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Contexts aren't useful for reference items. So if I want to store reference items in OF then I have to artificially set a context.

For actions, there are some where a context just isn't that meaningful to me. For instance, an action to call someone or do something that requires my computer. I'm never that far from either, so to set a context of Phone or Mac isn't that useful to me. I'm never going to view a list of all my Phone actions or all my Mac actions to determine what to do next. Instead I'll use some other criteria, such as project or due date.