  Simple Deceptionists include those who defend L1 (Isenberg 1973; Primoratz 1984) as well as those who defend the modified versions of this definition: L2 (Williams 2002), L3 (Mahon 2008), L4 (Newey 1997), and L5 (Lackey 2013). For Simple Deceptionists, lying requires the making of an untruthful statement with an intention to deceive, but it does not require the making of an assertion or a breach of trust or faith.