 Burge (1986b) has argued that causation-based worries about externalist individuation of psychological content, and the introduction of the narrow notion, are misguided. Fodor (1994, 1998) has more recently urged that a scientific psychology might not need narrow content in order to supply naturalistic (causal) explanations of human cognition and action, since the sorts of cases they were introduced to handle, viz., Twin-Earth cases and Frege cases, are either nomologically impossible or dismissible as exceptions to non-strict psychological laws.