If only these two original criteria are used to define hypoelasticity, then hyperelasticity would be included as a special case, which prompts some constitutive modelers to append a third criterion that specifically requires a hypoelastic model to "not" be hyperelastic (i.e., hypoelasticity implies that stress is not derivable from an energy potential). If this third criterion is adopted, it follows that a hypoelastic material might admit nonconservative adiabatic loading paths that start and end with the same deformation gradient but do "not" start and end at the same internal energy.