Jung on Values, Part II

Restoring Values

“Because the contemporary scientific attitude is exclusively concretistic and empirical, it has no appreciation of the value of ideas, for facts rank higher than knowledge of the primordial forms in which the human mind conceives them.”[1]

“You have restored for us the idea of value, the concept of human freedom in psychological thought; you have given us certain new ideas that to many of us have been very precious, and above all things you have not relinquished the study of the human psyche at the point where all science ends.”

Dr. H. Crichton-Miller, introducing Jung at his first Tavistock Lecture, 1935[2]

When Carl Jung traveled to London in 1935 to deliver five lectures to 200 medical professionals,[3] he was well known and, as the above quote of Dr. Crichton-Miller indicates, highly regarded for “restoring… the idea of value” to the practice of psychiatry. Eighty-seven years later, Jung’s recognition of the importance of values is even more needed, and, in this second part of the essay on value, I will explain why this is so.

In the first part of this two-part essay, I defined “value,” noted some of its features and offered examples of how Jung’s values were so different from our values today. In this part, I will begin with an examination of the history of late 19th/early 20th century science, toward addressing the questions “Why was “restoring” necessary? What had happened to psychology that sparked Dr. Crichton-Miller’s thanking Jung for “restoring the idea of value?” Then I will consider what “restoring” meant: What had Jung done that his fellow psychiatrists would speak of “the concept of human freedom,” and “the study of the human psyche … where all science ends”? In a final section I will bring the subject up to our own time, noting how Jung’s work, and the values that undergird it, are even more essential now.

Why Was “Restoring” Necessary?–a Brief History of Scientific Developments to 1935

Answering this question requires an overview of eight major developments in our history since the Middle Ages. The nine hundred years from the “fall” of Rome (476 CE)[4] to the time of Petrarch (1304-1374)[5] has often been described as the “Age of Faith,” and in so far as this label refers to a European society focused more on the vertical than the horizontal, it could be an accurate general statement. The orientation of the culture that built hundreds of cathedrals, created intricate stained glass windows of Biblical scenes, and looked toward an afterlife that preoccupied many people was a culture concerned much more with Heaven and Hell than we are today. We can see this difference in the art. Medieval painters were not representational artists: they had no sense of perspective; their figures lack proper proportions (e.g. children are painted just as smaller adults); and their landscapes look flat. Clearly they were not focused on observing the world around them.

“Around them” implies a horizontal focus, and we first begin to see this reorientation in Quattrocento Italy,[6] following pioneering figures like Petrarch, who vividly described a hike he took in the countryside,[7] reflecting an environmental awareness completely lacking in the medieval world. The first component of our brief history is this perceptual shift from an other-worldly concern to a fascination with this world. The Renaissance is more than glorious art and architecture; for our purposes, it marks the first essential development that the other seven built upon: a horizontal focus of inquiry into the nature and workings of this world.

As the “rebirth”[8] spread from Italy over two centuries, it became common for writers to look back with derisive labels, like the “middle” ages (i.e. implying the interval between the glory of ancient Rome and their own day), a “middle” sometimes disparagingly regarded as the “dark ages,”[9]–a time full of superstition, slavish adherence to authorities and priestly warnings, along with fear of Hell. People (men, mostly) began to think for themselves and exult in the potentialities of the human being.[10] Over two centuries (c. 1500-1700) this evolved into an era very much in reaction to anything “medieval”–the era we call the “Age of Reason”[11] or the Enlightenment.

“Reaction” took many forms, from disgust with the credulity of medieval people to the vaunting of rational criticism[12] and conscious efforts to limit the power of the Church.[13] The horror of decades of religious wars and other conflicts that arose in the 16th and 17th centuries led many philosophes to promote deism and even atheism.[14] Supplanting faith in this interval was “reason,” as figures like René Descartes,[15] Baruch Spinoza[16] and Gottfried Wilhelm Leibniz[17] developed philosophical positions that were the beginnings of rationalism, defined as:

“the principle or habit of accepting reason as the supreme authority  in matters of opinion, belief, or conduct; the philosophical doctrine that reason is in itself a source of knowledge, independent of the senses”[18]

Note now who and what are the arbiters of truth: the individual’s mind and his (rarely her, back then) ability to reason the way to what is right.

