In response to the charge of ontological bias, the Quinean might try to turn the tables on the objector: to take predicates to carry ontological commitment would be to be biased against nominalism. If even ‘∃x Swims(x)’ were committed to properties or universals, no theory would be compatible with nominalism. In any case, the Quinean will reject the charge of ontological bias. Ontological commitment to universals is not excluded by the quantifier criteria; a theory couched in a first-order language whose variables range over universals can be so committed. For example, the sentence ‘∃x∃y (Universal(y) &amp; y=Swim &amp; Instantiates(x,y)’ is committed to universals, as is, more simply, ‘∃y Universal(y)’. The Quinean, then, simply asks that the commitment to universals be made explicit in the same way that the commitment to particulars is made explicit: by quantifying.