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As early as 1496 her [England's] monarch granted a commission to the Cabots, to discover countries then unknown to Christian people, and to take possession of them in the name of the king of England... [Cabots were authorized to take possession of lands] notwithstanding the occupancy of the natives, who were heathens, and, at the same time, admitting the prior title of any Christian people who may have made a previous discovery.
— JOHN MARSHALL