section above. However, there is a middle path possible between these two extreme positions that allows for the existence of both physical and mental actions. Various mental events have been suggested as candidates for non-physical actions, like imagining, judging or remembering. One influential account of mental action comes from Galen Strawson, who holds that mental actions consist in "triggering the delivery of content to one's field of consciousness". According to this view, the events of imagining, judging or remembering are not mental actions strictly speaking but they can be the products of mental actions. Mental actions, in the strict sense, are prefatory or catalytic: they consist in preparing the mind for these contents to arise. They foster hospitable conditions but cannot ensure that the intended contents will appear. Strawson uses the analogy of jumping off a wall, in which the jumping itself (corresponding to the triggering) is considered an action, but the falling (corresponding to the entertaining of a content) is not an action anymore since it is outside the agent's control. Candace L. Upton and Michael Brent object that this account of mental actions is not complete. Taking their lead from mental activities taking place during meditation, they argue that Strawson's account leaves out various forms of mental actions, like maintaining one's attention on an object or removing a content from consciousness. One reason for doubting the existence of mental actions is that mental events often appear to be involuntary responses to internal or external stimuli and therefore not under our control. Another objection to the existence of mental actions is that the standard account of actions in terms of intentions seems to fail for mental actions. The problem here is that the intention to think about something already needs to include the content of the thought. So the thought is no longer needed since the intention already "thinks" the content. This leads to a vicious regress since another intention would be necessary to characterize the first intention as an action. An objection not just to mental actions but to the distinction between physical and mental actions arises from the difficulty of finding strict criteria to distinguish the two. Related concepts Deliberation and decision Deliberations and decisions are relevant for actions since they frequently precede the action. It is often the case that several courses of action are open to the agent. In such cases, deliberation performs the function