Two recent papers have focused on the question of case. Hale in his paper presented at A.N.Z.A.A.S. Congress, 1967, began with a set of hypotheses, proceeded to discuss case and voice in two Australian languages, and was forced to conclude "our initial typological correlation is itself jeopardized." One of his hypotheses was "case is not a property of deep structures." Fillmore in his paper has suggested that "the case notions comprise a set of universal, presumably innate concepts which identify certain types of judgments which human beings are capable of making on the events that are going on around them, judgments on such matters as who did it, who it happened to and what got changed."