• Korean small business review
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• v.31 no.2
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• pp.85-102
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• 2009

With the continued globalization of world markets, transfer pricing has become one of the dominant sources of controversy in international taxation. Transfer pricing is the process by which a multinational corporation calculates a price for goods and services that are transferred to affiliated entities. Consider a Korean electronic enterprise that buys supplies from its own subsidiary located in China. How much the Korean parent company pays its subsidiary will determine how much profit the Chinese unit reports in local taxes. If the parent company pays above normal market prices, it may appear to have a poor profit, even if the group as a whole shows a respectable profit margin. In this way, transfer prices impact the taxable income reported in each country in which the multinational enterprise operates. It's importance lies in that around 60% of international trade involves transactions between two related parts of multinationals, according to the OECD. Multinational enterprises (hereafter MEs) exert much effort into utilizing organizational advantages to make global investments. MEs wish to minimize their tax burden. So MEs spend a fortune on economists and accountants to justify transfer prices that suit their tax needs. On the contrary, local governments are not prepared to cope with MEs' powerful financial instruments. Tax authorities in each country wish to ensure that the tax base of any ME is divided fairly. Thus, both tax authorities and MEs have a vested interest in the way in which a transfer price is determined, and this is why MEs' international transfer prices are at the center of disputes concerned with taxation. Transfer pricing issues and practices are sometimes difficult to control for regulators because the tax administration does not have enough staffs with the knowledge and resources necessary to understand them. The authors examine transfer pricing practices to provide relevant resources useful in designing tax incentives and regulation schemes for policy makers. This study focuses on identifying the relevant business and environmental factors that could influence the international transfer pricing of MEs. In this perspective, we empirically investigate how the management perception of related variables influences their choice of international transfer pricing methods. We believe that this research is particularly useful in the design of tax policy. Because it can concentrate on a few selected factors in consideration of the limited budget of the tax administration with assistance of this research. Data is composed of questionnaire responses from foreign firms in Korea with investment balances exceeding one million dollars in the end of 2004. We mailed questionnaires to 861 managers in charge of the accounting departments of each company, resulting in 121 valid responses. Seventy six percent of the sample firms are classified as small and medium sized enterprises with assets below 100 billion Korean won. Reviewing transfer pricing methods, cost-based transfer pricing is most popular showing that 60 firms have adopted it. The market-based method is used by 31 firms, and 13 firms have reported the resale-pricing method. Regarding the nationalities of foreign investors, the Japanese and the Americans constitute most of the sample. Logistic regressions have been performed for statistical analysis. The dependent variable is binary in that whether the method of international transfer pricing is a market-based method or a cost-based method. This type of binary classification is founded on the belief that the market-based method is evaluated as the relatively objective way of pricing compared with the cost-based methods. Cost-based pricing is assumed to give mangers flexibility in transfer pricing decisions. Therefore, local regulatory agencies are thought to prefer market-based pricing over cost-based pricing. Independent variables are composed of eight factors such as corporate tax rate, tariffs, relations with local tax authorities, tax audit, equity ratios of local investors, volume of internal trade, sales volume, and product life cycle. The first four variables are included in the model because taxation lies in the center of transfer pricing disputes. So identifying the impact of these variables in Korean business environments is much needed. Equity ratio is included to represent the interest of local partners. Volume of internal trade was sometimes employed in previous research to check the pricing behavior of managers, so we have followed these footsteps in this paper. Product life cycle is used as a surrogate of competition in local markets. Control variables are firm size and nationality of foreign investors. Firm size is controlled using dummy variables in that whether or not the specific firm is small and medium sized. This is because some researchers report that big firms show different behaviors compared with small and medium sized firms in transfer pricing. The other control variable is also expressed in dummy variable showing if the entrepreneur is the American or not. That's because some prior studies conclude that the American management style is different in that they limit branch manger's freedom of decision. Reviewing the statistical results, we have found that managers prefer the cost-based method over the market-based method as the importance of corporate taxes and tariffs increase. This result means that managers need flexibility to lessen the tax burden when they feel taxes are important. They also prefer the cost-based method as the product life cycle matures, which means that they support subsidiaries in local market competition using cost-based transfer pricing. On the contrary, as the relationship with local tax authorities becomes more important, managers prefer the market-based method. That is because market-based pricing is a better way to maintain good relations with the tax officials. Other variables like tax audit, volume of internal transactions, sales volume, and local equity ratio have shown only insignificant influence. Additionally, we have replaced two tax variables(corporate taxes and tariffs) with the data showing top marginal tax rate and mean tariff rates of each country, and have performed another regression to find if we could get different results compared with the former one. As a consequence, we have found something different on the part of mean tariffs, that shows only an insignificant influence on the dependent variable. We guess that each company in the sample pays tariffs with a specific rate applied only for one's own company, which could be located far from mean tariff rates. Therefore we have concluded we need a more detailed data that shows the tariffs of each company if we want to check the role of this variable. Considering that the present paper has heavily relied on questionnaires, an effort to build a reliable data base is needed for enhancing the research reliability.

