Matthew 13:4
“And when he sowed, some seeds fell by the way side, and the fowls came and devoured them up:”
And great multitudes were gathered together unto him, so that he went into a ship, and sat; and the whole multitude stood on the shore.
And he spake many things unto them in parables, saying, Behold, a sower went forth to sow;
And when he sowed, some seeds fell by the way side, and the fowls came and devoured them up:
Some fell upon stony places, where they had not much earth: and forthwith they sprung up, because they had no deepness of earth:
And when the sun was up, they were scorched; and because they had no root, they withered away.
Counter-Arguments
The strongest case that this verse does not belong in this theme.

Cross-References
“Hear ye therefore the parable of the sower.”
“And when the fowls came down upon the carcases, Abram drove them away.”
“And it came to pass, as he sowed, some fell by the way side, and the fowls of the air came and devoured it up.”
“And he went out from thence, and came into his own country; and his disciples follow him.”