In 2006, an earlier Lord Lyon had recognised three petitioners as "Feudal Countess of Crawfurd-Lindsay", "Feudal Earl of Breadalbane" and "Feudal Earl of Rothes". In the ruling in 2010, the Lord Lyon stated that as a general rule previous decisions should be followed, but he could not agree with them as the arguments in the previous cases did not appear to have been tested and no reasoning had been given by the prior Lord Lyon for his decisions. The title "feudal Earl", "territorial Earl", or simply "Earl", being used or recognised in respect of an assemblage of lands into an earldom had never existed until recently. He stated that while the "Abolition of Feudal Tenure Act of 2000" divorced feudal baronies from land title, it preserved the title of baron. This was not the case he found with "territorial" or "feudal earldoms": "On the contrary there is a clear break between the type of territorial earldoms which existed before the evolution of a personal peerage, and the later erection of lands into what has been termed a “territorial earldom”. I therefore do not accept that it follows from the recognition of a feudal baron, or one possessed of the dignity of a former feudal barony, as “Baron of X”, that the person in possession of a “territorial earldom” stemming from the erection by the Crown of lands into a free earldom, should be recognised as an “Earl” or “Countess”, “feudal” or otherwise." Under the 2014 Menking Note, the Lord Lyon effectively revoked the 2010 restrictions on recognition of such dignities and customary title as long provided to those properly holding them. See also Peerage of Scotland and List of feudal baronies. Below is an incomplete list of Scottish feudal earldoms created in Scotland before 1707.  a: The creation date is the earliest known date for the Earldom and subject to revision