• Journal of Distribution Research
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• v.17 no.4
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• pp.55-80
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• 2012

I. Introduction Developing the relationships between companies is very important issue to ensure a competitive advantage in today's business environment (Bleeke & Ernst 1991; Mohr & Spekman 1994; Powell 1990). Partnerships between companies are based on having same goals, pursuing mutual understanding, and having a professional level of interdependence. By having such a partnerships and cooperative efforts between companies, they will achieve efficiency and effectiveness of their business (Mohr and Spekman, 1994). However, it is difficult to expect these ideal results only in the B2B corporate transaction. According to agency theory which is the well-accepted theory in various fields of business strategy, organization, and marketing, the two independent companies have fundamentally different corporate purposes. Also there is a higher chance of developing opportunism and conflict due to natures of human(organization), such as self-interest, bounded rationality, risk aversion, and environment factor as imbalance of information (Eisenhardt 1989). That is, especially partnerships between principal(or buyer) and agent(or supplier) of companies within supply chain, the business contract itself will not provide competitive advantage. But managing partnership between companies is the key to success. Therefore, managing partnership between manufacturer and supplier, and finding causes of conflict are essential to improve B2B performance. In conclusion, based on prior researches and Agency theory, this study will clarify how business hazards cause conflicts on supply chain and then identify how developed conflicts have been managed by two control mechanisms. II. Research model III. Method In order to validate our research model, this study gathered questionnaires from small and medium sized enterprises(SMEs). In Korea, SMEs mean the firms whose employee is under 300 and capital is under 8 billion won(about 7.2 million dollar). We asked the manufacturer's perception about the relationship with the biggest supplier, and our key informants are denied to a person responsible for buying(ex)CEO, executives, managers of purchasing department, and so on). In detail, we contact by telephone to our initial sample(about 1,200 firms) and introduce our research motivation and send our questionnaires by e-mail, mail, and direct survey. Finally we received 361 data and eliminate 32 inappropriate questionnaires. We use 329 manufactures' data on analysis. The purpose of this study is to identify the anticipant role of business hazard (environmental dynamism, asset specificity) and investigate the moderating effect of control mechanism(formal control, social control) on conflict-performance relationship. To find out moderating effect of control methods, we need to compare the regression weight between low versus. high group(about level of exercised control methods). Therefore we choose the structural equation modeling method that is proper to do multi-group analysis. The data analysis is performed by AMOS 17.0 software, and model fits are good statically (CMIN/DF=1.982, p<.000, CFI=.936, IFI=.937, RMSEA=.056). IV. Result V. Discussion Results show that the higher environmental dynamism and asset specificity(on particular supplier) buyer(manufacturer) has, the more B2B conflict exists. And this conflict affect relationship quality and financial outcomes negatively. In addition, social control and formal control could weaken the negative effect of conflict on relationship quality significantly. However, unlikely to assure conflict resolution effect of control mechanisms on relationship quality, financial outcomes are changed by neither social control nor formal control. We could explain this results with the characteristics of our sample, SMEs(Small and Medium sized Enterprises). Financial outcomes of these SMEs(manufacturer or principal) are affected by their customer(usually major company) more easily than their supplier(or agent). And, in recent few years, most of companies have suffered from financial problems because of global economic recession. It means that it is hard to evaluate the contribution of supplier(agent). Therefore we also support the suggestion of Gladstein(1984), Poppo & Zenger(2002) that relational performance variable can capture the focal outcomes of relationship(exchange) better than financial performance variable. This study has some implications that it tests the sources of conflict and investigates the effect of resolution methods of B2B conflict empirically. And, especially, it finds out the significant moderating effect of formal control which past B2B management studies have ignored in Korea.

