is explicitly stated on the fourth page of the study. "Our purpose was to examine the effects of the educational context on one graduate student's production of texts as he wrote in different courses and for different faculty members over the academic year 1984-85." The goal of the study then, was to explore the idea that writers must be initiated into a writing community, and that this initiation will change the way one writes.

The second example is Janet Emig's (1971) study of the composing process of a group of twelfth graders. In this study, Emig seeks to answer the question of what happens to the self as a result educational stimuli in terms of academic writing. The case study used methods such as protocol analysis, tape-recorded interviews, and discourse analysis.

In the case of Janet Emig's (1971) study of the composing process of eight twelfth graders, four specific hypotheses were made:

• Twelfth grade writers engage in two modes of composing: reflexive and extensive.
• These differences can be ascertained and characterized through having the writers compose aloud their composition process.
• A set of implied stylistic principles governs the writing process.
• For twelfth grade writers, extensive writing occurs chiefly as a school-sponsored activity, or reflexive, as a self-sponsored activity.

In this study, the chief distinction is between the two dominant modes of composing among older, secondary school students. The distinctions are:

• The reflexive mode, which focuses on the writer's thoughts and feelings.
• The extensive mode, which focuses on conveying a message.

Emig also outlines the specific questions which guided the research in the opening pages of her Review of Literature , preceding the report.

Designing a Case Study

After considering the different sub categories of case study and identifying a theoretical perspective, researchers can begin to design their study. Research design is the string of logic that ultimately links the data to be collected and the conclusions to be drawn to the initial questions of the study. Typically, research designs deal with at least four problems:

• What questions to study
• What data are relevant
• What data to collect
• How to analyze that data

In other words, a research design is basically a blueprint for getting from the beginning to the end of a study. The beginning is an initial set of questions to be answered, and the end is some set of conclusions about those questions.

Because case studies are conducted on topics as diverse as Anglo-Saxon Literature (Thrane 1986) and AIDS prevention (Van Vugt 1994), it is virtually impossible to outline any strict or universal method or design for conducting the case study. However, Robert K. Yin (1993) does offer five basic components of a research design:

• A study's questions.
• A study's propositions (if any).
• A study's units of analysis.
• The logic that links the data to the propositions.
• The criteria for interpreting the findings.

In addition to these five basic components, Yin also stresses the importance of clearly articulating one's theoretical perspective, determining the goals of the study, selecting one's subject(s), selecting the appropriate method(s) of collecting data, and providing some considerations to the composition of the final report.

Conducting Case Studies

To obtain as complete a picture of the participant as possible, case study researchers can employ a variety of approaches and methods. These approaches, methods, and related issues are discussed in depth in this section.

Method: Single or Multi-modal?

To obtain as complete a picture of the participant as possible, case study researchers can employ a variety of methods. Some common methods include interviews , protocol analyses, field studies, and participant-observations. Emig (1971) chose to use several methods of data collection. Her sources included conversations with the students, protocol analysis, discrete observations of actual composition, writing samples from each student, and school records (Lauer and Asher 1988).

Berkenkotter, Huckin, and Ackerman (1988) collected data by observing classrooms, conducting faculty and student interviews, collecting self reports from the subject, and by looking at the subject's written work.

A study that was criticized for using a single method model was done by Flower and Hayes (1984). In this study that explores the ways in which writers use different forms of knowing to create space, the authors used only protocol analysis to gather data. The study came under heavy fire because of their decision to use only one method.

Participant Selection

Case studies can use one participant, or a small group of participants. However, it is important that the participant pool remain relatively small. The participants can represent a diverse cross section of society, but this isn't necessary.

For example, the Berkenkotter, Huckin, and Ackerman (1988) study looked at just one participant, Nate. By contrast, in Janet Emig's (1971) study of the composition process of twelfth graders, eight participants were selected representing a diverse cross section of the community, with volunteers from an all-white upper-middle-class suburban school, an all-black inner-city school, a racially mixed lower-middle-class school, an economically and racially mixed school, and a university school.

Often, a brief "case history" is done on the participants of the study in order to provide researchers with a clearer understanding of their participants, as well as some insight as to how their own personal histories might affect the outcome of the study. For instance, in Emig's study, the investigator had access to the school records of five of the participants, and to standardized test scores for the remaining three. Also made available to the researcher was the information that three of the eight students were selected as NCTE Achievement Award winners. These personal histories can be useful in later stages of the study when data are being analyzed and conclusions drawn.

Data Collection

There are six types of data collected in case studies:

• Archival records.
• Interviews.
• Direct observation.
• Participant observation.

In the field of composition research, these six sources might be:

• A writer's drafts.
• School records of student writers.
• Transcripts of interviews with a writer.
• Transcripts of conversations between writers (and protocols).
• Videotapes and notes from direct field observations.
• Hard copies of a writer's work on computer.

Depending on whether researchers have chosen to use a single or multi-modal approach for the case study, they may choose to collect data from one or any combination of these sources.

Protocols, that is, transcriptions of participants talking aloud about what they are doing as they do it, have been particularly common in composition case studies. For example, in Emig's (1971) study, the students were asked, in four different sessions, to give oral autobiographies of their writing experiences and to compose aloud three themes in the presence of a tape recorder and the investigator.

In some studies, only one method of data collection is conducted. For example, the Flower and Hayes (1981) report on the cognitive process theory of writing depends on protocol analysis alone. However, using multiple sources of evidence to increase the reliability and validity of the data can be advantageous.

Case studies are likely to be much more convincing and accurate if they are based on several different sources of information, following a corroborating mode. This conclusion is echoed among many composition researchers. For example, in her study of predrafting processes of high and low-apprehensive writers, Cynthia Selfe (1985) argues that because "methods of indirect observation provide only an incomplete reflection of the complex set of processes involved in composing, a combination of several such methods should be used to gather data in any one study." Thus, in this study, Selfe collected her data from protocols, observations of students role playing their writing processes, audio taped interviews with the students, and videotaped observations of the students in the process of composing.

It can be said then, that cross checking data from multiple sources can help provide a multidimensional profile of composing activities in a particular setting. Sharan Merriam (1985) suggests "checking, verifying, testing, probing, and confirming collected data as you go, arguing that this process will follow in a funnel-like design resulting in less data gathering in later phases of the study along with a congruent increase in analysis checking, verifying, and confirming."

It is important to note that in case studies, as in any qualitative descriptive research, while researchers begin their studies with one or several questions driving the inquiry (which influence the key factors the researcher will be looking for during data collection), a researcher may find new key factors emerging during data collection. These might be unexpected patterns or linguistic features which become evident only during the course of the research. While not bearing directly on the researcher's guiding questions, these variables may become the basis for new questions asked at the end of the report, thus linking to the possibility of further research.

