During his fourth prison term, he was awarded the 2010 Nobel Peace Prize for "his long and non-violent struggle for fundamental human rights in China."[10][11][12][13] He is the first Chinese citizen to be awarded a Nobel Prize of any kind while residing in China.[14] Liu is the third person to be awarded the Nobel Peace Prize while in prison or detention, after Germany's Carl von Ossietzky (1935) and Burma's Aung San Suu Kyi (1991).[15] Liu is also the second person (the first being Ossietzky) to be denied the right to have a representative collect the Nobel prize for him.