Either Phillips is fronting the surprising opinion that generative theorizing has never been led down the wrong track by demonstrably unreliable data, or he is changing the subject. And unless clear criteria are established for what counts as “damage” and “holding back,” Phillips is not offering any testable hypothesis about data collection methodology. For example, Phillips discounts the observation of Schütze (1996) that conflicting judgments of relative unacceptability of violations of two li