In contrast, in the NS and its commentaries, Nyāya philosophers argue that words refer to universals, forms, and individual things. They point out that universals are never instantiated without particular things, and so the universal alone cannot be the referent. But likewise, since universals are identified by form (a cow is recognized as having cowhood by its particular structure), we must also take it into account. Replying to Mīmāṃsā philosophers who defend and refine the universals-denotation view, along with other opponents who defend individual- and form-only views, Nyāya philosophers defend and refine the context-dependent view. Vātsyāyana, for example, in the Commentary on Nyāya (Nyāyabhāṣya, hereafter NBh), argues for an epistemic point, that “It is not known which among these is the object or meaning of the word, or whether all of them might be meant” (NBh 2.2.59; Dasti and Phillips 2017). He takes on arguments from interlocutors who argue that only the individual or the universal is meant by words. Vātsyāyana observes that, to take the example of “cow” again, one never encounters a bare particular (individual). Rather, the individual cow is always found to be qualified by the universal. Ceteris paribus for universals, which do not exist apart from individuals. So it is possible that both universal and particular are meant together, along with form or shape (ākṛti), though in a structured relationship where one is predominant and the others are subsidiary, the particular structure depending on context. See Dasti 2020 for a summary of early Nyāya arguments.