 Use theories, like cluster theories, can be seen as open-ended in what counts towards reference (I was careful to allow for this in the general statement at the end of the previous section). Even an open-ended cluster theory can issue in ceteris paribus claims such as: if these are the only considerations operating in the case, then the reference is to so-and-so. In use theories, this open-endedness crops up (at least) in the choice of precedent; so that the best we might say, in some cases, is: if we fix the precedent like this, then the reference is to such-and-such. Though we are certainly not at a loss in deciding the proper precedent for any particular case, it is difficult to say in general and with precision which applications should count. Evans’ invocation of a name-using practice is too vague to guide us in concretely described cases, and Kripke explicitly disclaims that he is providing a prediction-making theory of nominal reference.