It has been suggested that (i) Daoxuan (道宣), (ii) Yuanzhao (元照) and (iii) the Huayan school (華厳) may have influenced the formulation of Gyonen's (凝然) conception of the Precepts.
(i) Insofar as the Three Undefiled Precepts are seen to bring about the Three Buddha Bodies, Gyonen's understanding of the Precepts is in accord with that of Dao-xuan; however, Gyonen does not limit his account to a mere decription of Daoxuan's position.
(ii) Gyonen shares in common with Yuanzhao the view that the causal relationship between the Three Precepts and the Three Buddha Bodies may be extrapolated to other triadic Buddhist formulae. However, it can be seen that Gyonen does not adopt the same triadic formulae which Yuanzhao uses, choosing instead to follow Fazang's (法蔵) commentary on the Awakening of Faith (起信論).
(iii) However, apart from the commentary on the Awakening of Faith, Gyonen does not draw upon the Huayan school elsewhere to explain the Three Precepts, thus making it impossible to definitively assert the overall influence of Huayan thought upon Gyonen's conception of the Precepts.
All of this would suggest that these none of these three possible candidates can be properly determined as precedents for Gyonen's formulation. Rather, Gyonen would seem to draw predominantly upon the Tathagatagarbha doctrine in the formulation of his conception of the Precepts; Fazang's commentary on the Awakening of Faith is utilised as a means of providing him with the authority to do so.