 A third position, defended by Ellery Eells (1991), is that neither token nor type causal relations are more fundamental than the other. Eells gives two probabilistic analyses of causation: one for type causation, and another for token causation. Eells thinks that type causal claims cannot just be generalizations about token causal claims because of examples like this: drinking a quart of plutonium causes death, even though nobody has ever drank a quart of plutonium, and so no particular persons’s death has been caused by drinking a quart of plutonium. So this type causal claim cannot be a generalization over token causal claims. (See Hausman 1998: chapter 5, for a response.)