 Paul Davies (2001) and Arno Wouters (2005) argue that both Millikan and Neander are incorrect to treat malfunction as an important theoretical or conceptual aspect of the practice of attributing functions by biologists. Wouters declares the wish that the study of biological function should be liberated “from the yoke of the philosophy of mind” (2005: 148). However, Ema Sullivan-Bissett (2017) argues that while the task of explicating biological practice by philosophers of biology is usefully distinguished from the broader goals of philosophers pursuing naturalistic accounts of mind and language (see the entry on  teleological theories of mental content),  the latter serves legitimate goals. She regards an account of malfunction to be integral to the latter project even if not to the former. Davies (2001) argues that the natural selection accounts are unable to provide an account of malfunction insofar as they individuate traits functionally, entailing that a putatively malfunctioning trait is not an instance of the functionally-defined kind. Sullivan-Bissett addresses Davies’ objection by incorporating a structural condition on the individuation of traits. (See also Garson 2016: 48–49, for additional discussion and critique of Davies’ view.) 