One of the factors that contributed to the expansion of corporate liability was the establishment of the respondeat superior notion in customary law. The vast majority of the first instances of corporate responsibility were considered to be public harms, such as nuisances, which were not expected to arise in private settings. As a result, public enforcement was necessary in order to ensure that the firm effectively internalised the costs of its activities to society. Not until after the concept of corporate criminal liability became widely applied did civil lawsuits become the vehicle by which public enforcement was administered. In order to keep the deterrent system functioning properly, the organisation needed to be held accountable. In light of the fact that there was a dearth of meaningful public civil enforcement prior to the early 1900s, it seems that the only option that could have achieved both the goals of corporate accountability and public enforcement was the concept of corporate criminal liability.