Descartes is important in our story not only for his emphasis on rationality: he also developed concepts concerning matter and space in ways that later scientists developed into materialism:[19]

“the belief that all action, thought, and feeling can be explained by the movements and changes of matter.”[20]… “any theory emphasizing the existence, priority, or value of matter or material objects;…”.[21]

Much of this was another way to wean inquiry away from the iron hand that religion had had over the schools and the wider culture. Unfettered inquiry and doubt were now prized as ways to promote discovery and invention. The 1600’s were “the century of genius,”[22] according to the 20th century philosopher Alfred North Whitehead–the era of Galileo Galilei,[23] William Harvey,[24] Isaac Newton,[25] Blaise Pascal,[26] Evangelista Torricelli,[27] and Descartes, with inventions like the telescope, the barometer, analytical geometry, and discoveries like the laws of motion, the pumping action of the heart, actuarial science, and the power of science to control Nature.[28] Over 300 years Western man went from ignoring Nature and the world around him to visions of having control over Nature.[29]

Thanks to the investigations of the anatomist Vesalius and the physiologist Harvey, people discovered human anatomy and how it operates, e.g. arms like levers, hearts like pumps–the body is a machine! The 17th and 18th centuries saw the growth of multiple practical inventions[30] as scientific discoveries were turned into useful technologies, and mechanism[31] joined rationalism and materialism as another feature of Western thought.

No figure more clearly embodied the man-as-machine idea than the 18th century French philosopher Julien Offroy de La Mettrie,[32] whose book L’Homme machine (Man-machine) was the “first thoroughly consistent exposition”[33] of the mechanistic image of the human being, reflecting the “growth of materialism”[34] over the century since Descartes defined “the animal as an automaton.”[35] While some folks were put off by the idea of human beings as machines, many scientists appreciated the image for its advantages: machines are predictable, controllable, and reducible to their parts.[36]

The stage was set in the 18th century for the rise and pervasive spread over the next hundred years of three other key components of our story: determinism (“the doctrine that human actions are the necessary results of antecedent causes;”[37]… “free will is … therefore illusory.”);[38] positivism (the main features of which “were an insistence on a scientific approach to the human, as well as the natural world… judged useful by psychology [it] places many restrictions on its subject matter by disparaging metaphysics and mentalism.”[39]); and reductionism (“the theory that life can be understood entirely in terms of the laws of physics and chemistry”[40] and that complex systems, e.g. human bodies, can be investigated by isolating and investigating the various parts).

Jung’s Restoring of the Idea of Value in Psychology

By the time Carl Jung was getting his medical degree,[41] Western science was solidly rooted in rationalism, materialism, determinism, reductionism, mechanistic images of living systems like the human body, and positivism, with its statistical metrics. With science enjoying tremendous prestige,[42] medical education was revised to stress “scientific” behaviors like objectivity:[43] no more personal names or empathic bedside manner–now you refer to patients (i.e. human beings) by the physical problem (e.g. the broken leg in Room 354);[44] and technology: no more squishy things like intuition as the way to diagnose–now you use all manner of machines, the more high-tech the better.

Psychiatrists were not spared the pressure to conform to the standards of scientific respectability, and in the early years of his practice at the Burghölzli clinic, Jung performed many experiments marked by objective, replicable, positivistic, rational methodology.[45] Throughout his life he remained an empiricist leery of metaphysics,[46] but he was also faithful to what he observed in his work with patients.

Always independent in his thinking, once Jung set up his own practice,[47] he began to work, write and teach based on truths as he recognized them: “a truth is a truth when it works,”[48] regardless of scientific orthodoxy. As I noted in Part I, Jung felt there was no place for dogma in science. So, when few psychiatrists, and even fewer men of science were questioning the current dogma, which denigrated “soft”[49] concepts like mentalism, psyche, intuition, consciousness, and values, Jung actively advocated for the reality and importance of these intangibles.

