 Later, in his review of Hart’s The Concept of Law, Ross claimed that Hart had misunderstood him. In his analysis of “valid law,” Ross replied, he had been concerned specifically with “legal concepts as they function in the doctrinal study of law, what we on the Continent are accustomed to call the science of law,” and if this were adequately understood, it would be evident that much of the apparent disagreement between him and Hart was illusory (1962, p. 1190). In effect, Ross said, he had been analyzing legal statements of a kind Hart would have classified as “external.” Ross chalked up the confusion at least in part to the translation of the Danish phrase “gældende ret” as “valid law,” acknowledging that the results sounded “odd in English usage,” and suggesting in passing that “existing law” or “law in force” might have better captured what he had in mind. (For further discussion of the translation question, see Eng 2011.)