In 'The Reference Book' (2012), Hawthorne and Manley observe the following contrast between (1) and (2): -/- (1) In every race John won. (2) In every race, the colt won. -/- The name 'John' in (1) must intuitively refer to the same single individual for each race. However, the description 'the colt' in (2) has a co-varying reading, i.e. a reading where for each race it refers to a different colt. This observation is a prima facie problem for proponents of (...) so-called The-Predicativism which is the view that the name in (1) is really a covert definite description, viz. 'the John'. If the The-Predicativism is correct, (1) and (2) are therefore syntactically equivalent, but this makes it mysterious why only (2) would have a co-varying reading. In a recent paper, Fara (2015) argues that there is a simple and elegant way for proponents of The-Predicativism to explain this contrast. This explanation relies on discerning some subtle syntactic differences between (1) and (2) which in turn are based on assumptions about nominal restrictions a la Stanley and Szabó (2000). In this short paper, I demonstrate that Fara's proposed explanation has a variety of serious shortcomings and hence that the contrast between (1) and (2) remains a significant problem for Predicativism. (shrink)