The People's Republic of China and the Philippines both claim the Scarborough Shoal or Panatag Shoal or Huangyan Island (), nearest to the island of Luzon, located in the South China Sea. The Philippines claims it under the principles of terra nullius and EEZ (exclusive economic zone). China's claim refers to its discovery in the 13th century by Chinese fishermen (the former Nationalist government on the Chinese mainland had also claimed this territory after the founding of the Republic of China in 1911). However, despite China's position of non-participation in a United Nations Convention on the Law of the Sea case, in 2016, the Permanent Court of Arbitration (PCA) denied the lawfulness of China's "nine-dash line" claim. Despite this, China continues to build artificial islands in the South China Sea, and Scarborough Shoal is a prime location for another one. Chinese ships have been seen in the vicinity of the shoal. Analysis of photos has concluded that the ships lack dredging equipment and therefore represent no imminent threat of reclamation work. Europe Ireland The term terra nullius has been applied by some modern academics in discussing the English colonisation of Ireland, although the term is not used in the international law sense and is often used as an analogy. Griffen and Cogliano state that the English viewed Ireland as a terra nullius. In The Irish Difference: A Tumultuous History of Ireland’s Breakup With Britain, Fergal Tobin writes that "Ireland had no tradition of unified statehood and no culturally unified establishment. Indeed, it had never known any kind of political unity until a version of it was imposed by Cromwell's sword […] So the English Protestant interest […] came to regard Ireland as a kind of terra nullius." Similarly, Bruce McLeod writes in The Geography of Empire in English Literature, 1580-1745 that "although the English were familiar with Ireland and its geography in comparison to North America, they treated Ireland as though it were terra nullius and thus easily and geometrically subdivided into territorial units." Rolston and McVeigh trace this attitude back to Gerald of Wales (13th century), who wrote "This people despises work on the land, has little use for the money-making of towns, contemns the rights and privileges of citizenship, and desires neither to abandon, nor lose respect for, the life which it has been accustomed to lead in the woods and countryside." The semi-nomadism of the native Irish