 Cara Nine has also updated the natural law tradition, focusing on Samuel Pufendorf’s theory. In a series of well-known articles and her 2012 book, she relied on a particular interpretation of Lockean arguments, but more recently she has argued that Pufendorf’s natural law/ common ownership argument is instructive for our thinking about what we now think of as the global commons. She examines the ocean as a common pool resource and the test case of rival claims in Arctic waters (Nine 2019). She argues that Pufendorf’s appeal to conventional agreements and a system of collective dominium may be the best way for assessing whether there is real benefit from exclusive use of an object (thereby potentially giving rise to property claims) and the role of necessity in adjudicating between rival claims. Nine argues that Pufendorf’s more social, conventional and collective account of our relations to the world contains a discussion of inherent limits of jurisdictional control. The claims to common pool resources, are, she argues, limited in three ways: the need to avoid domination among claimants, thus setting the stage for a deliberation amongst claimants from a position of equal status; avoiding greed,; and avoiding taking what is already used by others, which implies a recognition of the needs, commitments and expectations of others (see also Mancilla 2012). Although this is not presented as a full territorial theory, it does indicate the rich nuances of some exponents of that tradition and the way that the concepts they deployed can be serviceable to contemporary problems. It also points to a conventional account of the limits of such rights, where the conventions have to be sensitive to the equal standing of parties, and their needs and commitments. Nine then usefully discusses how this could be applied to places that we think of as part of the global commons as well as its implications for a hybrid (conventional combined with moral principles) theory of boundaries.