 For example, Jarrett Leplin (2007, 2009) rejects the common view of reliable processes as those that produce a high ration of truths to falsehoods. In its place, Leplin advances a conception of reliability according to which a process/method is reliable if it would never produce or sustain false beliefs under normal conditions (see Leplin 2007: 33: 2009: 34–35). A similar proposal has been developed by Peter Graham (e.g., Graham, 2012, 2020). Graham draws on an etiological account of function due to Larry Wright (1973) and Ruth Millikan (1984), among others, to advance a theory of epistemic entitlement in terms of proper functioning. Then, like Leplin, Graham tries to use a normality approach to address some familiar counterexamples to process reliabilism.