Data Analysis

As the information is collected, researchers strive to make sense of their data. Generally, researchers interpret their data in one of two ways: holistically or through coding. Holistic analysis does not attempt to break the evidence into parts, but rather to draw conclusions based on the text as a whole. Flower and Hayes (1981), for example, make inferences from entire sections of their students' protocols, rather than searching through the transcripts to look for isolatable characteristics.

However, composition researchers commonly interpret their data by coding, that is by systematically searching data to identify and/or categorize specific observable actions or characteristics. These observable actions then become the key variables in the study. Sharan Merriam (1988) suggests seven analytic frameworks for the organization and presentation of data:

• The role of participants.
• The network analysis of formal and informal exchanges among groups.
• Historical.
• Thematical.
• Ritual and symbolism.
• Critical incidents that challenge or reinforce fundamental beliefs, practices, and values.

There are two purposes of these frameworks: to look for patterns among the data and to look for patterns that give meaning to the case study.

As stated above, while most researchers begin their case studies expecting to look for particular observable characteristics, it is not unusual for key variables to emerge during data collection. Typical variables coded in case studies of writers include pauses writers make in the production of a text, the use of specific linguistic units (such as nouns or verbs), and writing processes (planning, drafting, revising, and editing). In the Berkenkotter, Huckin, and Ackerman (1988) study, for example, researchers coded the participant's texts for use of connectives, discourse demonstratives, average sentence length, off-register words, use of the first person pronoun, and the ratio of definite articles to indefinite articles.

Since coding is inherently subjective, more than one coder is usually employed. In the Berkenkotter, Huckin, and Ackerman (1988) study, for example, three rhetoricians were employed to code the participant's texts for off-register phrases. The researchers established the agreement among the coders before concluding that the participant used fewer off-register words as the graduate program progressed.

Composing the Case Study Report

In the many forms it can take, "a case study is generically a story; it presents the concrete narrative detail of actual, or at least realistic events, it has a plot, exposition, characters, and sometimes even dialogue" (Boehrer 1990). Generally, case study reports are extensively descriptive, with "the most problematic issue often referred to as being the determination of the right combination of description and analysis" (1990). Typically, authors address each step of the research process, and attempt to give the reader as much context as possible for the decisions made in the research design and for the conclusions drawn.

This contextualization usually includes a detailed explanation of the researchers' theoretical positions, of how those theories drove the inquiry or led to the guiding research questions, of the participants' backgrounds, of the processes of data collection, of the training and limitations of the coders, along with a strong attempt to make connections between the data and the conclusions evident.

Although the Berkenkotter, Huckin, and Ackerman (1988) study does not, case study reports often include the reactions of the participants to the study or to the researchers' conclusions. Because case studies tend to be exploratory, most end with implications for further study. Here researchers may identify significant variables that emerged during the research and suggest studies related to these, or the authors may suggest further general questions that their case study generated.

For example, Emig's (1971) study concludes with a section dedicated solely to the topic of implications for further research, in which she suggests several means by which this particular study could have been improved, as well as questions and ideas raised by this study which other researchers might like to address, such as: is there a correlation between a certain personality and a certain composing process profile (e.g. is there a positive correlation between ego strength and persistence in revising)?

Also included in Emig's study is a section dedicated to implications for teaching, which outlines the pedagogical ramifications of the study's findings for teachers currently involved in high school writing programs.

Sharan Merriam (1985) also offers several suggestions for alternative presentations of data:

• Prepare specialized condensations for appropriate groups.
• Replace narrative sections with a series of answers to open-ended questions.
• Present "skimmer's" summaries at beginning of each section.
• Incorporate headlines that encapsulate information from text.
• Prepare analytic summaries with supporting data appendixes.
• Present data in colorful and/or unique graphic representations.

Issues of Validity and Reliability

Once key variables have been identified, they can be analyzed. Reliability becomes a key concern at this stage, and many case study researchers go to great lengths to ensure that their interpretations of the data will be both reliable and valid. Because issues of validity and reliability are an important part of any study in the social sciences, it is important to identify some ways of dealing with results.

Multi-modal case study researchers often balance the results of their coding with data from interviews or writer's reflections upon their own work. Consequently, the researchers' conclusions become highly contextualized. For example, in a case study which looked at the time spent in different stages of the writing process, Berkenkotter concluded that her participant, Donald Murray, spent more time planning his essays than in other writing stages. The report of this case study is followed by Murray's reply, wherein he agrees with some of Berkenkotter's conclusions and disagrees with others.

As is the case with other research methodologies, issues of external validity, construct validity, and reliability need to be carefully considered.

Commentary on Case Studies

Researchers often debate the relative merits of particular methods, among them case study. In this section, we comment on two key issues. To read the commentaries, choose any of the items below:

Strengths and Weaknesses of Case Studies

Most case study advocates point out that case studies produce much more detailed information than what is available through a statistical analysis. Advocates will also hold that while statistical methods might be able to deal with situations where behavior is homogeneous and routine, case studies are needed to deal with creativity, innovation, and context. Detractors argue that case studies are difficult to generalize because of inherent subjectivity and because they are based on qualitative subjective data, generalizable only to a particular context.

Flexibility

The case study approach is a comparatively flexible method of scientific research. Because its project designs seem to emphasize exploration rather than prescription or prediction, researchers are comparatively freer to discover and address issues as they arise in their experiments. In addition, the looser format of case studies allows researchers to begin with broad questions and narrow their focus as their experiment progresses rather than attempt to predict every possible outcome before the experiment is conducted.

Emphasis on Context

By seeking to understand as much as possible about a single subject or small group of subjects, case studies specialize in "deep data," or "thick description"--information based on particular contexts that can give research results a more human face. This emphasis can help bridge the gap between abstract research and concrete practice by allowing researchers to compare their firsthand observations with the quantitative results obtained through other methods of research.

Inherent Subjectivity

"The case study has long been stereotyped as the weak sibling among social science methods," and is often criticized as being too subjective and even pseudo-scientific. Likewise, "investigators who do case studies are often regarded as having deviated from their academic disciplines, and their investigations as having insufficient precision (that is, quantification), objectivity and rigor" (Yin 1989). Opponents cite opportunities for subjectivity in the implementation, presentation, and evaluation of case study research. The approach relies on personal interpretation of data and inferences. Results may not be generalizable, are difficult to test for validity, and rarely offer a problem-solving prescription. Simply put, relying on one or a few subjects as a basis for cognitive extrapolations runs the risk of inferring too much from what might be circumstance.

