A part of the debate over the history of "terra nullius" is when the term itself was first used. According to historian of ideas Andrew Fitzmaurice, "territorium nullius" and "terra nullius" were two different, albeit related, legal terms. He claims that "territorium nullius" was first used in a meeting of the Institut de Droit International in 1888 where the legal principles of the Berlin conference were discussed and that "terra nullius" was introduced twenty years later during legal disputes over the polar regions. Historian Michael Connor on the other hand, argues that "territorium nullius" and "terra nullius" are the same thing. Both scholars are active in the Australian "history wars" debate.