 Katz took nominalism to have been refuted by Chomsky in his critiques of American structuralists in the 1960s. But, in Katz’s opinion, Chomsky had failed to notice that conceptualism was infected with many of the same faults as nominalism, because it too localized language spatiotemporally (in contingently existing, finite, human brains). Since contemporary Minimalist theories share in the earlier ontological commitment, Katz’ argument would presumably extent to them. Through an argument by elimination, Katz concluded that only platonism remained, and must be the correct view to adopt. But this is a false trichotomy and besides predating Devitt’s more philosophically grounded nominalism, it also fails to take linguistic pluralism into account.