English herald Arthur Charles Fox-Davies asserted in 1909 that the "leopard", denoting a lion passant guardant, was a term of French origin that had "long since become obsolete in English armory. In French blazon, however, the old distinction is still observed." Fox-Davies continued, "heralds term our lion passant a "léopard-lionné" and our lion rampant guardant is their "lion-léopardé"." Dutch heraldist Johannes Rietstap, however, defined a "Léopard lionné" as a lion rampant guardant (i.e., upright like a lion with its head turned to full face like a leopard) and a "Lion léopardé" as a lion passant (i.e., walking like a leopard with its head facing dexter like a lion). German-American heraldist Carl-Alexander von Volborth agrees with Rietstap's translations, in contrast to those of Fox-Davies as stated above.