 If, unlike Kripke, we start with the idea that linguistic reference is, at root, the result of an act, of something that we do rather than something that words themselves do, then definite descriptions start to look more like the normal case and indexicals like the outlier. This is, in fact, an old idea, one that dates back to Susan Stebbing (1943) and the later work of Ludwig Wittgenstein (1958), and which we already saw running through the ideas of Grice, Strawson, and  Donnellan.[14]  The enduring worry, of course, is that without some restrictions on how we can use terms to successfully refer, we will divorce the theory of reference from both our intuitions on cases and from any role in an overall theory of communication. But if we embrace certain limits on referential success—to be imposed by either Gricean reflexivity, conventionalized constraints, or both—these worries can plausibly be avoided. And, indeed, with respect to definite descriptions the case for there being a conventionalized constraint on referential success, as Strawson took there to be, can look particularly appealing.