 In 1983, Richard took this case to show that our apparent substitution-failure intuitions should be explained pragmatically and not semantically. Otherwise, he thought, we have substitution-failures outside the scope of attitude verbs, which is evidently unacceptable. While (39) may seem true and (41) may seem false, this is because we conflate what an utterance of these sentences pragmatically implicates, suggesting that Sally would accept the complement clause used to report what she believes. This same explanation, Richard insists, should be employed in both Frege’s and Kripke’s puzzles, leading us to Naive Russellianism.