but illustrate the difference between attributive and predicative possession: Requires fewer morphological features If a language has separate alienable and inalienable possession constructions, and one of the constructions is overtly marked and the other is "zero-marked", the marked form tends to be alienable possession. Inalienable possession is indicated by the absence of the overt marker. An example is the data from Dâw. One typological study showed that in 78% of South American languages that distinguish between inalienable and alienable possession, inalienable possession was associated with fewer morphological markers than was its alienable counterpart. By contrast, only one of the surveyed languages required more morphological features to mark inalienable possession than alienable possession. If a language makes a grammatical distinction between alienable and inalienable nouns, having an overt possessive marker to mark inalienability is redundant. After all, by being inalienable, a noun must be possessed. Tighter structural bond between possessor and possessee In inalienable possession constructions, the relationship between the possessor and possessee is stronger than in alienable possession constructions. Johanna Nichols characterizes that by the tendency of inalienable possession to be head-marked but alienable possession to be dependent-marked. In head-marking, the head of an inalienable possession construction (the possessed noun) is marked, but in dependent-marking, the dependent (the possessor noun) is marked. Theories of representation in syntax Since the possessor is crucially linked to an inalienable noun's meaning, inalienable nouns are assumed to take their possessors as a semantic argument. Possessors to alienable and inalienable nouns can be expressed with different constructions. Possessors in the genitive case like the friend of Mary appear as complements to the possessed noun, as part of the phrase headed by the inalienable noun. That is an example of internal possession since the possessor of the noun is inside the determiner phrase. External possession Inalienable possession can also be marked with external possession. Such constructions have the possessor appearing outside the determiner phrase. For example, the possessor may appear as a dative complement of the verb. French exhibits both external possessor construction and internal possessor construction, as in (23): However, those types of possessors are problematic. There is a discrepancy between the possessor appearing syntactically in an inalienable possession construction and what its semantic relationship to the inalienable noun seems to be. Semantically, the possessor of an inalienable noun is intrinsic to its meaning and acts like a semantic argument. On the surface syntactic structure,