 The fourth set of problems for the counterfactual test has to do with the test’s underinclusiveness, mostly exhibited in legal theory in the well-known overdetermination cases. These are cases in which each of a pair of two events, c1 and c2, is independently sufficient for some third event e. Logically, the sufficiency of c1 and of c2 entails that neither c1 nor c2 is individually necessary for e, and thus, on the counterfactual analysis of causation, neither of them can be the cause of e. The law uniformly rejects this conclusion (howevermuch some philosophers such as David Lewis have claimed uncertainty in their own intuitions about there being causation in such cases), so such cases pose a real problem for the counterfactual analysis of causation in law.