English gives you two ways to show ownership. "Giuliani's record" or "the record of Giuliani." Both work. Both are grammatically fine. But your brain has a strong preference for which one sounds right, and that preference is measuring something surprising: how alive the noun feels.

The Apostrophe Is an Animacy Test

Linguists call this the animacy effect. The more alive something is, the more naturally you reach for the apostrophe construction. The less alive, the more you default to "the X of Y."

Researcher Mark Liberman ran the numbers in 2008 and returned to update them in 2026, comparing how often people use "X's Y" versus "the Y of X" across enormous text corpora. The ratios tell a clean story.

People score high. Very high. Giuliani's ratio sits at 8.14, meaning for every time someone writes "the record of Giuliani," they write "Giuliani's record" over eight times. Trump comes in at 6.02 in the Corpus of Contemporary American English. McCain at 5.34. Clinton at 4.13. Obama at 3.42.

Your apostrophe reflex knows a person when it sees one.

Companies Land in the Middle

Corporations are animate enough for some apostrophe love, but not human-level love. Apple scores 2.41. IBM 1.73. Microsoft 1.67. Google 1.27.

Apple feels less alive than Giuliani. This makes intuitive sense. Giuliani bleeds. Apple does not. But Apple feels more alive than, say, a country.

Countries drop noticeably. America scores 0.863. Canada 0.443. England 0.227. Your grammar brain apparently ranks corporations above nation-states on the alive-o-meter. One possibility is that companies feel like agents that do things, while countries feel more like territories that contain things.

And Then There Are the Elements

Here is where the data gets genuinely funny. Hydrogen's ratio: 0.0048. Cadmium: 0.0018.

Nobody writes "hydrogen's electron." They write "the electron of hydrogen." The apostrophe practically flinches away from the periodic table.

The gap between Giuliani (8.14) and hydrogen (0.0048) is roughly 1,700 times. That is how powerfully aliveness predicts apostrophe use. The construction you choose is a tiny, automatic judgment about whether something can, in some sense, own things.

God Sits Awkwardly in the Middle

Here is a fun data point. God scores 0.75 in COCA. That puts the divine right between countries and corporations on the animacy scale. Higher than England (0.227), lower than Microsoft (1.67).

The Senate lands at 0.19. Institutional bodies, it turns out, feel almost as inanimate as chemical elements. Your brain is more comfortable saying "the Senate's vote" than "the vote of the Senate," but just barely.

The Apostrophe Is Winning

Here is the broader trend: the 's genitive has been gaining ground on the "of" construction steadily over time, according to the Corpus of Historical American English. English is slowly apostrophe-ing more and more nouns.

And the shift is not uniform. The move toward apostrophes spreads fastest for children, then women, then men. The most human-seeming nouns lead the charge toward apostrophe-land.

This could mean that as written language gets more conversational, we reach for constructions that feel personal and warm. "The plan of God" sounds like a theology textbook. "God's plan" sounds like a bumper sticker. Both correct. One much more alive-feeling than the other.

Your Instinct Was Already Running This Test

Next time you are writing and you pause over whether to use 's or "of," your hesitation is real. You are running a quick animacy check. Is this thing alive enough to own something in the natural, human-feeling way? Or does it need the formal distance of "of"?

The data from millions of texts says your instinct is tracking something true. Giuliani's apostrophe is earned. Hydrogen's is not.

Your grammar knows things your brain never consciously worked out.

Source: Languagelog