liberty to Americans, and then, after they had drafted their Articles and knew the nature of such Articles, whether _national_ or _federal_, to _propose_ a mode of ratification in which their proposed Articles would be made by those competent to make them. When September 10 had come they had finished their work of drafting their Article, which constituted government, the First Article. For the purpose of reaching their decision as to the valid mode of ratification for an Article of _that kind_, they had considered and discussed the existing unlimited ability of the “people” or “conventions” to make all Articles, and the existing limited ability of the state legislatures to make some. The unerring decision which they had made was that their Articles would not be validly made, because the First Article constituted _national_ government of men, unless they proposed a mode of ratification by the “conventions” of the American people. We note, with intent to remember, that they were well aware that drafting and proposing an Article did not make it valid or part of a Constitution and that _proposing_ a mode of ratification did not make it a valid mode, unless the ratifiers were competent to make the proposed Article. We recall that Wilson, who appears in the brief record of September 10, later made clear the knowledge of those at Philadelphia that their _proposal_ of Articles and their _proposal_ of a mode of ratification could not make either valid, that the making of a _proposal_ is not the exercise of any power. In the Pennsylvania convention he said: “I come now to consider the last set of objections that are offered against this Constitution. It is urged that this is not such a system as was within the powers of the Convention; they assumed the _power of proposing_.... I never heard, before, that to make a proposal was an exercise of power.... The fact is, they have exercised no power at all; and, in point of validity, this Constitution, proposed by them for the government of the United States, claims no more than a production of the same nature would claim, flowing from a private pen.” (2 _Ell. Deb._ 469-470.)