a Structure Note can make use of a TOC form, a normal table, a mind map, a flow diagram, a straight list, or even a picture.

I make a habit of outlining chapters in Obsidian as it allows me to structure them with indented bullet points, and to link individual bullet points to supporting notes, including notes on original sources. I also make the bullet points into checkboxes, so I can check them off as I make my way through the outline as I’m drafting the actual chapter.

In discussing the various ways Luhmann referenced his notes, Schmidt discusses specific notes created by Luhmann that appeared to produce "larger structural outline[s]."8 It seems, when beginning a major line of thought, Luhmann created a note that resembled "the outline of an article or table of contents of a book."9 Today, many call these outline notes "structure notes," a term which has come to prominence through its usage on the zettelkasten.de forum.