 (The example is from Quine 1953.) ‘Giorgione’, as it occurs in (9), simply refers to the man Giorgione. But substitution is illegitimate because ‘so-called’ refers to the expression preceding it and not merely the referent of that expression. So, substitution fails but not because the substitution affects the reference of the terms. Rather, substituting ‘Giorgione’ with the co-referring ‘Barbarelli’ in (9) affects the reference of ‘so’ in ‘so-called’. (This differs from Quine’s own explanation of why substitution fails in (9).)