 One worry for this response is that it cannot account for apparent non-modal differences between Lumpl and Goliath. For example, Kit Fine (2003) argues that Lumpl, but not Goliath, might be well-made, and that Goliath, but not Lumpl, might be Romanesque. Since these are not modal ascriptions, counterpart theory has no application. As a result, it is unclear what the temporal parts theorist is to say about apparent differences of this sort. (For more on this issue, see the exchange between Fine 2006, Frances 2006, and King 2006.)