 If one endorses only an aesthetic condition, and not a tonality condition, one still faces the problem of poetry—non-musical aesthetically organized sounds. Levinson, who takes this approach, excludes organized linguistic sounds explicitly (1990a). This raises the question of whether there are further distinctions to be made between arts of sound. Andy Hamilton defends a tripartite distinction, arguing that sound art, as opposed to both music and literature, was established as a significant art form in the twentieth century (2007: 40–65). This is one reason that Hamilton endorses both tonal and aesthetic conditions on music; without the former, Levinson is unable to make such a distinction. On the other hand, by endorsing an aesthetic condition, Hamilton is forced to exclude scales and Muzak, for instance, from the realm of music. Kania (2013a) suggests that it is a mistake to think that music is necessarily an art, any more than language. He argues that we should distinguish music simpliciter from its artistic uses, just as we do in the cases of language and literature, depiction and painting, and so on. By means of a disjunctive condition, Kania also adds a further distinction to Hamilton’s set. Kania argues that music is 