 An account that does not appeal to non-disjunctivity, but which uses principles similar to those used in the accounts described above, has been proposed by Denby 2010. (This account is a modified version of an earlier account given in Denby 2006 which takes into account objections made by Hoffman-Kolss 2010b.) Instead of appealing to naturalness or non-disjunctiveness, Denby’s account employs the notion of an object instantiating a property under a relation. Denby, however, gives very little explanation of what this technical notion is meant to mean, and it is therefore not clear what to make of Denby’s account.