While the force of Hempel's dilemma against theory-based conceptions of the physical remains contested, alternative "non-theory-based" conceptions of the physical have also been proposed. Frank Jackson (1998) for example, has argued in favour of the aforementioned "object-based" conception of the physical. An objection to this proposal, which Jackson himself noted in 1998, is that if it turns out that panpsychism or panprotopsychism is true, then such a non-materialist understanding of the physical gives the counterintuitive result that physicalism is, nevertheless, also true since such properties will figure in a complete account of paradigmatic examples of the physical.