 Cara Nine’s early articles and her 2012 book Global Justice and Territory also make use of Locke’s theory to explain how a state can gain entitlement to a territory. She argues that a state improves its territory, adding value to the area via the enforcement of jurisdictional rules about property, contract, and so on. This use of Locke to justify territory by a corporate agent is coherent but it is purely retrospective: it tells us that a state can be entitled to an area on the basis of what it has done, but since the state excludes other potential claimants it cannot really show that it has done more than other contending territorial agents would have done, nor does it offer the resources to decide between two contending groups, each aspiring to create a state in the region (and thereby engage in the value-enhancing jurisdictional activity). Nine’s recent work on Pufendorf and her emphasis on conventional agreements under certain conditions is focused on addressing that problem.