High Investment

Case studies can involve learning more about the subjects being tested than most researchers would care to know--their educational background, emotional background, perceptions of themselves and their surroundings, their likes, dislikes, and so on. Because of its emphasis on "deep data," the case study is out of reach for many large-scale research projects which look at a subject pool in the tens of thousands. A budget request of $10,000 to examine 200 subjects sounds more efficient than a similar request to examine four subjects.

Ethical Considerations

Researchers conducting case studies should consider certain ethical issues. For example, many educational case studies are often financed by people who have, either directly or indirectly, power over both those being studied and those conducting the investigation (1985). This conflict of interests can hinder the credibility of the study.

The personal integrity, sensitivity, and possible prejudices and/or biases of the investigators need to be taken into consideration as well. Personal biases can creep into how the research is conducted, alternative research methods used, and the preparation of surveys and questionnaires.

A common complaint in case study research is that investigators change direction during the course of the study unaware that their original research design was inadequate for the revised investigation. Thus, the researchers leave unknown gaps and biases in the study. To avoid this, researchers should report preliminary findings so that the likelihood of bias will be reduced.

Concerns about Reliability, Validity, and Generalizability

Merriam (1985) offers several suggestions for how case study researchers might actively combat the popular attacks on the validity, reliability, and generalizability of case studies:

• Prolong the Processes of Data Gathering on Site: This will help to insure the accuracy of the findings by providing the researcher with more concrete information upon which to formulate interpretations.
• Employ the Process of "Triangulation": Use a variety of data sources as opposed to relying solely upon one avenue of observation. One example of such a data check would be what McClintock, Brannon, and Maynard (1985) refer to as a "case cluster method," that is, when a single unit within a larger case is randomly sampled, and that data treated quantitatively." For instance, in Emig's (1971) study, the case cluster method was employed, singling out the productivity of a single student named Lynn. This cluster profile included an advanced case history of the subject, specific examination and analysis of individual compositions and protocols, and extensive interview sessions. The seven remaining students were then compared with the case of Lynn, to ascertain if there are any shared, or unique dimensions to the composing process engaged in by these eight students.
• Conduct Member Checks: Initiate and maintain an active corroboration on the interpretation of data between the researcher and those who provided the data. In other words, talk to your subjects.
• Collect Referential Materials: Complement the file of materials from the actual site with additional document support. For example, Emig (1971) supports her initial propositions with historical accounts by writers such as T.S. Eliot, James Joyce, and D.H. Lawrence. Emig also cites examples of theoretical research done with regards to the creative process, as well as examples of empirical research dealing with the writing of adolescents. Specific attention is then given to the four stages description of the composing process delineated by Helmoltz, Wallas, and Cowley, as it serves as the focal point in this study.
• Engage in Peer Consultation: Prior to composing the final draft of the report, researchers should consult with colleagues in order to establish validity through pooled judgment.

Although little can be done to combat challenges concerning the generalizability of case studies, "most writers suggest that qualitative research should be judged as credible and confirmable as opposed to valid and reliable" (Merriam 1985). Likewise, it has been argued that "rather than transplanting statistical, quantitative notions of generalizability and thus finding qualitative research inadequate, it makes more sense to develop an understanding of generalization that is congruent with the basic characteristics of qualitative inquiry" (1985). After all, criticizing the case study method for being ungeneralizable is comparable to criticizing a washing machine for not being able to tell the correct time. In other words, it is unjust to criticize a method for not being able to do something which it was never originally designed to do in the first place.

Annotated Bibliography

Armisted, C. (1984). How Useful are Case Studies. Training and Development Journal, 38 (2), 75-77.

This article looks at eight types of case studies, offers pros and cons of using case studies in the classroom, and gives suggestions for successfully writing and using case studies.

Bardovi-Harlig, K. (1997). Beyond Methods: Components of Second Language Teacher Education . New York: McGraw-Hill.

A compilation of various research essays which address issues of language teacher education. Essays included are: "Non-native reading research and theory" by Lee, "The case for Psycholinguistics" by VanPatten, and "Assessment and Second Language Teaching" by Gradman and Reed.

Bartlett, L. (1989). A Question of Good Judgment; Interpretation Theory and Qualitative Enquiry Address. 70th Annual Meeting of the American Educational Research Association. San Francisco.

Bartlett selected "quasi-historical" methodology, which focuses on the "truth" found in case records, as one that will provide "good judgments" in educational inquiry. He argues that although the method is not comprehensive, it can try to connect theory with practice.

Baydere, S. et. al. (1993). Multimedia conferencing as a tool for collaborative writing: a case study in Computer Supported Collaborative Writing. New York: Springer-Verlag.

The case study by Baydere et. al. is just one of the many essays in this book found in the series "Computer Supported Cooperative Work." Denley, Witefield and May explore similar issues in their essay, "A case study in task analysis for the design of a collaborative document production system."

Berkenkotter, C., Huckin, T., N., & Ackerman J. (1988). Conventions, Conversations, and the Writer: Case Study of a Student in a Rhetoric Ph.D. Program. Research in the Teaching of English, 22, 9-44.

The authors focused on how the writing of their subject, Nate or Ackerman, changed as he became more acquainted or familiar with his field's discourse community.

Berninger, V., W., and Gans, B., M. (1986). Language Profiles in Nonspeaking Individuals of Normal Intelligence with Severe Cerebral Palsy. Augmentative and Alternative Communication, 2, 45-50.

Argues that generalizations about language abilities in patients with severe cerebral palsy (CP) should be avoided. Standardized tests of different levels of processing oral language, of processing written language, and of producing written language were administered to 3 male participants (aged 9, 16, and 40 yrs).

Bockman, J., R., and Couture, B. (1984). The Case Method in Technical Communication: Theory and Models. Texas: Association of Teachers of Technical Writing.

Examines the study and teaching of technical writing, communication of technical information, and the case method in terms of those applications.

Boehrer, J. (1990). Teaching With Cases: Learning to Question. New Directions for Teaching and Learning, 42 41-57.

This article discusses the origins of the case method, looks at the question of what is a case, gives ideas about learning in case teaching, the purposes it can serve in the classroom, the ground rules for the case discussion, including the role of the question, and new directions for case teaching.

Bowman, W. R. (1993). Evaluating JTPA Programs for Economically Disadvantaged Adults: A Case Study of Utah and General Findings . Washington: National Commission for Employment Policy.

"To encourage state-level evaluations of JTPA, the Commission and the State of Utah co-sponsored this report on the effectiveness of JTPA Title II programs for adults in Utah. The technique used is non-experimental and the comparison group was selected from registrants with Utah's Employment Security. In a step-by-step approach, the report documents how non-experimental techniques can be applied and several specific technical issues can be addressed."

