 Anna Pakes’ view of dance as action is in line with that of Beardsley and Van Camp, against Khatchadourian and Langer. She (2013) agrees that action is a necessary feature of dance. Both Aaron Meskin (1999) and Pakes suggest that it is the embodiment of dance in a physical, intentional event that makes dances better construed as action-structures than as eternal types. It is for this reason (among others) that they find dance to be ill-suited for analysis under a Platonic ontology of art in which the structure of the work of art is discovered rather than created. Sondra Horton Fraleigh (1996) can be placed on Pakes and Meskin’s side here, since she holds that dance is necessarily expressive and transitive action.