The notion of the Property or Ownership as consisting of a ‘bundle of rights’ is often associated with the Legal Realists and with Hohfeld. However, in reading associated with the present project, John Hudson found F. W. Maitland using the phrase in his essay on ‘The Mystery of Seisin’, Law Quarterly Review, 2 (1886), 489. Consultation with helpful experts found an earlier instance, from 1873, in George Sweet, Papers Read before the Juridical Society, (1858-74), 83: ‘Proprietorship is a bundle of rights’. Is anyone aware of earlier instances?