Historically, landscape designers trained by apprenticing—such as André Le Nôtre, who apprenticed with his father before designing the Gardens of Versailles—to accomplished masters in the field, with the titular name varying and reputation paramount for a career. The professional section of garden designers in Europe and the Americas went by the name 'Landscape Gardener.' In the 1890s, the distinct classification of landscape architect was created, with educational and licensing test requirements for using the title legally. Beatrix Farrand, the sole woman in the founding group, refused the title preferring Landscape Gardener. Matching the client and technical needs of a project, and the appropriate practitioner with talent, legal qualifications, and experienced skills, surmounts title nomenclature.