real circumstances of the case. Writing about the 1317 Remonstrance (see below), the historian J. R. S. Phillips has said that "it demonstrates that in the early fourteenth century Pope Adrian IV’s bull Laudabiliter, in which he had urged Henry II of England to conquer Ireland, was regarded even by enemies of the English as a key element in the English monarchy’s claims to the lordship of Ireland". Against authenticity Goddard Henry Orpen notes that as early as 1615 Laudabiliter was denounced as a forgery by Stephen White, to be followed by John Lynch in 1662 and later still by Abbé Mac Geoghegan. Francis Aidan Gasquet writes that during the residence of the pontifical Court at Avignon two Lives of Pope Adrian IV were written. One was composed in 1331 and the second in 1356. In neither is there any mention of this important act of the Pope, although the authors find a place for many less important documents. Thomas N. Burke O.P., in his English Misrule in Ireland: A Course of Lectures in Reply to J. A Froude, puts forward a number of arguments against both the Bull of Adrian and the letters of his successor, Pope Alexander III. Burke questions the date on Laudabiliter, in addition to the terms contained in it and how it was obtained, questioning also the date in which it was first produced by Henry and why. Patrick Francis Moran also disputed the bull's authenticity in a November 1872 article in the Irish Ecclesiastical Record. Professor Anne Duggan's research indicates that Laudabiliter is a falsification of an existing letter and that was not in fact Adrian's intention to grant Henry the rights he claimed. In favor of an edited version A number of scholars have drawn a distinction between the letter given to John of Salisbury and the subsequent bull Laudabiliter. According to Arthur Ua Clerigh, the letter referred to was not Laudabiliter, but a formal letter of investiture, such as was used in the case of Robert Guiscard in Italy. Historian Paul Scheffer-Boichorst regards the donation as indisputable, while rejecting Laudabiliter as a forgery, as does Felix Liebermann. Oliver Joseph Thatcher's Studies Concerning Adrian IV; I. The Offer of Ireland to Henry II, reproduces the arguments of Boichorst. Textual scholar Anne Duggan of King's College, London, is of the opinion that Laudabiliter is a falsification of a genuine letter, now lost. Professor Duggan