 Many arguments were been advanced by Nāgārjuna, as well as by later Buddhist writers, for the claim that there is no intrinsic nature; many of these arguments, including most of those found in Śāntideva’s works, are thoroughly and sympathetically discussed in modern secondary sources such as Westerhoff 2009. In his presentation of emptiness in chapter 14 of the ŚS, though, Śāntideva devotes considerable space to an argument that has been quite prominent in the Tibetan tradition but is not usually foregrounded in Western interpretations of Madhyamaka. A representative instance of this argument can be found at ŚS 248: