 Most contemporary theorists of territory build on the historical arguments of Grotius and Pufendorf, Locke and Kant, or are a hybrid of these historical accounts. Some—like Risse in relation to Grotius, Stilz in relation to Grotius and Kant, Nine in relation to Pufendorf and Locke, Simmons in relation to Locke, and Waldron and Ypi in relation to Kant—are explicitly based on earlier theorists, and offer ways to improve some of the difficulties that beset the original account. Others—like Miller in relation to nationalist theory—offer a philosophical version of a popular nationalist belief in relation to homelands, which has historical roots in the nineteenth century, but lacked a clear philosophical defense. Contemporary accounts that ground territorial rights on self-determination and peoplehood are not based on a single identifiable theorist, though this version attempts to define territorial right—holder and the justificatory value in a way that avoids some of the problems of earlier theorists.