Conceptual arguments claim that a particular approach to legal interpretation follows from the concept of interpretation, the concept of law, the concept of authority, or some other relevant concept (e.g., Neale 2012 [Other Internet Resources]; see Berman 2009, 37–68). For example, as noted in section 2, some writers have argued that any approach to a text that does not seek the intentions of the author does not count as interpretation (Fish 2005; Graglia 1992).[31]