Jung recognized the importance of fantasy, imagination and the irrational. He urged his students to accept the reality of miracles.[50] He felt myths had a central role to play in psychology.[51] He saw the usefulness of regression,[52] and he stressed our human need for introspection and transcendence.[53] He knew how science’s emphasis on logic and statistics led to dangerous one-sidedness:

“This is the fallacy of the statistical picture: it is one-sided, inasmuch as it represents only the average aspect of reality and excludes the total picture. The statistical view of the world is a mere abstraction and therefore incomplete and even fallacious, particularly so when it deals with man’s psychology.”[54]

He recognized scientific materialism for what it really was:

“Scientific materialism has merely introduced a new hypostasis, and that is an intellectual sin. It has given another name to the supreme principle of reality and has assumed that this created a new thing and destroyed an old thing. Whether you call the principle of existence “God,” “matter,” “energy,” or anything else you like, you have created nothing; you have simply changed a symbol. The materialist is a metaphysician malgré lui.” Jung [55]

and he knew, from his work with patients, how rationalism had destroyed their capacity to respond to numinous symbols,[56] and how materialistic psychologies like Freudianism destroyed the transformative power of symbols.[57]

In its emphasis on objectivity, modern science claims to be value-free.[58] Jung recognized human beings’ potential to be both objective (when warranted) and subjective at times. The claim of being value-free is itself a value, and Jung knew that “objective” values also exist:[59] they are those things, qualities or features of life highly esteemed by a society–things like “honesty,” “integrity,” “courage,” “prudence,” “justice,” “temperance” and “fortitude.” None of these can be weighed or counted, but Jung knew this did not mean they were worthless.[60]

Unlike most scientists, Jung recognized the importance of values, especially in the humanistic fields like psychology:

“Values are no anchors for the intellect, but they exist, and giving value is an important psychological function. If you want to have a complete picture of the world you must necessarily consider values. If you do not, you will get into trouble.”[61]

This warning is one that the scientific community all too often ignores. Jung knew that, in his work as a psychotherapist, he could not ignore values:

“The feeling-value is a very important criterion which psychology cannot do without, because it determines in large measure the role which the content will play in the psychic economy. That is to say, the affective value gives the measure of the intensity of an idea, and the intensity in its turn expresses that idea’s energic tension, its effective potential. The shadow, for instance, usually has a decidedly negative feeling-value, while the anima, like the animus, has more of a positive one.”[62]

In working with patients, Jung had to be mindful of just how strongly his patients felt, what they valued, and how the “energic tension” might be utilized to foster growth. Because he never treated any two patients the same way, subjectivity was at the core of his practice as a psychiatrist.[63]

With his keen intuition, Jung knew where our “value-free” science and vaunted technology were heading:

“If science is an end in itself, man’s raison d’être lies in being a mere intellect. If art is an end in itself, then his sole value lies in the imaginative faculty, and the intellect is consigned to the lumber-room. If making money is an end in itself, both science and art can quietly shut up shop. No one can deny that our modern consciousness, in pursuing these mutually exclusive ends, has become hopelessly fragmented. The consequence is that people are trained to develop one quality only; they become tools themselves.”[64]

Human beings as tools–cogs in the wheel of “progress”–a reality that Jung would not consider to be progress at all.

The Importance of Jung’s Psychology for Our 21st Century World

It is now over sixty years since Jung died[65]–more than six decades on and scientism[66] and scientific materialism continue their grip on the practice and thinking of most scientists, but not all of them. Scientists like Willis Harman,[67] Jacob Needleman,[68] and Charles Tart[69] have written eloquently about our need to create an “extended”[70] science which includes important intangible realities like values, so as to counter the destructive impact of scientism. As a psychologist, Charles Tart is particularly explicit about this:

“… most forms of scientism have a psychopathological effect on too many people by denying and invalidating the spiritual or transpersonal longings and experiences that they have. This produces not just unnecessary individual suffering, but also attitudes of isolation and cynicism that worsen the state of the world.”[71]

Since Tart wrote this 13 years ago, things have only gotten worse, the covid pandemic forcing extremes of isolation, and our American political scene extremes of cynicism. Jacob Needleman, professor of philosophy and a fan of science as a child, grew to be alienated from it in college,[72] when it became clear to him that

“…science was a religion being ruined by its priests. There wasn’t any real acknowledgement of wonder, of the sacredness of trying to understand the whole of which we are a part, or the part of which we are whole–either way of putting it. It was geared to reductionism, to explanation, to math, to getting the right answers, to solving the problems, like meaningless intellectual puzzles…. We can say that it lost its heart.”[73]

“Heart,” like “wonder” and “wholes” are intangibles, which have no place in scientism, the degenerate form of modern science. But, as Charles Tart noted, these intangibles are vital to our lives as humans and we ignore (or even worse), disparage them to our detriment.

