 The overinclusiveness of the test has mostly been raised in cases of coincidence. Suppose a defendant culpably delays his train at t1; much, much later at t2, and much further down the track, the train is hit by a flood (Denny v. New York Central RR). Had the delay at t1 not occurred, there would have been no damage or loss of life at t2. In this case, the counterfactual test yields the unwelcome result that the defendant’s delaying caused the harm. Such cases of overt coincidences are rare, but they are the tip of the iceberg here, in that innumerable remote conditions are necessary to the production of any event. Oxygen in the air over England, timber in Scotland, Henry VIII’s obesity, and Sir Francis Drake’s perspicuity, were all probably necessary for England’s defeat of the Spanish Armada; but we should be loath to say that each of these was a cause of that defeat. The problem is greatly exacerbated by the admission of omissions as causes: the Spanish Armada was also defeated because Martian spaceships didn’t show up to help them.