 The Fodor and Sag argumentation was taken up in the philosophical literature by King (1988) and Ludlow and Neale (1991), who argued that there is a confusion in the Fodor and Sag discussion. Kripke’s claim, of course, was that referential uses of a description are a function of pragmatics, not quantifier scope. Nor, of course, could a referential use be associated with wide scope, as Kripke (1977) argued forcefully—they simply are not the same phenomenon. The problem is that the Fodor and Sag arguments do not address the pragmatic account of referential uses, which of course was the alternative advanced by Kripke.