"In quite different ways, in other words, Cahill, Hengehold, and MacKinnon were all implicitly or explicitly advocating, first. An understanding of rape that addressed both the reality and the rhetoric of women's sexuality, and, second, a more critical approach to crimes committed against this sexuality. To the extent that-constructed or not-sexual identity intersected with social, political, or national identity, rape needed to be understood as an attack on subjectivity as much as it was understood as a physical assault. To the extent that the centrality of the penis (counter intuitively) highlighted the violent as opposed to the sexual nature of rape, the male penis needed to be downplayed in favor of female bodily integrity. All three of these theorists, in other words, were understanding rape in terms of "trespass” rather than in terms of "penetration.” To draw on the vocabulary of the last chapter, identity was trumping violence. All three of these theorists were also, however, writing in the late 1980s and 1990s. By the first years of the twenty-first century, both internal law and European law had changed. Indeed, by 2005, various international legislative commissions had started defining rape in precisely the terms advanced by Cahill, Henhehold, and MacKinnon. Meanwhile, French, Italian, Turkish and other nation-state based jurists were coming to understand rape explicitly as an issue of bodily integrity, identity and dignity-highlighting the victim's subjectivity, and marginalizing or in some cases eliminating completely the role of violence, penetration, or the penis. If we are operating in a progress narrative, therefore, we seem to be on the right track. In fact, if we look further back in time, past the 1977 conversation with Foucault, we can see a distinctly progressive transformation-from a “traditional” approach to rape, in which a woman's sexuality, or more specifically her virginity, was the property of her family, her father, or her husband, to a late nineteenth/early twentieth century moment during which women were understood as (liberal) political actors theoretically (if not actually) capable of consent, to, finally, this late twentieth/early twenty-first century point at which women became embodied subjects, political actors to the extent that their bodily integrity remained intact."