Boyce, A. (1993) The Case Study Approach for Pedagogists. Annual Meeting of the American Alliance for Health, Physical Education, Recreation and Dance. (Address). Washington DC.

This paper addresses how case studies 1) bridge the gap between teaching theory and application, 2) enable students to analyze problems and develop solutions for situations that will be encountered in the real world of teaching, and 3) helps students to evaluate the feasibility of alternatives and to understand the ramifications of a particular course of action.

Carson, J. (1993) The Case Study: Ideal Home of WAC Quantitative and Qualitative Data. Annual Meeting of the Conference on College Composition and Communication. (Address). San Diego.

"Increasingly, one of the most pressing questions for WAC advocates is how to keep [WAC] programs going in the face of numerous difficulties. Case histories offer the best chance for fashioning rhetorical arguments to keep WAC programs going because they offer the opportunity to provide a coherent narrative that contextualizes all documents and data, including what is generally considered scientific data. A case study of the WAC program, . . . at Robert Morris College in Pittsburgh demonstrates the advantages of this research method. Such studies are ideal homes for both naturalistic and positivistic data as well as both quantitative and qualitative information."

---. (1991). A Cognitive Process Theory of Writing. College Composition and Communication. 32. 365-87.

No abstract available.

Cromer, R. (1994) A Case Study of Dissociations Between Language and Cognition. Constraints on Language Acquisition: Studies of Atypical Children . Hillsdale: Lawrence Erlbaum Associates, 141-153.

Crossley, M. (1983) Case Study in Comparative and International Education: An Approach to Bridging the Theory-Practice Gap. Proceedings of the 11th Annual Conference of the Australian Comparative and International Education Society. Hamilton, NZ.

Case study research, as presented here, helps bridge the theory-practice gap in comparative and international research studies of education because it focuses on the practical, day-to-day context rather than on the national arena. The paper asserts that the case study method can be valuable at all levels of research, formation, and verification of theories in education.

Daillak, R., H., and Alkin, M., C. (1982). Qualitative Studies in Context: Reflections on the CSE Studies of Evaluation Use . California: EDRS

The report shows how the Center of the Study of Evaluation (CSE) applied qualitative techniques to a study of evaluation information use in local, Los Angeles schools. It critiques the effectiveness and the limitations of using case study, evaluation, field study, and user interview survey methodologies.

Davey, L. (1991). The Application of Case Study Evaluations. ERIC/TM Digest.

This article examines six types of case studies, the type of evaluation questions that can be answered, the functions served, some design features, and some pitfalls of the method.

Deutch, C. E. (1996). A course in research ethics for graduate students. College Teaching, 44, 2, 56-60.

This article describes a one-credit discussion course in research ethics for graduate students in biology. Case studies are focused on within the four parts of the course: 1) major issues, 2 )practical issues in scholarly work, 3) ownership of research results, and 4) training and personal decisions.

DeVoss, G. (1981). Ethics in Fieldwork Research. RIE 27p. (ERIC)

This article examines four of the ethical problems that can happen when conducting case study research: acquiring permission to do research, knowing when to stop digging, the pitfalls of doing collaborative research, and preserving the integrity of the participants.

Driscoll, A. (1985). Case Study of a Research Intervention: the University of Utah’s Collaborative Approach . San Francisco: Far West Library for Educational Research Development.

Paper presented at the annual meeting of the American Association of Colleges of Teacher Education, Denver, CO, March 1985. Offers information of in-service training, specifically case studies application.

Ellram, L. M. (1996). The Use of the Case Study Method in Logistics Research. Journal of Business Logistics, 17, 2, 93.

This article discusses the increased use of case study in business research, and the lack of understanding of when and how to use case study methodology in business.

Emig, J. (1971) The Composing Processes of Twelfth Graders . Urbana: NTCE.

This case study uses observation, tape recordings, writing samples, and school records to show that writing in reflexive and extensive situations caused different lengths of discourse and different clusterings of the components of the writing process.

Feagin, J. R. (1991). A Case For the Case Study . Chapel Hill: The University of North Carolina Press.

This book discusses the nature, characteristics, and basic methodological issues of the case study as a research method.

Feldman, H., Holland, A., & Keefe, K. (1989) Language Abilities after Left Hemisphere Brain Injury: A Case Study of Twins. Topics in Early Childhood Special Education, 9, 32-47.

"Describes the language abilities of 2 twin pairs in which 1 twin (the experimental) suffered brain injury to the left cerebral hemisphere around the time of birth and1 twin (the control) did not. One pair of twins was initially assessed at age 23 mo. and the other at about 30 mo.; they were subsequently evaluated in their homes 3 times at about 6-mo intervals."

Fidel, R. (1984). The Case Study Method: A Case Study. Library and Information Science Research, 6.

The article describes the use of case study methodology to systematically develop a model of online searching behavior in which study design is flexible, subject manner determines data gathering and analyses, and procedures adapt to the study's progressive change.

Flower, L., & Hayes, J. R. (1984). Images, Plans and Prose: The Representation of Meaning in Writing. Written Communication, 1, 120-160.

Explores the ways in which writers actually use different forms of knowing to create prose.

Frey, L. R. (1992). Interpreting Communication Research: A Case Study Approach Englewood Cliffs, N.J.: Prentice Hall.

The book discusses research methodologies in the Communication field. It focuses on how case studies bridge the gap between communication research, theory, and practice.

Gilbert, V. K. (1981). The Case Study as a Research Methodology: Difficulties and Advantages of Integrating the Positivistic, Phenomenological and Grounded Theory Approaches . The Annual Meeting of the Canadian Association for the Study of Educational Administration. (Address) Halifax, NS, Can.

This study on an innovative secondary school in England shows how a "low-profile" participant-observer case study was crucial to the initial observation, the testing of hypotheses, the interpretive approach, and the grounded theory.

Gilgun, J. F. (1994). A Case for Case Studies in Social Work Research. Social Work, 39, 4, 371-381.

This article defines case study research, presents guidelines for evaluation of case studies, and shows the relevance of case studies to social work research. It also looks at issues such as evaluation and interpretations of case studies.

Glennan, S. L., Sharp-Bittner, M. A. & Tullos, D. C. (1991). Augmentative and Alternative Communication Training with a Nonspeaking Adult: Lessons from MH. Augmentative and Alternative Communication, 7, 240-7.

"A response-guided case study documented changes in a nonspeaking 36-yr-old man's ability to communicate using 3 trained augmentative communication modes. . . . Data were collected in videotaped interaction sessions between the nonspeaking adult and a series of adult speaking."

Graves, D. (1981). An Examination of the Writing Processes of Seven Year Old Children. Research in the Teaching of English, 15, 113-134.

Hamel, J. (1993). Case Study Methods . Newbury Park: Sage. .

