Skylarking refers to the aerial displays including song made by various species of birds, such as Cassin's sparrow (Peterson 1990). Many skylarking displays are in courtship.[citation needed] Some are referred to as territorial displays by the male.[1] There are some instances in which birdwatchers claim that skylarking has been used by male birds to avoid predators; the objective being that the predator will mistake the prey for another type of bird and end the pursuit. This survival tactic rarely works.