• KSCE Journal of Civil and Environmental Engineering Research
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• v.34 no.2
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• pp.549-559
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• 2014

The rapid expansion of cities led to the shortage of housing in urban areas. The government compensated for this shortage through large scale residential developments that increased the housing supply. The supply of condominium apartments remains above 83% of the entire housing supply, and the proportion of apartments are at a steady increase, at about 50%. Due to the increase, illegally parked cars resulting from the shortage of parking spaces within the apartment complex have become increasingly problematic as they block the transit of emergency vehicles, and heighten the tension among neighboring residents in obtaining a parking space. Especially, the future residents are considered to plan the parking based on the estimated demand for parking. However, the parking unit method utilized to estimate the parking demand accounts for the exclusive use of space, which is believed to be far from the parking demands in reality. The reason for this discrepancy is that, as the number of households decrease, and area of exclusive space is expanded, the planned parking increases. On the other hand, when the number of households increase, and the area of exclusive space is reduced, the planned parking decreases, thus methods to recalculate the parking units based on estimated parking demand is an urgent concern. To estimate the parking units based on condominium apartments, this study first examined the existing research literature, and appointed the field of investigation to collect the necessary data. In addition, field study data and surveys collected and analyzed, in order to identify the problems underlying parking units, and problems regarding the current traffic impact assessment parking unit calculation method were deduced. Through identifying the influential factors on parking demand estimates, and performing a factorial analysis based on the collected data, the variables were selected in relation to the parking demand estimates, to develop the parking unit estimate model. Finally, through comparing and verifying the existing traffic impact assessment parking unit estimate against the newly developed model using collected data, a far more realistic parking unite estimate was suggested, reflecting the characteristics of the residents. The parking unit estimate model developed in this study is anticipated to serve as the guidelines for future parking lot legislature, as wel as the basis to provide a more realistic estimate of parking demands based on the resident characteristics of an apartment complex.

• Journal of the Korean Association of Geographic Information Studies
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• v.14 no.4
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• pp.221-237
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• 2011

This study aims to investigate the environmental equity of the accessibility to urban neighborhood parks in the city of Daegu. The spatial distribution of urban neighborhood parks was explored by spatial statistics and the spatial accessibility to them was then evaluated by both minimum distance and coverage approaches. Descriptive and inferential statistics such as proximity ratio, Mann Whitney U test, and logistic regression were used for comparing the socioeconomic characteristics over different accessibilities to the neighborhood parks and then testing the distributional inequity hypothesis. The results from the minimum distance method indicated that Dalseo-gu had the best accessibility to the neighborhood parks while Dong-gu had the worst accessibility. It was apparent with the coverage method that Dalseo-gu had the best accessibility whereas Dong-gu and Nam-gu had the worst accessibility to the neighborhood parks at 500m and 1,000m buffer distances. There existed the spatial pattern of environmental inequity in old towns with respect to population density and the percentage of people under the age of 18. The spatial pattern of environmental inequity in new towns was explored on the basis of the percentage of people over the age of 65, the percentage of people below the poverty level, and the percentage of free of charge rental housing. These results were closely related to the development process of urban parks in Daegu stimulated by the quantitative urban park policy, urban development process, and residential location pattern such as permanent rental housing and free of charge rental housing. This study further extends the existing research topics of environmental justice related to the distributional inequity of environmental disamenities and hazards by focusing on environmental amenities such as urban neighborhood parks. The results from this study can be used in making the decisions for urban park management and setting up urban park policy with considering the social geography of Daegu.

