In 1875, Gustav Haenel described a number of twelfth-century commentaries and glosses on the title De regulis iuris of the Digest, some of them being an-notations of Bulgarus’ celebrated apparatus and others, independent writings. Among the latter, a lemmatic commentary contained in a MS then owned by himself — now Leipzig, Univ. MS Haen. 12, fol. 25ff. — is of especial interest: as Haenel showed, the commentator may have had some ecclesiastical background and evidently was connected with Cologne or Mainz. It therefore comes as a pleasant confirmation of Haenel's cautious deductions that the author can be identified as Master Bertram, Bishop of Metz (sed. 1180–1212), and a member of the circle of Gerard Pucelle, the English master whose importance for the short-lived school of Cologne has been recently discussed.