 But appearances can be deceiving. The new dispositionalist claims have received some serious criticism, with the majority of the criticisms maintaining that these analyses are still too permissive (Clarke 2009; Whittle 2010; Franklin 2011b). For example, Randolph Clarke argues that Vihvelin’s analysis fails to overcome the original problem with the Simple Conditional Analysis. He writes, “A phobic agent might, on some occasion, be unable to choose to A and unable to A without so choosing, while retaining all that she would need to implement such a choice, should she make it. Despite lacking the ability to choose to A, the agent might have some set of intrinsic properties B such that, if she chose to A and retained B, then her choosing to A and her having B would jointly be an agent-complete cause of her A-ing” (Clarke 2009, p. 329).