It is not difficult to avoid this conclusion, as Mele (1997, 2003: Ch. 9, 2009b) has shown. Consider again the central case of decision-making, and assume that making a decision consists in the formation of an intention. According to the standard theory, the formation of an intention is an action if it is an intentional action under some description (or if it is either identical with or generated by an intentional action; see section 2). What could plausibly be the agent’s intention in making a decision? Mele suggests that processes of decision-making are usually motivated by the intention to settle the practical question at hand. This proposal avoids the problem outlined above. Suppose the agent decides to A. For this to be an action, it is not required that the agent has the intention to decide to A. For if the agent has the intention to settle the question by making a decision, making the decision is intentional under a description. In particular, making a decision is then an intentional action and making the decision to A is then an unintentional action (that is either identical with or generated by the intentional action of making a decision).[10] Similar considerations apply to the mentioned issue concerning reason explanation and to other cases, such as remembering. Mele (2009b) argues that remembering something is never an intentional action, because no one has ever the intention to remember the particular content in question. But there is nevertheless a closely associated intentional mental action that one might perform: intentionally trying to bring it about that one remembers the particular content in question. See Shepherd (2015) for a defense of the view that decisions are intentional actions by construing them as extensions and conclusions of deliberative activity.