1037: China’s activities at Mischief Reef have since evolved into the creation of an artificial island. China has elevated what was originally a reef platform that submerged at high tide into an island that is permanently exposed. Such an island is undoubtedly “artificial” for the purposes of Article 60. It is equally clear that China has proceeded without receiving, or even seeking, the permission of the Philippines. Indeed, China’s conduct has taken place in the face of the Philippines’ protests. Article 60 is unequivocal in permitting only the coastal State to construct or authorise such artificial islands.