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(ä k¯o-¯a 9 -l¯o ¯us 9 -kw¯a äd s˘en 9 -tr¯um)— Lat.: from the sky [heavens] all the way to the center of the earth; a very old property maxim which marked the boundaries within which an owner owned his property. This maxim no longer strictly applies because the owner of property in modern times owns subject to the rights of airplanes and oil and gas exploration. See Boyer, Hovenkamp, and Kurtz, The Law of Property: An Introductory Survey (4th ed. 1991).