"In a most economical fashion, Hamel provides a practical guide for producing theoretically sharp and empirically sound sociological case studies. A central idea put forth by Hamel is that case studies must "locate the global in the local" thus making the careful selection of the research site the most critical decision in the analytic process."

Karthigesu, R. (1986, July). Television as a Tool for Nation-Building in the Third World: A Post-Colonial Pattern, Using Malaysia as a Case-Study. International Television Studies Conference. (Address). London, 10-12.

"The extent to which Television Malaysia, as a national mass media organization, has been able to play a role in nation building in the post-colonial period is . . . studied in two parts: how the choice of a model of nation building determines the character of the organization; and how the character of the organization influences the output of the organization."

Kenny, R. (1984). Making the Case for the Case Study. Journal of Curriculum Studies, 16, (1), 37-51.

The article looks at how and why the case study is justified as a viable and valuable approach to educational research and program evaluation.

Knirk, F. (1991). Case Materials: Research and Practice. Performance Improvement Quarterly, 4 (1 ), 73-81.

The article addresses the effectiveness of case studies, subject areas where case studies are commonly used, recent examples of their use, and case study design considerations.

Klos, D. (1976). Students as Case Writers. Teaching of Psychology, 3.2, 63-66.

This article reviews a course in which students gather data for an original case study of another person. The task requires the students to design the study, collect the data, write the narrative, and interpret the findings.

Leftwich, A. (1981). The Politics of Case Study: Problems of Innovation in University Education. Higher Education Review, 13.2, 38-64.

The article discusses the use of case studies as a teaching method. Emphasis is on the instructional materials, interdisciplinarity, and the complex relationships within the university that help or hinder the method.

Mabrito, M. (1991, Oct.). Electronic Mail as a Vehicle for Peer Response: Conversations of High and Low Apprehensive Writers. Written Communication, 509-32.

McCarthy, S., J. (1955). The Influence of Classroom Discourse on Student Texts: The Case of Ella . East Lansing: Institute for Research on Teaching.

A look at how students of color become marginalized within traditional classroom discourse. The essay follows the struggles of one black student: Ella.

Matsuhashi, A., ed. (1987). Writing in Real Time: Modeling Production Processes Norwood, NJ: Ablex Publishing Corporation.

Investigates how writers plan to produce discourse for different purposes to report, to generalize, and to persuade, as well as how writers plan for sentence level units of language. To learn about planning, an observational measure of pause time was used" (ERIC).

Merriam, S. B. (1985). The Case Study in Educational Research: A Review of Selected Literature. Journal of Educational Thought, 19.3, 204-17.

The article examines the characteristics of, philosophical assumptions underlying the case study, the mechanics of conducting a case study, and the concerns about the reliability, validity, and generalizability of the method.

---. (1988). Case Study Research in Education: A Qualitative Approach San Francisco: Jossey Bass.

Merry, S. E., & Milner, N. eds. (1993). The Possibility of Popular Justice: A Case Study of Community Mediation in the United States . Ann Arbor: U of Michigan.

". . . this volume presents a case study of one experiment in popular justice, the San Francisco Community Boards. This program has made an explicit claim to create an alternative justice, or new justice, in the midst of a society ordered by state law. The contributors to this volume explore the history and experience of the program and compare it to other versions of popular justice in the United States, Europe, and the Third World."

Merseth, K. K. (1991). The Case for Cases in Teacher Education. RIE. 42p. (ERIC).

This monograph argues that the case method of instruction offers unique potential for revitalizing the field of teacher education.

Michaels, S. (1987). Text and Context: A New Approach to the Study of Classroom Writing. Discourse Processes, 10, 321-346.

"This paper argues for and illustrates an approach to the study of writing that integrates ethnographic analysis of classroom interaction with linguistic analysis of written texts and teacher/student conversational exchanges. The approach is illustrated through a case study of writing in a single sixth grade classroom during a single writing assignment."

Milburn, G. (1995). Deciphering a Code or Unraveling a Riddle: A Case Study in the Application of a Humanistic Metaphor to the Reporting of Social Studies Teaching. Theory and Research in Education, 13.

This citation serves as an example of how case studies document learning procedures in a senior-level economics course.

Milley, J. E. (1979). An Investigation of Case Study as an Approach to Program Evaluation. 19th Annual Forum of the Association for Institutional Research. (Address). San Diego.

The case study method merged a narrative report focusing on the evaluator as participant-observer with document review, interview, content analysis, attitude questionnaire survey, and sociogram analysis. Milley argues that case study program evaluation has great potential for widespread use.

Minnis, J. R. (1985, Sept.). Ethnography, Case Study, Grounded Theory, and Distance Education Research. Distance Education, 6.2.

This article describes and defines the strengths and weaknesses of ethnography, case study, and grounded theory.

Nunan, D. (1992). Collaborative language learning and teaching . New York: Cambridge University Press.

Included in this series of essays is Peter Sturman’s "Team Teaching: a case study from Japan" and David Nunan’s own "Toward a collaborative approach to curriculum development: a case study."

Nystrand, M., ed. (1982). What Writers Know: The Language, Process, and Structure of Written Discourse . New York: Academic Press.

Owenby, P. H. (1992). Making Case Studies Come Alive. Training, 29, (1), 43-46. (ERIC)

This article provides tips for writing more effective case studies.

---. (1981). Pausing and Planning: The Tempo of Writer Discourse Production. Research in the Teaching of English, 15 (2),113-34.

Perl, S. (1979). The Composing Processes of Unskilled College Writers. Research in the Teaching of English, 13, 317-336.

"Summarizes a study of five unskilled college writers, focusing especially on one of the five, and discusses the findings in light of current pedagogical practice and research design."

Pilcher J. and A. Coffey. eds. (1996). Gender and Qualitative Research . Brookfield: Aldershot, Hants, England.

This book provides a series of essays which look at gender identity research, qualitative research and applications of case study to questions of gendered pedagogy.

Pirie, B. S. (1993). The Case of Morty: A Four Year Study. Gifted Education International, 9 (2), 105-109.

This case study describes a boy from kindergarten through third grade with above average intelligence but difficulty in learning to read, write, and spell.

Popkewitz, T. (1993). Changing Patterns of Power: Social Regulation and Teacher Education Reform. Albany: SUNY Press.

Popkewitz edits this series of essays that address case studies on educational change and the training of teachers. The essays vary in terms of discipline and scope. Also, several authors include case studies of educational practices in countries other than the United States.

---. (1984). The Predrafting Processes of Four High- and Four Low Apprehensive Writers. Research in the Teaching of English, 18, (1), 45-64.

