 Furthermore, Dharmakīrti’s argues that conceptual or judgmental awareness is phenomenologically distinct from non-conceptual awareness. In the latter we are confronted with the object of perception which is vivid and immediate, while in the former no object is present. In the judgment “this is a cow”, even the ‘subject’ of the judgment does not refer to the object of perception, since words do not refer to perceived particulars but to universals which extend across space and time. Dharmakīrti admits that the words we apply to things have some objective basis in those things; we call something a cow because it has a certain effect, it gives milk, is gentle, or it calls forth a certain cognition, etc. This effect, in turn, inclines us to associate the word ‘cow’ with other things that have the same effect and we do that by jointly dissociating them from things that lack that effect. Universals, according to the Buddhists are arbitrarily constructed “exclusions” (apoha); words serve the purpose of separating things off from other objects. For example, the word ‘cow’ singles out a class of things by excluding them from things they are not, all things assembled together under the concept ‘cow’ are distinct from each other and do not share a single nature that the word ‘cow’ names. A conceptual awareness insofar as it imputes a word to a particular object and, therefore a universal nature it shares with all others of the same universal-kind, essentially falsifies the object. Kumārila objects to the Buddhists theory of universals (apoha) on the grounds that it is counterintuitive and circular. The theory of universals (apoha) contradicts our intuition that meaning of a positive word is positive; there is nothing negative about the word ‘cow’. A negative entity can be the meaning of a word only where something is negated. Moreover, if we accept that understanding x requires eliminating non-x, then in turn we presuppose knowledge of non-x, which entails an understanding of non-non-x, and so on (Drefyus, 1997, 215). The Mīmāṃsakas also take on board the concerns raised by the Naiyāyika philosopher Uddyotakara (c. 7th century CE), who questions the theory of exclusions on the specific grounds that it fails to offer an adequate theory of reference and relation between concepts and reality. He argues if the word ‘cow’ primarily designates a negative entity, either this entity is a cow in disguise or is different from a cow. If it is a cow in disguise then the Buddhist view of universals is no different from the Nyāya common sense realism that words are used to single out phenomena in the world. If the negative entity is different from a cow, then the word ‘cow’ does not refer to real cows, making it difficult to explain how any word can refer to real objects or classes thereof. This last point begs the question because the Buddhist denies that words refer to the objects in the real world. For him words refer to universals, and that is precisely what the world does not contain. The onus is put back on the realists to show that universals, which serve as meanings of words, are real properties of objects rather than imagined or mentally constructed features. This challenge is taken up by the Naiyāyikas and their position against the nominalist stand of both the Buddhists and the Grammarians is presented later below.