 A more fundamental problem concerns the efficacy of the appeal to the active nature of such efforts. In the case of the man who breaks the tabletop, his breaking the tabletop is free (if it is) not just because it results from an active effort to break the tabletop, but because it results (we are to presume) from a free effort to break the tabletop. A successful effort to make a certain choice can contribute in an analogous way to the choice’s being free, then, only if the effort itself is free. If the appeal to these efforts is to accomplish anything, then, what is needed is an account of the freedom with which the agent acts in making these efforts of will (Clarke 2002, 2003a, and 2003b: 89–92; Mele 2006: 51–52).