The "Earl of Clare" was probably not a medieval title. Some contemporary sources called them "Earls of Clare", but many modern historians treat this as if it were a "styled" (self-assumed) title. There was no standardised method of reference to earls in the late eleventh and twelfth centuries, and the Clares were one of a handful referred to as earls in this period without a county mentioned. For example, Gerald of Wales recounts an incident relating to the Earl of Clare, possibly referring to William Fitz Robert, 2nd Earl of Gloucester. Such references led some older historians to assume the Earls of Gloucester and Hertford also carried the title Earls of Clare. The title, for instance, is given in the original Dictionary of National Biography. The confusion probably stems from misinterpretation of references, such as that of "Earl Gilbert de Clare", in which Clare was taken as a title rather than a surname. One view is there was no such title in existence, and that the first creation of the title Earl of Clare dates to 1624. However, John Burke in 1831 states that prior to the 1624 creation, Robert Rich, Earl of Warwick, was to be created Earl of Clare, but that it was refused by the crown lawyers, "on a solemn declaration, that it was a title peculiar to the royal blood and not to be conferred upon a subject."