  A third way which purports to deal with the problem of distinguishing on the rule model is to argue that the ‘rule’ for which the decision is binding is not the precedent court's ruling, but something narrower—the ‘material facts’ that were ‘necessary’ for the result of the case. (See Goodhart 1930, 1959; and see also Burton 1995, 25–58, 60–5 on ‘case-specific facts’ and Eisenberg 1988, 51–4 on ‘minimalist’ and ‘result-centred’ techniques.)  This approach makes use of the fact that decisions do not provide canonical formulations of the ratio to argue that the ratio is not to be identified with the court's stated ruling on the issue. The effect of such an approach is to narrow what is regarded as binding in the case to those facts which were crucial to the actual outcome, rather than the stated ruling applied to those facts. The difficulties with this approach are three-fold: