Baconians Walter Begley and Bertram G. Theobald claimed that Elizabethan satirists Joseph Hall and John Marston alluded to Francis Bacon as the true author of "Venus and Adonis" and "The Rape of Lucrece" by using the sobriquet "Labeo" in a series of poems published in 1597–98. They take this to be a coded reference to Bacon on the grounds that the name derives from Rome's most famous legal scholar, Marcus Labeo, with Bacon holding an equivalent position in Elizabethan England. Hall denigrates several poems by Labeo and states that he passes off criticism to "shift it to another's name". This is taken to imply that he published under a pseudonym. In the following year Marston used Bacon's Latin motto in a poem and seems to quote from "Venus and Adonis", which he attributes to Labeo. Theobald argued that this confirmed that Hall's Labeo was known to be Bacon and that he wrote "Venus and Adonis". Critics of this view argue that the name Labeo derives from Attius Labeo, a notoriously bad poet, and that Hall's Labeo could refer to one of many poets of the time, or even be a composite figure, standing for the triumph of bad verse. Also, Marston's use of the Latin motto is a different poem from the one which alludes to "Venus and Adonis". Only the latter uses the name Labeo, so there is no link between Labeo and Bacon.