• Journal of the korean academy of Pediatric Dentistry
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• v.27 no.1
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• pp.169-179
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• 2000

The purpose of this study is to develop the system which convert the optical difference of teeth texture between intact enamel and incipient caries lesion into shade difference by laser fluorescence and to develop new and simple caries activity test using laser fluorescence. The experimental design of this study consists of three parts. In first part, a new method for the in vitro assessment of changes in initial enamel caries lesion of Bovine teeth using laser fluorescence is tested. In second part, in vivo assessment undertaken. Number of teeth which showed incipient carious lesion on buccal surface examined by laser fluorescence was compared with the caries activity test of $Cariescreen^{(R)}$ test and other oral environmental test of dDfFtT. In third part, new caries activity test measured by laser fluorescence was developed on the basis of above results and evaluated the sensitivity, specificity, and diagnostic power. Optical density measured by laser fluorescence was increased as increasing the depth of incipient carious lesion and showed high correlation$(\gamma=0.7015)$ with lesion depth. Optical density showed direct proportion to lesion depth. Linear equation was obtained between the optical density and the lesion depth by regression analysis. The result of caries activity test with laser fluorescence showed high correlation with those of $Cariescreen^{(R)}$ test and dDfFtT examination. Caries activity test with laser fluorescence showed 48% of sensitivity, 52% of specificity, and 45% of diagnostic power on the basis of dDfFtT examination, and also showed 48% of sensitivity, 51% of specificity, and 36% of diagnostic power on the basis of $Cariescreen^{(R)}$ test. In regard above result, caries activity test with laser fluorescence considered to be reliable for caries activity test compared with other oral environmental test. and it was also considered to be practical because it would be simple, inexpensive, and time saving method.

• Journal of agricultural medicine and community health
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• v.35 no.3
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• pp.287-300
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• 2010

Objectives: We identified factors associated with any participation and with "good participation" (as assessed by frequency of attendance) in health promotion programs at a public health center in Korea. Methods: The subjects included 199 women who attended a baseline examination of health promotion programs during the first half of 2009. We collected data by structured interviews and physical examinations. Participation status was quantified by the frequency of attendance to the program. We classified the subjects as non-participants (0) and participants (1+ times), and as poor participants (0-29 times) and good participants (30+ times). Results: Of the 199 subjects, there were 57 (28.6%) non-participants, while 56 (28.1%) were classified as good participants. The factors that significantly affected participation status, as identified by univariate analysis, were personal factors (age, educational level, marital status, religion, living with someone, monthly income), environmental factors (method of access, accessibility of other facilities), body mass index, hypertension, perceived barriers to health, emotional salience, affectionate domain of social support, and depression. Multiple logistic regression analyses indicated that method of access was the most significant factor affecting participation in the health promotion program, and that the factors most highly associated with good participation were emotional salience, hypertension and body mass index. Conclusions: Our findings suggest that specific factors determine and enhance participation in health promotion programs offered by public health centers. These factors should be considered during the design and evaluation of health promotion programs that are offered by public health centers.

• Current Research on Agriculture and Life Sciences
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• v.8
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• pp.129-138
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• 1990

This study investigated the relationship between the cutflow of rural population and agricultural policy by using time series method. For the analytical tools, decomposition time series methods and regression technique were employed in computing seasonal fluctuation and cyclical fluctuation of population migration. Also, this study predicted farmhouse, rural population till the 2000's by means of the mathematical methods. The analytical forms employed in forecasting farmhouse, rural population were Exponential curve, Gompertz curve and Transcendental form. The major findings of this study were identified as follows: 1) Rural population and farmhouse population began to decrease from 1965 and hastily went down since 1975. Rural population which accounted for 36.4 percent, 35.6 percent of national population respectively in 1960 diminished about two times: 17.5 percent, 17.1 percent respectively. 2) The rapid decreasing of the rural population was caused because of the outflow of rural people to the urban regions. Of course, that was also caused from the natural decreases but the main reason was heavily affected more the former than the latter. In the outflowing course shaped from rural to the urban regions, rural people concentrated on such metropolis as Seoul, Pusan, Keanggi. But these trends were diminishing slowly. On the other hand, compared with that of the 1970's the migration to Keanggi was still increasing in the 1980's. That is, people altered the way of migration from the migration to Seoul, Pusan to the migration to the out-skirts of Seoul. 3) The seasonal fluctuation index of population migration has gone down since the June which the request of agricultural labor force increases and has turned to be greatly wanted in the March as result of decomposition time series method. As result of cyclical analysis, the cyclical patterns of migration have greatly 7 cycle. 4) As result of forecasting the rural and farmhouse population, rural and farmhouse population in the 2000 will be about 9,655(thousand/people) and 4,429(thousand/people) respectively. Thus, it is important to analyze the probloms that rural and farmhouse population will decrease or increase by the degree. But fairly defining the agricultural into a industry that supply the food, this problem - how much our nation need the rural and farmhouse population - is greatly significant too. Therefore, the basic problems of the agricultural including the outflows of rural people are the earning differentials between rural and urban regions. And we should regard the problems of the gap of relative incomes between rural and urban regions as the main task of the agricultural policy and treat the agricultural policy in the viewpoint of developing economic equilibrium than efficiency by using actively the natural resources of the rural regions.

