 The Naiyāyikas also have a general response to nominalists—Buddhists as well as Grammarians. They posit monadic universals that correspond to natural and metaphysical kinds and one dyadic universal, viz. inherence. The main nominalist objection is that once we accept real universals in our ontology we risk overpopulating the world with entities corresponding to every expression that designates a property. For example, if we accept horsehood and cowhood as universals, we also need to accept universalhood as another universal. The Naiyāyikas propose that not every expression which designates a property generates an objective universal (jāti); some property-expressions correspond to subjectively constructed categories (upādhi), which though useful for analysis, are not ontologically real. Uddyotakara argues that to correspond to a real universal a general term must meet two conditions: (i) a general term should be based on a ground, which accounts for the common awareness of a number of different objects, that makes the application of the term possible, and (ii) that ground should be a simple (non-compound), unitary property or entity that cannot be analyzed or explained away otherwise (Commentary on Nyāya-sūtra, 2.2.65). Universalhood is a bogus universal; it violates the second condition. There is no simple basis or ground for universalhood as opposed to universals such as cowhood and horsehood; the ground of being one-in-many can be analyzed in terms of inherence. The same applies to universals like ‘barefooted’, ‘cook’, ‘reader’ etc.; the basis for their application is presence of compound features such as bare feet, etc. However, this stratagem forces the Naiyāyikas to admit that many general terms designate bogus universals and, consequently, they start succumbing to the nominalist pressure. Matilal (1986, 420–421) notes that there is another way in which it happens to Navya-Nyāya: A real universal must partake of the nature of ‘one-in-many’. The Navya-Naiyāyika, Udayana (c. 10th century CE), lists a third necessary condition for disqualifying a property from being regarded as a real universal. Under this condition, an abstract property that belongs only to one individual is also a bogus universal even though it is simple and unanalyzable; skyness in the sky is bogus because it is only a nominal attribute. However, since both cowhood and skyness are simple properties, they are grasped as such in perception without further qualification. In this sense, Naiyāyikas maintain that some real universals are directly perceptible. When we see a cow, we do not necessarily see ‘it’ as a ‘cow’, the cow and the cowness are not given as separate entities in our awareness, rather they appear fused. This leads to the peculiar Nyāya view that real universals and basic properties are grasped in our awareness as ‘epistemic firsts’ or ultimates (Matilal, 1986, 421). Gaṅgeśa calls such perception, in which universals are grasped as such, non-conceptual (nirvikalpaka) perception.