 First, Saka (1998, 1999, 2003) has developed a theory that has much in common with Washington’s (though it also differs in important respects). He agrees with Washington in emphasizing ‘quotational use’ (Saka calls it ‘mentioning’), but Saka has more to say about mentioning than Washington has to say about quotational use (see Saka 1998 and 2003). Saka also goes further than Washington in claiming that quotation marks are not required for mentioning even in written language. (For Washington, it is only in spoken language that we can quote without quotation marks). According to Saka, (34) ‘is a grammatical and true sentence’ (Saka 1998, p.118.)