The late Willis Harman, a Stanford University professor of engineering and then President of the Institute of Noetic Sciences, deemed science as “the knowledge base of our culture,”[74] and, in that regard, he issued a warning in 1988:

“It is impossible to create a well-working society on a knowledge base which is fundamentally inadequate, seriously incomplete, and mistaken in basic assumptions.”[75]

For over a hundred years, this is what we have been trying to do, and Jung would not be surprised at the malaise of our current American situation. It is impossible to have a viable government when it actively works to exclude its citizens from participating in the political process. Nor should we be surprised at the disillusionment and anger in our midst, as cynicism spreads. No society can hope to be healthy when it is riven by hatred and driven by fear. A major restoration of values is essential if we hope to address our current problems and Jung can provide us support in doing so.

**Sue Mehrtens is the author of this and all the other blog essays on this site. The opinions expressed in these essays are her own and do not necessarily reflect the views or opinions of other Jungian Center faculty or Board members.  Honesty, as well as professional courtesy, require that you give proper attribution to the author if you post this essay elsewhere.


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Bacon, Francis (1620), “Novum Organum,” Contemporary Civilization in the West, I, 3rd ed. New York: Columbia University Press.

Bair, Deirdre (2003), Jung: A Biography. Boston: Little, Brown & Co.

Barry, Ellen (2022), “Doctor, Doctor,” The New York Times Book Review (September 25, 2022), 14.

Bothamley, Jennifer (2002), Dictionary of Theories. New York: Barnes & Noble Books.

Brinton, Crane, John Christopher & Robert L. Wolff (1960), A History of Civilization, 2nd ed., 2 vols. Englewood Cliffs NJ: Prentice-Hall, Inc.

Curti, Merle (1973), “Psychological Theories in American Thought,” Dictionary of the History of Ideas, IV. New York: Charles Scribner’s Sons, 1973),

Feigl, Herbert (1973, “Positivism in the Twentieth Century (Logical Empiricism),” Dictionary of the History of Ideas, III. New York: Charles Scribner’s Sons, 1973), 545-551.

Griffin, David (1996), “Postmodern Science,” Revisioning Science: Essays Toward a New Knowledge Base for Our Cuture, ed. S. Mehrtens. Waterbury VT: The Potlatch

Grun, Bernard (1979), The Timetables of History. New York: Simon & Schuster.

Hannah, Barbara (1976), Jung: His Life and Work. New York; G.P. Putnam.

Harman, Willis (1988), Global Mind Change. Indianapolis IN: Knowledge Systems.

Jung, C.G.  (1970), “Psychiatric Studies,” Collected Works, 1. Princeton: Princeton University Press.

________ (1973), “Experimental Researches,” Collected Works, 2. Princeton: Princeton University Press.

________ (1961), “Freud and Psychoanalysis,” Collected Works, 4. Princeton: Princeton University Press.

________ (1956), “Symbols of Transformation,” Collected Works, 5. Princeton: Princeton University Press.

_________(1971), “Psychological Types,” Collected Works, 6. Princeton: Princeton University Press.

_________(1960), “The Structure and Dynamics of the Psyche,” Collected Works (CW) 8. Princeton: Princeton University Press.

________ _(1959), “Aion,” Collected Works, 9ii. Princeton: Princeton University Press.

_________ (1970), “Civilization in Transition,” CW 10. Princeton: Princeton University Press.

_________ (1969), “Psychology and Religion: West and East,” CW 11. Princeton University Press.

________ (1967), “Alchemical Stuides,” CW 13. Princeton: Princeton University Press.

________ (1976), “The Symbolic Life,” Collected Works 18. Princeton: Princeton University Press.

________ (1964), “Approaching the Unconscious,” Man and His Symbols. New York: Dell.

________ (1984), Seminar on Dream Analysis. Princeton: Princeton University Press.

Lammers, Ann Conrad (2007), The Jung-White Letters. New York: Routledge.

Mueller, Fernand-Lucien (1973), “Psychological Schools in European Thought,” Dictionary of the History of Ideas, IV. New York: Charles Scribner’s Sons, 1973, 11-6.

