this involves his introduction and development of the term Grundnorm which can be briefly summarized to illustrate the diverse responses which his opinion was able to often stimulate in the legal community of his time. The short version of its reception is illustrative of many similar debates with which Kelsen was involved at many points in his career and may be summarized as follows. The Grundnorm Regarding Kelsen's original use of the term Grundnorm, its closest antecedent appears in writings of his colleague Adolf Merkl at the University of Vienna. Merkl was developing a structural research approach for the understanding of law as a matter of the hierarchical relationship of norms, largely on the basis of their being either superior, the one to the other, or inferior with respect to each other. Kelsen adapted and assimilated much of Merkl's approach into his own presentation of the Pure Theory of Law in both its original version (1934) and its revised version (1960). For Kelsen, the importance of the Grundnorm was in large measure two-fold since it importantly indicated the logical regress of superior relationships between norms as they led to the norm which ultimately would have no other norm to which it was inferior. Its second feature was that it represented the importance which Kelsen associated with the concept of a fully centralized legal order in contrast to the existence of decentralized forms of government and representing legal orders. Another form of the reception of the term originated from the fairly extended attempt to read Kelsen as a neo-Kantian following his early engagement with Hermann Cohen's work in 1911, the year his Habilitation dissertation on public law was published. Cohen was a leading neo-Kantian of the time and Kelsen was, in his own way, receptive to many of the ideas which Cohen had expressed in his published book review of Kelsen's writing. Kelsen had insisted that he had never used this material in the actual writing of his own book, though Cohen's ideas were attractive to him in their own right. This has resulted in one of the longest-running debates within the general Kelsen community as to whether Kelsen became a neo-Kantian himself after the encounter with Cohen's work, or if he managed to keep his own non-neo-Kantian position intact which he claimed was the prevailing circumstance when he first wrote his book in 1911. The neo-Kantians, when pressing the issue,