 Tarski’s hierarchical approach has been subject to a number of criticisms. One is that in light of naturally occurring cases of self-reference, his ruling Liar sentences syntactically not well-formed seems overly drastic. Though Tarski himself was more concerned to resolve the Liar for formal languages, his solution seems implausible as applied to many naturally occurring uses of ‘true’. Another important problem was highlighted by Kripke (1975). As Kripke notes, any syntactically fixed set of levels will make it extremely hard, if not impossible, to place various non-paradoxical claims within the hierarchy. For instance, if Jc says that everything Michael says is true, the claim has to be made from a level of the hierarchy higher than everything Michael says. But if among the things Michael says is that everything Jc says is true, Michael’s claims must be at a higher level than all of Jc’s claims. Thus, some of Michael’s claims must be higher than some of Jc’s, and vice versa. This is impossible. It is also difficult to explain what level of the hierarchy an utterance winds up at when it can be coherently assigned a level. What makes it such that it involves truth at one level rather than another?