 One interesting fact to observe here, is that as noted by Hewson (1972; 66–67), languages with articles and languages with robust case morphology are typically in complementary distribution. Indeed, as languages evolve, their robust inflectional system gives way to structure dependent language (Leiss (2000)). It is when the case system weakens that determiners begin to appear––an idea that is offered in Abraham (1997:29), Philippi (1997:63–64), Selig (1992), Ivančev 1988:105, and (Mayer 1988: 112). As Mladenova (2007) puts it, “the morphology of the definite article makes it possible to perpetuate case distinctions long after they have been obliterated elsewhere.” (But see also Mladenova for subtleties in applying this idea to Bulgarian.) Could it be then that determiners serve the purpose of case marking? Iliev (2019) argues that this is what is happening in Bulgarian––genitive case markers have been replace by determiners, which continue to express a kind of possessive relation.