Similarly, Belgium took no direct influence from the Statute or English copyright theory, but Joris Deene of the University of Ghent identifies an indirect influence "at two levels"; the criteria for what constitutes copyrightable material, which comes from the work of English theorists such as Locke and Edward Young, and the underlying justification of copyright law. In Belgium, this justification is both that copyright serves the public interest, and that copyright is a "private right" that serves the interests of individual authors. Both theories were taken into account in "Donaldson v Beckett", as well as in the drafting of the Statute of Anne, and Deene infers that they subsequently affected the Belgian debates over their first copyright statute. In the United States, the Copyright Clause of the United States Constitution and the first Federal copyright statute, the Copyright Act of 1790, both draw on the Statute of Anne. The 1790 Act contains provisions for a 14-year term of copyright and sections that provide for authors who published their works before 1790, both of which mirror the protection offered by the Statute 80 years previously.