 Nevertheless, two broad trends in the scholarly discussions have emerged. The first is to push the origins of a term indicating a modern, subjective sense of “a right” back further into history: from Locke to Hobbes to Grotius in the seventeenth century, then to Gerson in the fifteenth century, then to Ockham in the fourteenth, perhaps even to Gratian in the twelfth (Brett 1997, Tierney 1997, Siedentop 2014, Lisska and Tierney 2015). Donohue (2010) even argues that ius is used in a subjective sense throughout the works of the classical Roman jurists in the first century BCE to the third century CE.