This paper criticizes Ko's (2007) CL analysis of scrambling. Against her analysis, according to which a case-less numeral quantifier and its host NP comprise a constituent, I adapt Miyagawa's (1989) mutual c-command analysis in tandem with the current minimalist framework (Chomsky 2005), and propose that they do not form a constituent but do enter into an ana-phoric relation. On the other hand, with Ko's (2007) analysis of vP as a Spell-out domain subject to criticism, I show that there are some serious theoretical problems with it. It should be noted that this criticism would apply to Fox & Pesetsky's (2005a) original proposal. Consequently, I will show that the intriguing phenomena observed by Ko (2007) can be reasonably accounted for in the way proposed in this paper
