 What is crucial to making sense of contingent identity is an acceptance that modal predicates are inconstant in denotation (that is, stand for different properties when attached to different singular terms or different quantifying expressions). Counterpart theory provides one way of explaining this inconstancy, but is not necessarily the only way (Gibbard 1975, Noonan 1991, 1993). However, whether the examples of contingent identity in the literature are persuasive enough to make it reasonable to accept the certainly initially surprising idea that modal predications are inconstant in denotation is still a matter of considerable controversy.