 In the secondary literaure discussing the apoha theory, Tillemans (2011) draws a useful distinction between the two versions of the apoha doctrine offerd by Diṅnāga and Dharmakīrti: the top-down approach and the bottom-up approach. The former is presented by Diṅnāga. According to the top-down version, the negation operator in the exclusion, the apoha somehow manages pick out real particulars in the world while avoiding any commitment to universals. Apoha, in this sense functions like a sense or meaning, a not-non X expressed by the word X, which enables us to pick out real particulars while at the same time avoiding a commitment to real universals in virtue of the special features of double negation. The latter is presented by Dharmakīrti who uses the causal approach to link language and the world. According to this version of the doctrine, apoha provides a way to bridge the gap between sensory perception of particulars and expressions of belief and judgement in thought and language. The top-down version of the apoha doctrine was subjected to various criticisms from the Hindu realists, especially by Kumārila who criticised the doctrine on grounds of circularity. The thought is that in order to understand the exclusion class of non-cows, we have to first have an idea that some particulars are cows. In other words, one must be able to refer to cows before one can refer to non-cows. The bottom-up approach developed by Dharmakīrti was basically a response to this circularity worry. His version of the apoha doctrine is developed as a strategy to bridge the gap between non-conceptual perceptual content and conceptual content. Dreyfus (2011) develops Dharmakīrti’s naturalized account of concept formation by elucidating the mediating role of representations that link reality to conceptuality. Representations, in this sense, stand for agreed-upon fictional commonalties and are projected on to discrete individuals (Dreyfus, 2011, 216).