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A quite popular approach to solving the Causal Exclusion Problem is to adopt a counterfactual theory of causation. In this paper, I distinguish three versions of the Causal Exclusion Argument. I argue that the counterfactualist approach can block the first two exclusion arguments, because the Causal Inheritance Principle and the Upward Causation Principle upon which the two arguments are based respectively are problematic from the perspective of the counterfactual account of causation. However, I attempt to show that the counterfactualist approach is unable to refute a sophisticated version (i.e. the third version) of the exclusion argument in that the Downward Causation Principle, a premise of the third exclusion argument, is actually implied by the counterfactual theory of causation. Therefore, even if other theories of causation might help the non-reductive physicalist to solve the exclusion problem, the counterfactual theory of causation cannot.