A notable example is provided by the Tosny family (see the document NORMANDY NOBILITY).
The first post-conquest earldoms were Chester, Hereford, Huntingdon (with Northampton), Kent, Norfolk and Shrewsbury (Shropshire).
As late as 1161, Hawise, widow of William de Roumare Earl of Lincoln, described herself as "Hadewysia comitissa de Rumara".
Suffolk may also have been unavailable as it was already closely associated with the earldom of Norfolk, conceded by King Stephen to Hugh Bigod in [Dec 1140/Jan 1141].
As it turned out, Aubrey became Earl of Oxford, not one of the counties where he held significant amounts of land.
The inevitable conclusion is that the territorial epithet was not considered exclusive at the time.
Reference to these early earls as "Earl in [county]" rather than "Earl of [county]" may therefore more accurately reflect contemporary reality.