Note 79 — BOOK IX NOETUS, CALLISTUS, AND OTHERS
Francis Legge translation
Döllinger (op. cit., p. 158) suggests that this is a reference to the contubernium, or concubinage known to Roman Law, which the Church insisted on regarding as a lawful marriage. The case of Marcia mentioned above might be one in point, but it is to be noted that Hippolytus calls her παλλακὴ Κομόδου only.