The actor starts the use case because it wants something from the system so:

	Name the use case in terms of the outcome of value to the actor
	Begin the use case name with an active verb
	The actor supplies the event that starts the use case

	The actor is the source of the incoming event that is the first line in the use case
	The arrow indicates that the actor starts the interaction between the actor and the use case
	This actor is then the 'active' or 'primary' actor for the use case