 There is a further preliminary issue, orthogonal to our discussion, about whether expression-types or expression-instances are what are primarily mass or count. Many hold that mass expressions are ambiguous between mass or count senses depending upon context (e.g., ‘Mary had a little lamb’ could mean she owned one, or ate some (Quine 1960, p. 91)). This question, and the former, can be side-stepped by stipulating, in what follows, that the phrases ‘mass nouns,’ ‘mass terms,’ and ‘mass expressions’ will mean “noun/term/expression occurrences employed with a mass  sense.”[8]