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Part of the problem is simply planned obsolescence – The X Factor produces a constant turnover of artists whose audiences cross over.
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He reckons that a mere 3% capital requirement (which enables a bank to lend more than 30 times as much as the capital it holds) is "simply planning for failure".
Or maybe the academy is simply planning a surprise tribute to the greatest circus films of all time?
They are simply planning devices for Congress and establish the framework for tax and spending legislation to come.
Nobody was suggesting further stimulus; Labour was simply planning less austerity (as it happens, the deficit has ended up around the level that Labour was aiming for).
Perhaps Erik Spoelstra was simply planning ahead on that Sunday in late March when he left his two superstars in the locker room.
When 22-year-old student and writer Paulina Drėgvaitė headed to Trafalgar Square last week, she was simply planning to meet a friend in central London and enjoy the good weather.
The gunman claimed he was simply planning to commit a robbery on the train.
The Oklahoma Republican told the Ethics Committee that he was simply planning to pass along information to Ensign.
Stanley Weiner: You know, when we initially set up shop with STW, we were simply planning on targeting frack water in the oil business.
"Art was simply plan B after I gave up the idea of being a superhero," she said.
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Justyna Jupowicz-Kozak
CEO of Professional Science Editing for Scientists @ prosciediting.com