In Gollihar v. State, 46 S.W.3d 243, 254-255 (Tex. Crim. App. 2001), the Court addressed the sufficiency implications of a variance between the indictment and the evidence at trial. The Court held that, under the hypothetically correct jury charge, "only a 'material' variance will render the evidence insufficient." In arriving at this holding, we discussed two purposes of the doctrine against variances: notice and jeopardy preclusion - an indictment should give the defendant enough notice of the crime to allow him to prepare an adequate defense at trial and it should preclude the defendant from being prosecuted later for the same crime. The variance at issue in the case was the difference between the go-cart model number alleged in the indictment and the number proved at trial. In holding that the variance was not material, we remarked that the State was not required to plead the model number and that the defendant's defensive theory was not impacted by the variance. The Court also held that the variance would not place the defendant in danger of being prosecuted again for the same offense. The Court stated that a variance is material if it is "prejudicial to a defendant's 'substantial rights.'" The Court explained that, to determine whether a defendant's substantial rights are prejudiced, we consider "(1) whether the indictment . . . informed the defendant of the charge against him sufficiently to allow him to prepare an adequate defense at trial, and (2) whether prosecution under the deficiently drafted indictment would subject the defendant to the risk of being prosecuted later for the same crime." The important part of that statement for our purposes is part (2): A variance is material if a prosecution under the deficiently drafted indictment would subject the defendant to the risk of being prosecuted later for the same crime. Of course, Gollihar did not make this up. The Court said essentially the same thing many times before Gollihar, at least as far back as 1910 in Rowan v. State. 57 Tex. Crim. 625, 124 S.W. 668, 673 (1910) there the Court stated, "A variance is not now regarded as material unless it is such as might mislead the defense, or might expose the accused to the danger of being put twice in jeopardy for the same offense." The Court of criminal appeals overruled Curry, Burrell, and surplusage law because of the "inconsistencies between the Burrell v. State exception and the fatal variance doctrine." Id. at 257. Including the deadly weapon special issue is an allegation of non-statutory fact of the type discussed in Judge Kellers's concurring opinion in Fuller v. State, 73 S.W.3d 250, 256-57 (Tex. Crim. App. 2002). Whether the State has an obligation to prove such an allegation depends on whether the allegation is necessary for an adequate description of the particular offense for which the defendant was tried. Id. at 256. Under the rule adopted in Gollihar, that necessity turns on considerations of notice and double jeopardy and is evaluated through the material variance test. Id. Thus, the Court must consider whether the indictment, as written, informed the defendant of the charge against him sufficiently to allow him to prepare an adequate defense at trial, and whether prosecution under the deficiently-drafted indictment would subject the defendant to the risk of being prosecuted later for the same crime. See Gollihar, 46 S.W.3d at 257.