As we search for a way to discuss comics and how they work, as we write criticism of comics as an art form, so we clutch for the language in which to describe what we see and read, as a language is not yet decided for us. We need metaphors for the action of comics, since we have not yet agreed on what would not be metaphor. Off the peg, we can reach for the language of film, such as shots, angles, zooms, the camera and so on. But we should bear in mind that this is indeed metaphor, and a metaphor which has not fully been formalised, which may contain disanalogy as well as analogy. We can reach for languages built metaphorically on literature, and on art and on other forms. In proposing functional linguistics as a model for a critical language of comics, as a model for describing how comics function, I am aware I propose a further metaphor; but a metaphor which has been worked through with some care and with consideration for the mapping of appropriate ‘parts’ of language at an appropriate level of description onto the ‘parts’ of comics.