Rasmussen, P. (1985, March) A Case Study on the Evaluation of Research at the Technical University of Denmark. International Journal of Institutional Management in Higher Education, 9 (1).

This is an example of a case study methodology used to evaluate the chemistry and chemical engineering departments at the University of Denmark.

Roth, K. J. (1986). Curriculum Materials, Teacher Talk, and Student Learning: Case Studies in Fifth-Grade Science Teaching . East Lansing: Institute for Research on Teaching.

Roth offers case studies on elementary teachers, elementary school teaching, science studies and teaching, and verbal learning.

Selfe, C. L. (1985). An Apprehensive Writer Composes. When a Writer Can't Write: Studies in Writer's Block and Other Composing-Process Problems . (pp. 83-95). Ed. Mike Rose. NMY: Guilford.

Smith-Lewis, M., R. and Ford, A. (1987). A User's Perspective on Augmentative Communication. Augmentative and Alternative Communication, 3, 12-7.

"During a series of in-depth interviews, a 25-yr-old woman with cerebral palsy who utilized augmentative communication reflected on the effectiveness of the devices designed for her during her school career."

St. Pierre, R., G. (1980, April). Follow Through: A Case Study in Metaevaluation Research . 64th Annual Meeting of the American Educational Research Association. (Address).

The three approaches to metaevaluation are evaluation of primary evaluations, integrative meta-analysis with combined primary evaluation results, and re-analysis of the raw data from a primary evaluation.

Stahler, T., M. (1996, Feb.) Early Field Experiences: A Model That Worked. ERIC.

"This case study of a field and theory class examines a model designed to provide meaningful field experiences for preservice teachers while remaining consistent with the instructor's beliefs about the role of teacher education in preparing teachers for the classroom."

Stake, R. E. (1995). The Art of Case Study Research. Thousand Oaks: Sage Publications.

This book examines case study research in education and case study methodology.

Stiegelbauer, S. (1984) Community, Context, and Co-curriculum: Situational Factors Influencing School Improvements in a Study of High Schools. Presented at the annual meeting of the American Educational Research Association, New Orleans, LA.

Discussion of several case studies: one looking at high school environments, another examining educational innovations.

Stolovitch, H. (1990). Case Study Method. Performance And Instruction, 29, (9), 35-37.

This article describes the case study method as a form of simulation and presents guidelines for their use in professional training situations.

Thaller, E. (1994). Bibliography for the Case Method: Using Case Studies in Teacher Education. RIE. 37 p.

This bibliography presents approximately 450 citations on the use of case studies in teacher education from 1921-1993.

Thrane, T. (1986). On Delimiting the Senses of Near-Synonyms in Historical Semantics: A Case Study of Adjectives of 'Moral Sufficiency' in the Old English Andreas. Linguistics Across Historical and Geographical Boundaries: In Honor of Jacek Fisiak on the Occasion of his Fiftieth Birthday . Berlin: Mouton de Gruyter.

United Nations. (1975). Food and Agriculture Organization. Report on the FAO/UNFPA Seminar on Methodology, Research and Country: Case Studies on Population, Employment and Productivity . Rome: United Nations.

This example case study shows how the methodology can be used in a demographic and psychographic evaluation. At the same time, it discusses the formation and instigation of the case study methodology itself.

Van Vugt, J. P., ed. (1994). Aids Prevention and Services: Community Based Research . Westport: Bergin and Garvey.

"This volume has been five years in the making. In the process, some of the policy applications called for have met with limited success, such as free needle exchange programs in a limited number of American cities, providing condoms to prison inmates, and advertisements that depict same-sex couples. Rather than dating our chapters that deal with such subjects, such policy applications are verifications of the type of research demonstrated here. Furthermore, they indicate the critical need to continue community based research in the various communities threatened by acquired immuno-deficiency syndrome (AIDS) . . . "

Welch, W., ed. (1981, May). Case Study Methodology in Educational Evaluation. Proceedings of the Minnesota Evaluation Conference. Minnesota. (Address).

The four papers in these proceedings provide a comprehensive picture of the rationale, methodology, strengths, and limitations of case studies.

Williams, G. (1987). The Case Method: An Approach to Teaching and Learning in Educational Administration. RIE, 31p.

This paper examines the viability of the case method as a teaching and learning strategy in instructional systems geared toward the training of personnel of the administration of various aspects of educational systems.

Yin, R. K. (1993). Advancing Rigorous Methodologies: A Review of 'Towards Rigor in Reviews of Multivocal Literatures.' Review of Educational Research, 61, (3).

"R. T. Ogawa and B. Malen's article does not meet its own recommended standards for rigorous testing and presentation of its own conclusions. Use of the exploratory case study to analyze multivocal literatures is not supported, and the claim of grounded theory to analyze multivocal literatures may be stronger."

---. (1989). Case Study Research: Design and Methods. London: Sage Publications Inc.

This book discusses in great detail, the entire design process of the case study, including entire chapters on collecting evidence, analyzing evidence, composing the case study report, and designing single and multiple case studies.

Related Links

Consider the following list of related Web sites for more information on the topic of case study research. Note: although many of the links cover the general category of qualitative research, all have sections that address issues of case studies.

• Sage Publications on Qualitative Methodology: Search here for a comprehensive list of new books being published about "Qualitative Methodology" http://www.sagepub.co.uk/
• The International Journal of Qualitative Studies in Education: An on-line journal "to enhance the theory and practice of qualitative research in education." On-line submissions are welcome. http://www.tandf.co.uk/journals/tf/09518398.html
• Qualitative Research Resources on the Internet: From syllabi to home pages to bibliographies. All links relate somehow to qualitative research. http://www.nova.edu/ssss/QR/qualres.html

Becker, Bronwyn, Patrick Dawson, Karen Devine, Carla Hannum, Steve Hill, Jon Leydens, Debbie Matuskevich, Carol Traver, & Mike Palmquist. (2005). Case Studies. Writing@CSU . Colorado State University. https://writing.colostate.edu/guides/guide.cfm?guideid=60

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What Is a Computer Case?

A case keeps the computer's internal components safe and cool

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The computer case serves mainly as a way to physically mount and contain all the actual components inside a computer, like the motherboard , hard drive , optical drive , floppy disk drive , etc. They typically come bundled with a power supply .

The housing of a laptop, netbook, or tablet is also considered a case, but since they aren't purchased separately or very replaceable, the computer case tends to refer to the one that's part of a traditional desktop PC.

Some popular computer case manufacturers include CORSAIR , NZXT , Xoxide , and Antec .

The computer case is also known as a tower , box, system unit, base unit, enclosure, housing , chassis , and cabinet .

Important Computer Case Facts

Motherboards, computer cases, and power supplies all come in different sizes called form factors. All three must be compatible to work properly together.

