What is a pirate? Says President Woolsey: "Piracy is robbery on the sea, or by descent from the sea upon the coast, committed by persons not holding a commission from, or at the time pertaining to, any established state. It is the act (1) of persons forming an organization for the purpose of plunder, or with malicious intent; but who, inasmuch as such a body is not constituted for political purposes, can not be said to be a body politic; (2) of persons who, having in defiance of law seized possession of a chartered vessel, use it for the purpose of robbery; (3) of persons taking a commission from two belligerent adversaries. The reason for ranking these latter among pirates is that the _animus furandi_ is shown by acting under two repugnant authorities. It has been held by some that a vessel which takes commissions even from two allies is guilty of piracy, but others regard such an act only as illegal and irregular."[61] Chancellor Kent calls piracy "robbery, forceful plunder, or murder by marauders on the high seas _in the spirit and intent of universal hostility_." The Century Dictionary defines it as follows: "Specifically in the law of nations, the crime of depredations or willful and aggressive destruction of life and property, committed on the seas by persons having no commission or authority from any established state. As commonly used, it implies something more than a simple theft with violence at sea, and includes something of the idea of general hostility to law."