• Asia pacific journal of information systems
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• v.19 no.2
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• pp.157-178
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• 2009

Corporate credit rating is a very important factor in the market for corporate debt. Information concerning corporate operations is often disseminated to market participants through the changes in credit ratings that are published by professional rating agencies, such as Standard and Poor's (S&P) and Moody's Investor Service. Since these agencies generally require a large fee for the service, and the periodically provided ratings sometimes do not reflect the default risk of the company at the time, it may be advantageous for bond-market participants to be able to classify credit ratings before the agencies actually publish them. As a result, it is very important for companies (especially, financial companies) to develop a proper model of credit rating. From a technical perspective, the credit rating constitutes a typical, multiclass, classification problem because rating agencies generally have ten or more categories of ratings. For example, S&P's ratings range from AAA for the highest-quality bonds to D for the lowest-quality bonds. The professional rating agencies emphasize the importance of analysts' subjective judgments in the determination of credit ratings. However, in practice, a mathematical model that uses the financial variables of companies plays an important role in determining credit ratings, since it is convenient to apply and cost efficient. These financial variables include the ratios that represent a company's leverage status, liquidity status, and profitability status. Several statistical and artificial intelligence (AI) techniques have been applied as tools for predicting credit ratings. Among them, artificial neural networks are most prevalent in the area of finance because of their broad applicability to many business problems and their preeminent ability to adapt. However, artificial neural networks also have many defects, including the difficulty in determining the values of the control parameters and the number of processing elements in the layer as well as the risk of over-fitting. Of late, because of their robustness and high accuracy, support vector machines (SVMs) have become popular as a solution for problems with generating accurate prediction. An SVM's solution may be globally optimal because SVMs seek to minimize structural risk. On the other hand, artificial neural network models may tend to find locally optimal solutions because they seek to minimize empirical risk. In addition, no parameters need to be tuned in SVMs, barring the upper bound for non-separable cases in linear SVMs. Since SVMs were originally devised for binary classification, however they are not intrinsically geared for multiclass classifications as in credit ratings. Thus, researchers have tried to extend the original SVM to multiclass classification. Hitherto, a variety of techniques to extend standard SVMs to multiclass SVMs (MSVMs) has been proposed in the literature Only a few types of MSVM are, however, tested using prior studies that apply MSVMs to credit ratings studies. In this study, we examined six different techniques of MSVMs: (1) One-Against-One, (2) One-Against-AIL (3) DAGSVM, (4) ECOC, (5) Method of Weston and Watkins, and (6) Method of Crammer and Singer. In addition, we examined the prediction accuracy of some modified version of conventional MSVM techniques. To find the most appropriate technique of MSVMs for corporate bond rating, we applied all the techniques of MSVMs to a real-world case of credit rating in Korea. The best application is in corporate bond rating, which is the most frequently studied area of credit rating for specific debt issues or other financial obligations. For our study the research data were collected from National Information and Credit Evaluation, Inc., a major bond-rating company in Korea. The data set is comprised of the bond-ratings for the year 2002 and various financial variables for 1,295 companies from the manufacturing industry in Korea. We compared the results of these techniques with one another, and with those of traditional methods for credit ratings, such as multiple discriminant analysis (MDA), multinomial logistic regression (MLOGIT), and artificial neural networks (ANNs). As a result, we found that DAGSVM with an ordered list was the best approach for the prediction of bond rating. In addition, we found that the modified version of ECOC approach can yield higher prediction accuracy for the cases showing clear patterns.