Needleman, Jacob (1996), “Science and Scientism,” Revisioning Science: Essays Toward a New Knowledge Base for Our Cuture, ed. S. Mehrtens. Waterbury VT: The Potlatch

Peters, R.S. (1973), “Behaviorism,” Dictionary of the History of Ideas, I. New York: Charles Scribner’s Sons, 1973), 214-229.

Petrarch, (1960), “The Ascent of Mount Ventoux,” Contemporary Civilization in the West, I, 3rd ed. New York: Columbia University Press.

Pico della Mirandola, Giovanni (1486), “Oration on the Dignity of Man,” Contemporary Civilization in the West, I, 3rd ed. New York: Columbia University Press.

Simon, Walter (1973), “Positivism in Europe to 1900,” Dictionary of the History of Ideas, III. New York: Charles Scribner’s Sons, 1973, 532-539.

Tart, Charles (2009), The End of Materialism. Oakland CA: New Harbinger Publications.

Vartanian, Aram (1973), “Man-Machine from the Greeks to the Computer,” Dictionary of the History of Ideas, III. New York: Charles Scribner’s Sons, 1973), 131-146

Voltaire (1763), “On Toleration.” Contemporary Civilization in the West, I, 3rd ed. New York: Columbia University Press.

[1] CW 6 ¶516.

[2] CW 18 ¶1.

[3] The transcripts of all five lectures are available in CW 18 ¶1-415.

[4]Rome had been under assault by multiple waves of Germanic tribes for hundreds of years before Romulus Augustulus was ousted by Odovacar, the Ostrogoth leader in 476; this displacement is the traditional date of the “fall of Rome;” Brinton et al. (1960), I, 178.

[5]Ibid., 444.

[6] Italian dating conventions label what we term the 15th century as the “fourteen hundreds;” Petrarch was a precursor to the heyday of the Italian Renaissance.

[7] In 1336 he climbed Mount Ventoux, noting the vistas and hardscrabble climbing; Petrarch (1960), 557-564.

[8] The literal meaning of “renaissance,” harking back to the glory that Europeans of the time associated with ancient Rome.

[9] “Dark” in this context has two meanings: the one is given here (the negative term used by the “enlightened” men to contrast their own time with the benighted era before their own), and a more neutral meaning, to refer to the absence of many historical records for the 500-1500 interval, due in part to vandalizing by Vandals and other barbaric tribes, but also because educational levels had fallen so far that few people were able to read, write and thus keep records.

[10] E.g. Giovanni Pico della Mirandola’s “Oration on the Dignity of Man” (1486); the text is available in Pico (1960), 582-587.

[11] Brinton et al. (1960), II, 52.

[12] E.g. Francis Bacon’s acerbic comments on the “inveterate errors” and “vulgar notions” of what had passed for logic up to his time; Novum Organum (1620); portions of the text are available in Bacon (1960), 780-781.

[13] E.g. Voltaire, who lamented how “the monkish superstitions from Rome do nothing but evil;” On Toleration (1763); Voltaire (1960), 1109.

[14] The rise of Protestantism led to wars all over the Continent, and were especially destructive in the territory we now call Germany, where for 30 years (1618-1648) fighting raged between Catholics and Protestants. Voltaire and Rousseau were deists; Bothamley (2002), 140.

[15] French philosopher and mathematician (creator of analytical geometry), 1596-1650; Bothamley (2002), 116.

[16] Dutch philosopher and rationalist, 1632-1677; ibid.

[17] German mathematician (inventor of calculus, along with Newton), 1646-1716; ibid.

[18] World Book Encyclopedia Dictionary, II. 1614.

[19] Bothamley (2002), 332.

[20] World Book Encyclopedia Dictionary, II, 1196.

[21] Bothamley (2002), 332.

[22]Brinton et al. (1960), I, 626.

[23] Italian mathematician, inventor and astronomer (1564-1642); hauled before the Inquisition by the Catholic Church repeatedly for claiming that the sun was the center of the solar system; the Church finally recognized he was right in 1965. Asimov (1982), 105.

[24] English physician, 1578-1657; court physician to the Stuart kings; into medical research, leading him to discover the pumping action of the heart, publicized in 1628; ibid., 110-111.

[25] English scientist and mathematician, 1642-1727; inventor of the calculus (independently of Leibniz) and codifier of the laws of motion, regarded by Isaac Asimov as “the greatest intellect that the world has produced;” ibid., 148-149.

