 Philosophers have not argued by direct appeal to NI or ND. Typically, (e.g., Gibbard 1975, Noonan 1993, Johnston 1992), arguments that \(c\) and \(s_1\) are not identical run as follows: \(c\) exists prior to the existence of \(s_1\) and hence the two are not identical. Again, \(s_1\) possesses the property of being such that it will be destroyed by being squeezed into a ball, but \(c\) does not possess this property \((c\) will be squeezed into a ball but it will not thereby be destroyed). So again the two are not identical. Further, whatever the future in fact brings, c might have been squeezed into a ball and not destroyed. Since that is not true of \(s_1\), the two are not identical. On a careful analysis, however, each of these arguments can be seen to rely on NI or ND, provided one adopts the standard account of modal/temporal predicates. This last proviso suggests an interesting way out for one who adheres to the standard account of identity but who also holds that constitution is identity (see below).