 Theorists who sought to avoid this alleged fallacy held that a penny might appear elliptical in a phenomenally direct way without an elliptical item being present to the mind. These are sometimes known as “appearance theories”. One such position is the adverbial analysis, which holds that phenomenal qualities inhere in the mental activity of perceiving but without being present as objects or as property-instances. Accordingly, we perceive the penny itself, but perceive it in a certain manner: roundly, or elliptically, and redly (Ducasse 1942; Chisholm 1957: part 3). To say that we are experiencing the penny elliptically is to say that we enjoy an elliptical appearance without there being an actually elliptical item present to us; rather, the appearance is understood simply as our manner of sensing the penny, or as the way our sensory activity makes us experience the shape of the penny. A related sort of appearance theory renders the elliptical appearance as a mental content, or an intentional state, with the contents elliptical and red (Barnes 1944–1945). Accordingly, via intentional content, one can experience an elliptical spatial structure without being acquainted with an actually elliptical object. The intentional content instantiates an appearance as a state of the perceiver, whose perceptual experience thereby represents the world as being a certain way, for instance, as containing an elliptical shape. (Intentionalist theories are found in Dretske 1995 and Tye 1995; an important earlier formulation is Anscombe 1965.) These two types of theories account for Variation and Illusion via adverbial or intentional contents that can also account for veridical cases of perception. Indeed, these theories can allow that, in some instances (with moderate slant), we see a penny that is round by seeing it as being round and slanted relative to the line of sight. Adverbialists would say that we see the penny roundly; intentionalists, that we see the penny via mental content that represents it as being round. (On these philosophies of perception, see Crane &amp; French 2015 [2021].)