 The interest of Locke’s account lies in the way he combines the structure of a theory of first occupancy with an account of the substantive moral significance of labor. In the hands of writers like Samuel Pufendorf (1991 [1673], p. 84), First Occupancy theory proceeded on the basis that the first human user of a natural resource—a piece of land, for example—is distinguished from all others in that he did not have to displace anyone else in order to take possession. It did not particularly matter how he took possession of it, or what sort of use he made of it: what mattered was that he began acting as its owner without dispossessing anyone else. Now although Locke used the logic of this account, it did matter for him that the land was cultivated or in some other way used productively. (For this reason, he expressed doubts whether indigenous hunters or nomadic peoples could properly be regarded as owners of the land over which they roamed.) This is partly because Locke identified the ownership of labor as something connected substantially to the primal ownership of self. But it was also because he thought the productivity of labor would help answer some of the difficulties which he saw in First Occupancy theory. Though the first occupier does not actually dispossess anyone, still his acquisition may prejudice other’s interests if there is not, in Locke’s words, ‘enough and as good left in common’ for them to enjoy (Locke 1988 [1689], II, para. 27). Locke’s answer to this difficulty was to emphasize that appropriation by productive labor actually increased the amount of goods available in society for others (ibid., II, para. 37). There is also something like a strand of moral desert in Locke’s theory: if one person fails to take advantage of an opportunity of resource-use or resource development, can that person really complain or demand compensation when the opportunity is taken up by someone else (de Jasay 2004)?