Nest build fresh nests daily out of leaves and other vegetation in which they sleep at night. They sometimes also build nests during the day for resting in. The smaller species of gorilla build their nests in trees, while the larger are confined to the ground. Nests of the western gorilla, the largest species, measure about in diameter. Some species of frog build nests ranging from simple to modest complexity. Many stream-dwelling frogs lay their eggs in a gelatinous mass which they attach to underwater vegetation. The jelly structure prevents the eggs from washing away. Fish engage in nest building activities
Nest-building in primates together a loose selection of branches. They may also make a "bunk-nest" or "bunk-bed", a few metres above the main nest. A study on the phylogeny of primate behaviour has revealed that the use of tree holes or nests are important in the life-history strategies of many strepsirrhine species and some New World monkey species. Alternative strategies of infant care which involve carrying the infants rather than leaving them, have evolved several times but have reproductive costs and generally slower rates of population increase than species which build nests. Use of nests for leaving young is thought to have evolved