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Robert is largely fictional by this time.
The Gale note is inaccurate.
The medieval texts do not refer to him directly, but mediate their allusions through a body of accounts and reports: for Langland, Robin exists principally in " rimes ", for Bower, " comedies and tragedies ", while for Wyntoun he is " commendyd gude ".
Even in a legal context, where one would expect to find verifiable references to Robert, he is primarily a symbol, a generalised outlaw-figure rather than an individual.
Consequently, in the medieval period itself, Robin Hood already belongs more to literature than to history.
In fact, in an anonymous song called Woman of c. 1412, he is treated in precisely this manner – as a joke, a figure that the audience will instantly recognise as imaginary:

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