The history of predation on shelled marine invertebrates is an important part of our reconstruction of ancient ecosystems and evolutionary paleoecology (Kowalewski et al., 1998; Harper et al., 1999). One of the primary puzzles is the earliest appearance of drilling predation. There are small round holes in Cloudina skeletons of the Late Precambrian (Bengston and Zhao, 1992), and similar small holes in Cambrian brachiopod shells (Conway Morris and Bengston, 1994) which may be predatory, but the earliest post-Cambrian predation drillholes are thus far in the Devonian (see Leighton, 2001, and references therein). Thus, the status of Ordovician predatory boring is of considerable interest to paleoecologists because the record here is at best equivocal. Kaplan and Baumiller (2000, p. 508) conclude that a set of holes in Late Ordovician brachiopod shells is the product of''''mixed-motive boring''''with the borers'''likely including predators.''''We believe that these holes were pro-duced by boring organisms with a single motive, that of excavating domiciles which occasionally passed through dead shells. These holes are not predatory borings and, thus, not part of the history of drilling predation in the Phanerozoic. The explanation of these holes as dwellings is simpler than the''''mixed-motive''''concept, because it in-volves fewer ad hoc hypotheses and is a better explanation of all the evidence. The bored brachiopods Kaplan and Baumiller (2000) studied are from the Onniella epibole (Frey, 1997) in the Waynesville Formation (Richmondian) of the Cincinnatian Series in southeastern Indiana. These borings, which are primarily in the orthid Onniella meeki, were examined by Fenton and Fenton (1931), Bucher (1938), and Cameron (1967), all of whom concluded that they were produced by gastropods. Carriker and Yochelson (1968) and Richards and Shabica (1969), however, presented compelling evidence that the borings actually were excavated in dead shells by borers to form dwelling places. Kaplan and Baumiller (2000, p. 502) accept this conclusion, in part, stating that while most of the borings are non-predatory, there has been a''''masking effect''''whereby predatory borings (10-15% of the total) have been obscured; thus, the''''mixed-motive''''model. It is useful to review the evidence Kaplan and Baumiller (2000) present to support the non-predatory nature of