 There is a reading of (8) where ‘she’, as it occurs in (8), is anaphoric on ‘Jill’; that is, ‘she’ is anchored to ‘Jill’, in the sense that the reference of the former is inherited from the reference of the later. ‘Jill’, as it occurs in (8), is outside the scope of a propositional attitude verb and hence has its customary reference. So, then, it would seem, ‘she’ must also have the customary reference of ‘Jill’ and hence must refer to an individual and not a sense. This runs contrary to Frege’s reference-shift claim. More generally, Frege’s theory seems to have trouble accounting for the truth of sentences like (8), as ‘she’ (for example) seems to simply pick out Jill herself independently of any mode of presentation. (Sentence (8) tells us nothing about how Jack represents Jill.) Soames 1989 presents a similar argument against the Fregean solution, although he does not use it to argue for semantic innocence directly. The point is related to the more general worry that Fregean accounts cannot offer an adequate account of de re belief. (See the supplementary document on 