 A more promising approach to understanding the fiction/non-fiction distinction focuses not on semantic notions or stylistic features, but on the author’s inventiveness in producing a text, whatever its semantic or stylistic character. The best known such account is Harry Deutsch’s “fiction as making up stories” (Deutsch 2000, 2013). Deutsch insists “we cannot be left without a sharp distinction between fact and fiction” (2000: 149) even if we think, as Goodman did, that facts are themselves fabricated. Crucial to the notion of fiction, he thinks, is that, unlike fact, it is the product of creative, imaginative activity on the author’s part, activity in which the author makes something up “out of whole cloth”. His own distinctive take on this view explains the kind of fabrication involved in fiction-making as the author’s stipulatively ascribing properties to individuals, but where these properties match properties possessed by pre-existing objects from the “fictional plenitude”, a domain that contains not only every conceivable object and event but also an enormous range of impossibilities (Deutsch 2000: 155–6). 