According to the phenomenal intentionality research program, a state’s intentional content is fixed by its phenomenal character. Defenders of this view have little to say about just how this grounding is accomplished. I argue that without a robust account of representation, the research program promises too little. Unfortunately, most of the well-developed accounts of representation – asymmetric dependence, teleosemantics, and the like – ground representation in external relations such as causation. Such accounts are inconsistent with the core of the phenomenal intentionality program. I argue that, however counter-intuitive it may seem, the best prospect for explaining how phenomenal character represents appeals to resemblance.