 The notion of practical modes of presentation has received several criticisms (Schiffer 2002; Koethe 2002; Noë 2005; Fantl 2011; Glick 2015), on the ground that it seems excessively obscure or even question begging. Koethe (2002: 327) worries that practical modes of presentation smuggle in an antecedent notion of knowledge-how (though see Fantl 2008: 461 for a response). This widespread skepticism about practical modes of presentation has led some intellectualists to explore ways of responding to the insufficiency objection that do not appeal to practical modes of presentation. For example, Stanley (2011b: 126) considers answering the sufficiency challenge in Swimming by appealing to the context-sensitivity of the ability modal “could”. According to Stanley, depending on how the context for the modal is restricted, “That is how you could swim” could mean either that that is how you can swim given your current physical state or that that is how you could swim after training. But coming to know that that is how I could swim after training is clearly not enough for me to come to know how to swim now. Instead, the argument goes, what one needs to know is the former proposition: that that is a way to swim given my current physical state.