• Clinical and Experimental Pediatrics
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• v.48 no.2
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• pp.143-147
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• 2005

Purpose : The aim of the this study was to evaluate the effect of various perinatal conditions on TSH and thyroid hormone levels in cord blood. Methods : Cord blood samples were collected from 130 neonates immediately after birth. TSH, $T_3$, and free $T_4$ levels were measured by the radioimmunoassay(RIA) method. The effects of gestational age, sex, birth weight, delivery method, perinatal asphyxia, maternal diabetes mellitus(DM), and preeclampsia on TSH and thyroid hormone levels were assessed by ANOVA test, Student t-test, and multiple regression analysis. Results : Birth weight and sex did not affect TSH and thyroid hormone levels. TSH level increased according to gestational age(P<0.05). TSH level was $4.42{\pm}0.66{\mu}IU/mL$ in infants born vaginally, which was higher than that of cesarian section delivery($3.31{\pm}0.33{\mu}IU/mL$)(P<0.05). TSH level was $5.18{\pm}0.93{\mu}IU/mL$ in asphyxiated newborns and $2.97{\pm}0.84{\mu}IU/mL$ in non-asphyxiated newborns(P<0.05). TSH level in infants with maternal DM($8.911{\pm}1.25{\mu}IU/mL$) was higher than that of infants without maternal DM($4.32{\pm}0.42{\mu}IU/mL$)(P<0.05). TSH level was $5.28{\pm}0.42{\mu}IU/mL$ in infants with maternal preeclampsia and $3.65{\pm}0.46{\mu}IU/mL$ in infants without maternal preeclampsia(P<0.05). Thyroid hormones were lower in infants with perinatal asphyxia(P<0.05). In asphyxiated infants, $T_3$ level was $75.33{\pm}55.65ng/mL$ and free $T_4$ was $0.54{\pm}0.21ng/mL$. $T_3$ and free $T_4$ level was $109.85{\pm}41.77ng/mL$ and $0.76{\pm}0.22ng/mL$ each in infants without perinatal asphyxia. Among the perinatal factors, gestational age, 1 min Apgar score and maternal DM influenced TSH level independently. Conclusion : In our study, cord blood TSH and thyroid hormone levels were affected by perinatal stress events.

• Toxicological Research
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• v.33 no.2
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• pp.107-118
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• 2017

Although alternative test methods based on the 3Rs (Replacement, Reduction, Refinement) are being developed to replace animal testing in reproductive and developmental toxicology, they are still in an early stage. Consequently, we aimed to develop alternative test methods in male animals using mouse spermatogonial stem cells (mSSCs). Here, we modified the OECD TG 489 and optimized the in vitro comet assay in our previous study. This study aimed to verify the validity of in vitro tests involving mSSCs by comparing their results with those of in vivo tests using C57BL/6 mice by gavage. We selected hydroxyurea (HU), which is known to chemically induce male reproductive toxicity. The 50% inhibitory concentration ($IC_{50}$) value of HU was 0.9 mM, as determined by the MTT assay. In the in vitro comet assay, % tail DNA and Olive tail moment (OTM) after HU administration increased significantly, compared to the control. Annexin V, PI staining and TUNEL assays showed that HU caused apoptosis in mSSCs. In order to compare in vitro tests with in vivo tests, the same substances were administered to male C57BL/6 mice. Reproductive toxicity was observed at 25, 50, 100, and 200 mg/kg/day as measured by clinical measures of reduction in sperm motility and testicular weight. The comet assay, DCFH-DA assay, H&E staining, and TUNEL assay were also performed. The results of the test with C57BL/6 mice were similar to those with mSSCs for HU treatment. Finally, linear regression analysis showed a strong positive correlation between results of in vitro tests and those of in vivo. In conclusion, the present study is the first to demonstrate the effect of HU-induced DNA damage, ROS formation, and apoptosis in mSSCs. Further, the results of the current study suggest that mSSCs could be a useful model to predict male reproductive toxicity.