[26] French mathematician and physicist, 1623-1662; ibid., 130.

[27] Italian physicist, 1608-1647; inventor of the barometer; ibid., 191-192.

[28] Brinton et al. (1960), 625-628.

[29] This had been a goal of Francis Bacon, but it took generations of later scientists and technologists to develop information and tools that made this hubristic ambition into our current nightmare of climate change. Jung was aware of both the hubris and the illusion in the idea that we had, or could conquer Nature; CW 18 ¶598.

[30] E.g. the telescope, the compass, the barometer, logarithms, the thermometer, the micrometer, the air pump, the clock pendulum, the balance spring (for watches), the calculus, the high-pressure boiler, the flying shuttle loom, the condenser, electricity, the steam engine, the torpedo, the diving bell, the circular saw, the fountain pen, the hygrometer, the oil burner, the threshing machine, the cotton gin, the telegraph, the hydraulic press–to name just a few technologies and tools; Grun (1979), 267-373.

[31] The term for “the theory that everything in the universe is produced and can be explained by mechanical or material forces…”; World Book Encyclopedia Dictionary, II, 1203.

[32] La Mettrie (1709-1751) corresponded with Thomas Jefferson; Curti (1973), IV, 21.

[33] Vartanian (1973), III, 131.

[34] Ibid.

[35] Ibid., 135.

[36] Ibid.

[37] World Book Encyclopedia, I, 543.

[38] Bothamley (2002), 145.

[39] Ibid., 423; mentalism is defined as the belief that the mind transcends the physiological processes of the brain, i.e. it challenges the core tenet of materialism.

[40] Ibid., 454.

[41] He wrote the thesis for his medical degree in 1901, a year after he began working at the Burghölzli Clinic; Bair (2003), 55, 64.

[42] Simon (1973), 532.

[43] The reform of medical education was the result of the 1910 Flexner Report, created by Abraham Flexner under the aegis of the Carnegie Foundation; https://www.ncbi.nlm.nih.gov

[44] Ellen Barry notes how modern “doctors are desensitized–the nature of their training practically guarantees that.” Barry (2022), 14.

[45] Cf. CW 1 ¶s430-484 and  CW 2 ¶s 1-497, 639-659.

[46] Cf. CW 11 ¶238 and CW 13 ¶356. Ann Lammers notes that Jung was suspicious of theologians for “their tendency to dodge reality and flee into metaphysical realms…often he was angrily impatient with what he saw as the ‘medieval’ frame of mind that could ignore facts, if necessary…”. Lammers (2007), xxv.

[47] He left the clinic in 1909; Bair (2003), 150.

[48] CW 4 ¶578.

[49] As opposed to “hard” concepts and phenomena that are amenable to deterministic, materialistic treatment, i.e. matter.

[50] Jung (1984), 559.

[51] Cf. CW 11 ¶s287, 291 & 292.

[52] Cf. CW 4 ¶406 & CW 8 ¶69.

[53] CW 13 ¶455. In CW 18 ¶555, Jung complains about how modern man “cultivates a remarkable lack of introspection,” a situation that Jung found lamentable.

[54] CW 8 ¶884. .

[55] CW 11 ¶763. The French means “in spite of himself.”

[56] Jung (1964), 84.

[57] CW 4 ¶774.

[58] Griffin (1996), 68.

[59] CW 5 ¶126.

[60] CW 18 ¶23.

[61] Ibid.

[62] CW 9ii ¶53.

[63] Hannah (1976), 202.

[64] CW 8 ¶731.

[65] He died on June 6, 1961; Bair (2003), 623.

[66] I.e. “the tendency to reduce all reality and experience to mathematical descriptions of physical and chemical properties; World Book Encyclopedia Dictionary, II, 1736.

[67] Born in 1918, died in 1997; see bibliography, infra, for his arguments relevant here.

[68] Born in 1934; still living; see bibliography, infra, for his interview discussing science v. scientism.

[69] Born in 1937; still living; his The End of Materialism is a masterful argument relevant here.

[70] For the specific features of an extended science, cf. Griffin (1996), 54-112, and Harman (1988), 92-101.

[71] Tart (2009), 241-242.

[72] Needleman (1996), 28.

[73].Ibid., 28-29.

[74] Harman (1988), 101.

[75] Ibid.