 Against what was suggested above about Frege  (§2),  it has been objected that Frege could not have held an identity theory of truth (Baldwin 1991: 43); the idea here is that, even if he had acknowledged states of affairs as bona fide elements of reality, Frege could not have identified true thoughts with them on pain of confusing the levels of sense and reference. As far as the exegetical issue is concerned, the objection might be said to overlook the possibility that Frege identified true thoughts with facts construed as sense-level entities, rather than with states of affairs taken as reference-level entities; and, as we have noted, Frege does indeed appear to have done just this (see Dodd &amp; Hornsby 1992). Still, the objection raises an important theoretical issue. It would surely be a serious confusion to try to construct an identity across the categorial division separating sense and reference, in particular to attempt to identify true Fregean thoughts with reference-level facts or states of  affairs.[7]  It has been suggested that McDowell and Hornsby are guilty of this  confusion;[8]  they have each rejected the  charge,[9]  insisting that, for them, facts are not reference-level entities, but are, like Fregean thoughts, sense-level  entities.[10]