 Unlike the more familiar cases, Mendelovici, (2013), does not argue that there actually are such problematic cases. The argument is not that there are actual cases of reliable misrepresentations, but merely that reliable misrepresentations are possible and that this is enough to create trouble for causal theories of mental representation. One sort of trouble stems from the need for a pattern of psychological explanation. Let a mental representation “X” mean intrinsically-heavy. Such a representation is a misrepresentation, since there is no such property of being intrinsically heavy. Such a misrepresentation is, nonetheless, reliable (i.e. consistent), since it is consistently tokened by all the same sort of things on earth. But, one can see how an agent using “X” could make a reasonable, yet mistaken, inference to the conclusion that an object that causes a tokening of “X” on earth would be hard to lift on the moon. To allow such a pattern of explanation, Mendelovici argues, a causal theorist must allow for reliable misrepresentation. A theory of what mental representations are should not preclude such patterns of explanation. Another sort of trouble stems from the idea that if a theory of meaning does not allow for reliable misrepresentation, but requires that there be a connection between “X”s and Xs, then this would be constitute a commitment to a realist metaphysics for Xs. While there can be good reasons for realism, the needs of a theory of content would not seem to be a proper source for them.