 For their part, anti-realists have taken the metaphysical realist’s insistence on a Right Reference Constraint to be ‘just more theory’—what it is for a model to conform to a constraint is for us to be justified in asserting that it does. Unfortunately, this has led to something of a stand-off. Metaphysical realists think that anti-realists are refusing to acknowledge a clear and important distinction. Anti-realists think realists are simply falling back on dogmatism at a crucial point in the argument.