 Other aspects of the systems approach make philosophers wary. (See, especially, Armstrong 1983, 66–73; van Fraassen 1989, 40–64; Carroll 1990, 197–206.) Some argue that this approach will have the untoward consequence that laws are inappropriately mind-dependent in virtue of the account’s appeal to the concepts of simplicity, strength and best balance, concepts whose instantiation seems to depend on cognitive abilities, interests, and purposes. The appeal to simplicity raises further questions stemming from the apparent need for a regimented language to permit reasonable comparisons of the systems (Lewis 1983, 367.) More recently, Roberts questions the systems approach at a point sometimes thought to be a strength of the view: “We have no practice of weighing competing virtues of simplicity and information content for the purpose of choosing one deductive system over others, where all are presumed to be true” (2008, 10). There is the practice of curve-fitting, which involves weighing the competing virtues of simplicity and closeness of fit, but this is a practice that is part of the process of discovering what is true. Also, the systems approach is ill-suited to rule out widespread and striking regularities as laws, even those that are clearly determined by the initial conditions. That the universe is closed, that entropy generally increases, that the planets of our solar system are co-planar, and others (if true) could be added to any true deductive system, greatly increasing the strength of the system, with only a small cost in terms of simplicity (Maudlin 2007, 16; Roberts 2008, 23). Interestingly, sometimes the systems view is abandoned because it satisfies the broadly Humean constraints on laws of nature; some argue that what generalizations are laws is not determined by local matters of particular fact. (See Section 4 below.) Though Humeans like Lewis generally favor realism to any form of anti-realism (Section 5 below), Berenstain and Ladyman (2012) have argued that scientific realism is incompatible with Humeanism because realism requires a notion of natural necessity not susceptible to Humean analysis.