Many computer cases, especially ones made of metal, contain very sharp edges. Be very careful when working with an open case to avoid serious cuts.

When a computer repair person says "just bring the computer in," they are typically referring to the case and what's inside it, excluding any external keyboard, mouse, monitor, or other peripherals .

Why a Computer Case Is Important

There are several reasons why we use computer cases. One is for protection, which is easy to assume because it's the most obvious. Dust, animals, toys, liquids, etc. can all damage the internal parts of a computer if the hard shell of a computer case doesn't enclose them and keep them away from the outside environment.

Do you always want to be looking at the disc drive, hard drive, motherboard, cables, power supply, and everything else that makes up the computer? Probably not. Hand-in-hand with protection, a computer case also doubles as a way to hide all those parts of the computer that nobody really wants to see each time they look in that direction.

Another good reason to use a case is to keep the computer cool . Proper airflow over the internal components is one more benefit to using a computer case. While the case has special vents to allow some of the fan air to escape, the rest of it can be used to cool down the hardware , which would otherwise get pretty hot and possibly overheat to the point of malfunction.

Keeping noisy computer parts, like the fans, in a closed space within the computer case is one way to reduce the noise they make.

The structure of the computer case is also important. The different parts can fit together and become easily accessible to the user by being compacted in a case to hold it all together. For example, USB ports and the power button are easily accessible, and the disc drive can be opened at any time.

Computer Case Description

The computer case itself can be constructed from any material that still allows the internal devices to be supported. This is usually steel, plastic, or aluminum but might instead be wood, glass, or styrofoam.

Most computer cases are rectangular and black. Case modding is the term used to describe the styling of a case to personalize it with things like custom internal lighting, paint, or a liquid cooling system.

The front of the computer case contains a power button and sometimes a reset button. Small LED lights are also typical, representing the current power status, hard drive activity , and sometimes other internal processes. These buttons and lights connect directly to the motherboard, which is secured to the inside of the case.

Cases often contain multiple 5.25-inch and 3.5-inch expansion bays for optical drives, floppy disk drives, hard drives, and other media drives. These expansion bays are located at the front of the case so that, for example, the DVD drive can be easily reached by the user when in use.

At least one side of the case, perhaps both, slide or swing open to allow access to the internal components. See our guide on opening a computer case for instructions, or see what the inside of a PC looks like .

The rear of the computer case contains small openings to fit the connectors contained on the motherboard, which is mounted inside. The power supply is also mounted just inside the back of the case, and a large opening allows for the connection of the power cord and use of the built-in fan. Fans or other cooling devices may be attached to any and all sides of the case.

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Duke settlement could mean less drastic price hikes in rate case, affordability study

Duke Energy and six other parties filed a settlement agreement Friday regarding Duke’s controversial residential electric rate increase case.

The settlement could lessen the proposed monthly rate hike for customers beginning in August and establish a Low-Income Affordability Working Group to create more programs to assist customers.

Last night, Duke and the Public Service Commission (PSC), which regulates utilities in the state, heard from customers for the final time before the PSC decides Duke’s case.

In January, Duke requested a two-part cost hike for residential electric rates that would increase costs by nearly 20%. They faced criticism from customers in the Upstate , who voiced concerns about how the cost would impact them.

Duke initially requested $323 million in increased revenue. In the settlement, they lessened the request to $240 million, a decrease of about 26%.

If the PSC adopts the settlement, a customer using 1,000 kilowatt hours each month would see an increase of about $12.53 each month beginning in August 2024 and $6.42 each month starting in August 2026.

The initial application would have cost the same customer about $5 more in 2024 and $4 more in 2026.

The South Carolina Office of Regulatory Staff, the South Carolina Energy Users Committee, the Southern Alliance for Clean Energy, the Coastal Conservation League, Vote Solar and the South Carolina Small Business Chamber of Commerce joined Duke Energy Carolinas in the settlement agreement.

Walmart and CEC Recycling did not sign the settlement agreement but noted that neither company opposed it. However, the South Carolina Department of Consumer Affairs did not support the settlement.

On Monday morning, representatives from the company and other settling parties met for a merits hearing.Because the new settlement, which is 51 pages long, was filed on Friday, the PSC and involved parties are still “trying to parse through everything,” said PSC Chair Florence P. Belser.

Consequently, Belser recessed Monday’s hearing, which will resume on Thursday, May 23, at 9 a.m. to give everyone involved more time to review the settlement.

“I'm not trying to drag this out,” Belser said. “I just want all parties and the commission to have the opportunity to be as familiar as possible with the settlement agreement and with other testimony that's before the commission.”

During Monday’s hearing, Duke’s Deputy General Counsel Camal O. Robinson said the company agreed to reduce overall revenue costs.

“The settlement specifically provides for a 26% lower revenue impact than that requested by the company, and also provides that the company will make a $2 million shareholder contribution to fund a Low-Income Affordability Study in South Carolina and low-income weatherization programs,” Robinson said.

The $2 million will come from shareholders, Robinson said, rather than customers.

According to the settlement, $1 million will go to weatherization programs , or programs that help reduce energy consumption. An example of weatherization is upgrading insulation or adding moisture control to a home.

The other $1 million will go to a study modeled after a similar Duke program in North Carolina to evaluate energy consumption for lower-income customers. The study will be completed by the end of 2025. The company claimed it would evaluate current programs and search for additional protection for customers struggling to afford their electric bills.

Duke also promised to improve their Residential Neighborhood Energy Savings program (NES).

While several parties agreed, the S.C. Department of Consumer Affairs said they could not find common ground with the company, Advocacy Director and Deputy Consumer Advocate Roger Hall said.

“The Department of Consumer Affairs did engage in good faith negotiations with all the parties in this matter. Our aim and any negotiations or any hearing is to get the best deal possible for residential customers while recognizing the needs of the other customer classes and any other interest groups,” Hall said. “Unfortunately, we were just not able to get there in this matter.”

The PSC held its final hearing for customers last night. Duke, the PSC, and the other parties involved in the settlement will meet at the next hearing on Thursday. After the hearings, the PSC will decide whether to adopt the settlement.

Sarah Swetlik covers climate change and environmental issues in South Carolina's Upstate for The Greenville News.   Reach her at [email protected] or on X at @sarahgswetlik .

Have a question for Sustainability with Sarah? Ask  here  or email [email protected] .

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Mirror Image Rule: Meaning, Importance, Implications and Case Studies

What is mirror image rule.

