udyotakarastvāha gavādiṣvanuvṛttipratyayaḥ piṇḍādivyatiriktānnimittādbhavati, viśeṣakatvān nīlādipratyayavat / tathā goto 'rthāntaraṃ gotvaṃ, bhinnapratyayaviṣayatvād rūpasparśādivat, tasyeti ca vyapadeśaviṣayatvādyathā caitrasyāśva iti caitrādvyatirekeṇa vyapadiśyamāna iti /
But Udyotakara says: "The notion that persists in all cows arises from a cause distinct from the body etc., because it is a differentiator, like the notion of blue etc. Similarly, cowness is something different from a cow, because it is the object of a different notion, like color and touch etc., and because it is designated as 'of that [cow]', just as a horse is designated as 'Caitra's horse' [and is] distinct from Caitra."