China could well win, as it has been preparing for the long-rumored WTO action by couching its export policies in language consistent with recognized WTO environmental exceptions.

FORBES: Forget the WTO: The Rare Earths Solution Is Right Here at Home

By couching Palestinian rejection of the Israeli offer in such terms, Arafat made clear that the Palestinian demands on Israel are not limited, and so amenable to compromise and conciliation.

CENTERFORSECURITYPOLICY: Israel and the Palestinians: Ending the Stalemate

The Yankees are couching it as an experiment and say nothing is final, but unless something goes drastically wrong over the next month, this is how the Yankees will deploy their outfielders in 2013.

WSJ: In the Center of Yankee Change

Couching the country's policy choices as being between dollarisation and devaluation, against a backdrop of collusion between banks and government, is unfair and misrepresents the progress made by the country over the past ten years.

ECONOMIST: Letters

Demonising his opponent's ideas, appropriating the popular aspects of them and couching the overall policy in populist rhetoric is a coherent strategy, and one Mr Gore excels at: remember his demolition of Bill Bradley's health-care plans.

ECONOMIST: The precarious politics of prosperity