Mirror image rule describes how an offer has to be accepted for there to be a legally binding agreement. According to this regulation, an acceptance must precisely match the terms and circumstances of the initial offer to be considered genuine. A counter-offer is any alteration or departure from the conditions of the offer. This concept is based on the idea that the offer is accepted in its original form by one party, and the contract is then drafted to reflect that acceptance. The “absolute acceptance” rule, as it is often known, states that a contract may only be formed if all parties propose and agree to identical conditions. A contract is created when the parties propose and accept the precise conditions; this is also known as the “absolute acceptance” rule.

Key Takeaways

The mirror image rule, commonly known as the mirror image doctrine, is a fundamental principle in contract law. The enforceability and integrity of contracts are safeguarded by the mirror image rule. A theory in contract law known as the “mirror image rule” holds that for a contract to be created, the conditions of the offer and the acceptance of the offer must exactly match. The mirror image rule highlights how crucial it is for the parties to communicate intelligibly and clearly while drafting a contract. It guarantees that the terms and conditions of the contract are understood and agreed upon by both parties.

Table of Content

Importance of Mirror Image Rule

Implications of mirror image rule, case studies under mirror image rule, mirror image rule- faqs.

1. Clarity and Certainty: Ensuring clarity and certainty in a contract is the main purpose of the mirror image rule. It removes uncertainty regarding the conditions that have been agreed upon by demanding that an acceptance accurately represent the offer. As a result of both parties’ clear grasp of their responsibilities and rights, the likelihood of future issues resulting from misread terms is reduced.

2. Prevents Sneaky Acceptances : A further important consideration is to avoid “illusory acceptance.” This happens when one party appears to accept an offer while making little adjustments that they believe the other side won’t observe. Such strategies are exposed by the mirror image rule. It inhibits parties from putting in hidden conditions that might change the original agreement by demanding a full reflection of the offer.

3. Promotes Good Faith Negotiations : A more open and sincere negotiating process is promoted by the mirror image rule. A party must expressly make a counter-offer in order to request adjustments to the offer , which forces an honest dialogue and unambiguous disclosure of the requested changes. Parties are discouraged from attempting to “sneak something in” during acceptance as a result.

4. Reduces Litigation : The mirror image rule helps lessen the possibility of litigation by guaranteeing precise and well-defined contracts. There is less opportunity for misunderstandings that might result in legal action when both parties are aware of the precise terms from the beginning.

5. Simplicity and Efficiency : The contract construction procedure is made simpler by the mirror image rule. It eliminates ambiguity and expedites the preliminary phases of agreement-building by offering a distinct standard for legitimate acceptance.

1. Clarity and Certainty : Contractual commitments are made clear and definite by the mirror image rule. The need for the acceptance to match the offer exactly removes any room for interpretation or misunderstanding caused by inconsistent or changed wording. It lessens the possibility of future disagreements or miscommunications by assisting both parties in properly knowing their rights and responsibilities.

2. Intent of Parties : In order to make sure that everyone is on the same page and intends to be bound by the same terms, the mirror image rule is used. It stops one party from agreeing to an offer that has new or modified conditions, which might transform the essence of the contract. The parties can be sure that they are entering into a mutually agreed-upon contract and that their objectives are in line by following the mirror image rule.

3. Legal Enforceability : A contract needs to meet a number of requirements in order to be upheld in court. One such rule is the mirror-image rule. The first offer is deemed a counteroffer and is no longer acceptable if the acceptance does not match the offer.

1. Gibson v. Manchester City Council

• In Gibson v. Manchester City Council, Mr. Gibson completed a form from the council in order to get the conditions of his mortgage and learn the worth of his council property, with the intention of purchasing it.
• He received a letter from the council with the information and an application to complete if he wanted to proceed. He gave the filled-out form back. However, a new administration soon took office and put an end to the municipal housing sales. Mr. Gibson was so informed that he could not complete his transaction.
• He filed a lawsuit against the council, claiming he was entitled to finish the transaction because a legally binding agreement was already in place.
• The court determined that the council’s letter was not an offer.
• There was never a contract made for the council to break because there was never an offer to accept. This is a result of the lack of an offer that Mr. Gibson may have accepted in return. As a result, poor old Mr. Gibson was unable to purchase his home.

2. Minneapolis & S. L. Ry. v. Columbus Rolling Mill

• Another case that addressed the mirror image rule is Minneapolis & S. L. Ry. v. Columbus Rolling Mill. It concerned a railroad firm taking legal action against a manufacturing company. In March 1880, the Minneapolis & St. Louis Railway Co. requested a price from Columbus Rolling Mill Co. for the delivery of iron rails.
• They responded by offering to sell the railroad firm between 2,000 and 5,000 tons of 50 kg rails; the acceptance had to be accepted by December 20, 1879, for it to be considered enforceable. The railroad business placed an order for 1,200 tons of rails at the same price in a letter dated December 16.
• Columbus claimed that they were unable to complete the reduced order at the initial cost, and the railroad tried to file a breach of contract lawsuit.
• The court determined that this case did not satisfy the mirror image requirement. Columbus Rolling Mill refused to accept Minneapolis & St. Louis Railway Co.’s attempts to modify the conditions of the initial offer, which is why. Since the acceptance did not match the offer, the contract was void.

The mirror image rule stipulates that an offer must be accepted in exactly the same, unconditional form as it was made. Put differently, any alterations or adjustments to the conditions of the offer should be regarded as a counteroffer rather than an acceptance. In addition to preventing misunderstandings or conflicts resulting from contradictory or changing wording, this regulation provides clarity and certainty in the construction of contracts. Although the mirror image rule offers a structure for contract generation, there are certain exclusions and alternate methods that could be useful in specific situations. When engaging in a contract, both individuals and businesses must be aware of the restrictions and exceptions.

When is a rejection not a counteroffer?

A counter-offer with a few modest adjustments may occasionally be viewed by courts as an extension of the bargaining process rather than a total rejection. This is unusual and contingent upon the particular circumstances.

What consequences result from breaking the mirror-image rule?

An “acceptance” turns into a counter-offer if it contains modifications. The initial bidder may then: Accept the opposing proposal. Make a fresh offer and reject the counter-offer. Treat the counter-offer as a rejection and ignore it.

How can I stay clear of mirror image rule problems?

In your offer, explicitly list all terms and limitations. Make sure the deal you accept accurately represents what you were offered. Make a specific counteroffer and wait for the other party’s answer if you wish to make modifications. When handling complicated contracts, think about speaking with an attorney.

How do contracts get protected by the mirror image rule?

In order to make sure that everyone is on the same page and intends to be bound by the same terms, the mirror image rule is used. It stops one party from agreeing to an offer that has new or modified conditions, which might transform the essence of the contract.

What are the exceptions to mirror image rule?

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Note: The information provided is sourced from various websites and collected data; if discrepancies are identified, kindly reach out to us through comments for prompt correction.

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