Ergative case can be regarded as one of the main challenges for a standard Case Theory (CT). The most prominent implementations of the CT, which tend to be very influential in the recent years’ generative tradition, are: Inherent Case Theory (ICT) and Dependent Case Theory (DCT). I analyse ergative in Georgian as a dependent case, when ergative is assigned to the higher DP in a clause with transitive verbs, when the lower DP bears an unmarked case. Problematic for this view, however, are two types of verbs which either have no second DP (unergative verbs) or no unmarked case on a second DP (predicates with ergative-dative pairings) that can be counted as a case competitor for assigning ergative. I argue that both these cases involve a covert object in the nominative/absolutive. This view is not uncontroversial cross-linguistically, but I will show that the counter-arguments for the absence of an implicit argument in unergatives’ structure do not hold for Georgian.