This chapter provides comparison of Bentham's theory with the two movements commonly labelled 'Legal Realism': American Legal Realism and Scandinavian Legal Realism. Hagerstown's ontological naturalism, then, is developed as an answer to the epistemological problem of explaining the possibility of objective knowledge. Bentham's ontology seems very similar, even if not identical, to that of the Scandinavian legal realists. Bentham's naturalistic semantic analysis of legal obligation is obviously very close to, even if not identical with, the prediction theory of law' as stated in Justice Holmes the Path of the Law. In legal philosophy, semantic naturalism consists in the view that all legal concepts such as right, duty, law, liability and the like must be shown to be capable of being analysed in natural, factual and empirical terms. Now, in a sense semantic naturalism can be seen as depending on a naturalistic ontological view.