Example (43) crucially holds fixed the outcome of a highly contingent particular fact: the coin outcome. Cases of this kind are discussed extensively by Edgington (2004). Example (44) shows that a chancy outcome is not an essential feature of these cases. Noting the existence of recalcitrant cases, (1979: 472) simply says he wishes he knew why they came out differently. Additional counterexamples to the Lewis’ (1979) System of Weights  have been proposed by Bowie (1979), Kment (2006), and Wasserman (2006).[36] Kment (2006: 458) proposes a new similarity metric to handle this example which is sensitive to the way particular facts are explained, and is integrated into a general account of metaphysical modality in Kment (2014). Ippolito (2016) proposes a new theory of how context determines similarity for counterfactuals which aims to make the correct predictions about many of the above cases.