 Such intentions to mislead came to be called sneaky intentions (Grice 1969), and they constituted a problem for speech act analyses based on communicative intentions. The idea was that genuine communication is essentially open: the speaker’s communicative intentions are meant to be fully accessible to the hearer. Sneaky intentions violate this requirement of openness, and therefore apparently they must be ruled out one way or another. Strawson’s own solution was to add a fourth clause about the speaker’s intention that the hearer recognize the third intention. However, that solution only invited a sneaky intention one level up (cf. Schiffer 1972: 17–42; Vlach 1981; Davis 1999).