The effort to establish enforceable human rights obligations on nonstate actors, including corporations, has persisted since the beginning of attempts to protect human rights through law. See Steven R. Ratner, Corporations and Human Rights: A Theory of Legal Responsibility, 111 Yale L.J. 443, 452–54 (2001). Originally, though, international human rights obligations were viewed as governing only states, because of entrenched international legal doctrine related to legal personality. Lauterpacht, writing in the mid-twentieth century observed that “[t]he orthodox positivist doctrine has been explicit in the affirmation that only States are subjects of international law.” H. Lauterpacht, The Subjects of the Law of Nations, 63 L.Q. Rev. 438, 439 (1947). See also L. Oppenheim, 1 International Law 341 (1905) (“[s]ince the Law of Nations is a law between States only and exclusively, States only and exclusively are subjects of the Law of Nations”). Individuals and other nonstate actors were viewed as objects, not subjects, of the international legal system. Recall the discussion in Chapter 4 about the human rights obligations to “respect” and “ensure” and “take steps” contained in article 2 of the International Covenant on Civil and Political Rights and the International Covenant on Economic, Social, and Cultural Rights. Those obligations, of course, rest on states for their fulfillment. However, this does not necessarily mean that nonstate actors cannot be held accountable for human rights violations on other grounds.