In 1866, of course, there were large confiscations of land in the Bay of Plenty, including land to which Ngāti Rangitihi had a strong connection. Those confiscation claims were never properly investigated, despite the protests of rangatira. Of course, in our land law, back in the 1860s, the Crown went about converting collectively held land, land that was held by Māori in tribal ownership, into individual tenure. This was devastating. Then in the 1870s through to 1890s there were proceedings in the Native Land Court, but this succeeded in burdening Ngāti Rangitihi with considerable survey costs and didn't really resolve any of the claims. Then you had the Crown refusing to pay rent on land where the tenure was yet to be determined.