Although there are many philosophers responsible for introducing phenomenology to philosophy departments in the United States and United Kingdom (e.g. Charles Taylor and Richard Rorty), arguably none has been as broadly influential as Hubert Dreyfus (1929–2017). It may not be too much of an exaggeration to claim (as some have; see Kelly, 2005), that the reading of Heidegger taught in most philosophy departments in the English-speaking world is some descendent of Dreyfus’s Heidegger—or “Dreydegger” as it is sometimes called. This portmanteau is at once a term of endearment and of derision. The union of the two thinkers represents some of the best of Dreyfus’s personal contributions to philosophy: the willingness to look to philosophical texts of the past for insights that can help untangle current theoretical problems; and the boldness in appropriating and reimagining the thinking of one of the most influential thinkers of the past century. But the term also stands for a certain style of reading texts in the history of philosophy that, some argue, gives short shrift to the historical context of the thinking that went into it, the life and legacy of the philosopher who wrote it, and most starkly, the original intentions of the text itself. As Marjorie Grene, a contemporary and colleague, remarked, Dreyfus “purveys his Heidegger, not wholly uncritically, but with deep intellectual passion and undoubted pedagogical brilliance to all—hundreds a year—who come to listen, and uses that Heidegger, in turn, for his own philosophical purposes” (Grene, 1976: 33).

I have argued (with Mark Wrathall) that the approach to phenomenology inaugurated by Dreyfus is better described as “Anglo-American Existential Phenomenology” for its fusion of pragmatist and analytic currents in academic philosophy with existential approaches to phenomenology, as found in Heidegger, Merleau-Ponty and others (Wrathall & Londen, 2019). We identify a number of core commitments or claims that characterize Dreyfus’s philosophical teaching and writing, as well as a collection of views put forward by his many collaborators, colleagues, and students.

In this chapter, I build on that proposal by examining the challenges and prospects of this ongoing research program. My goal is not to present a history or a catalogue of this view, or family of views, but to lay out its internal logic, with an eye to the gaps in that logic and areas that stand to benefit from further philosophical investigation.

Let me start by listing these core commitments:

  1. 1.

    The Primacy of Practice thesis.

  2. 2.

    The paradigm for understanding practice in general is highly skilled, fluid coping.

  3. 3.

    Ontology is contained in background practices.

  4. 4.

    A meaningful life comes from taking a stand on one’s existence.

Broadly construed, the Primacy of Practice thesis holds that practical engagement, agency, or doing is in an important sense more fundamental to human life than theoretical engagement, cognition, or knowing. The most basic way we have of finding ourselves in a world, of relating to others and to ourselves, is by acting in the world rather than thinking about it.

This thesis is a response to a traditional view about the kind of intelligence that characterizes human understanding. A traditional view in the history of philosophy, which Dreyfus, following Heidegger, traces at least back to Descartes, holds that knowledge and cognition are basic to human understanding, and that intelligence is modeled on reflective thought (Heidegger, 1962, 44; Dreyfus, 1972, 147, 1991, 3). Practical engagement, on this view, involves representing both the stuff we engage with and what we are doing in that engagement. This capacity to represent the world and what we are doing is taken to involve our “higher” faculties of reasoning and knowing. Thinking of practical engagement along these lines often leads to explanations of human activity in terms of beliefs, desires, intentions, and causal connections among these states.

The Primacy of Practice thesis seems to invert this relationship. What is basic, Dreyfus argues, is not the experience of being a detached observer reflecting on one’s mental states. Rather, we manifest our intelligence primarily in skillfully responding to the world, or as Dreyfus says, in “coping” with it, without that engagement being mediated by mental states that represent the world. As Wrathall puts it, “So rather than starting from cognition as the primary locus of intelligence, and building out to an account of action, Dreyfus starts with the premise that skillful activity itself is the consummate form and foundation of human intelligence, and derives an account of cognition from coping” (Wrathall, 2014, 3).

But the Primacy of Practice thesis is not just the inversion of the traditional view. Dreyfus insists that it would be a mistake to construe Heidegger’s commitment to the primacy of practice as the claim that the tradition views two ways of relating to objects, one practical and the other theoretical, and that the issue concerns which comes first. “Heidegger does not merely claim that practical activity is primary,” Dreyfus explains; “he wants to show that neither practical activity nor contemplative knowing can be understood as a relation between a self-sufficient subject with its intentional content and an independent object” (Dreyfus, 2014, 77). The problem with the traditional view is that it regards all manifestations of human intelligence, including skillful practical activity, in terms of the relation between an intellect and a world that is the object of its representations. The Primacy of Practice thesis holds, more precisely, that practical engagement has its own kind of intelligence distinct from that of the intellect and that the form or structure of intelligibility manifested in practical engagement is basic to human experience, and the form of intelligibility native to cognition is derivative.Footnote 1

This thesis thus assumes that cognition and practical activity, respectively, are embodied in attitudes with distinct forms or structures. The idea is that attitudes like believing and desiring, understood as native to cognition, make recourse to propositions, whereas basic practical engagement in the world is not faithfully expressed in these kinds of attitudes. For example, when I enter a room with a crooked picture frame and am moved to adjust it, we might understand what I am doing in terms of the mental states of belief and desire: I might believe that the frame is crooked and want to fix it. The belief that the picture frame is hanging crooked on the wall involves being in a certain relation to the proposition that this picture frame is hanging crooked on the wall or to the meaning of the sentence that expresses that fact. The desire to make the picture frame parallel to the ceiling and floor has a similar propositional structure, in wanting it to be the case that the picture frame be parallel to the ceiling and floor. This point about attitudinal structure is that much of our ordinary practical engagement in the world, as we experience that engagement for the most part, is not best captured by these kinds of attitudes. The claim is that when I enter a room with a crooked frame and am moved to adjust it, I don’t need to represent the states of affairs identified in the above-mentioned propositions. The attitude responsible for making the adjustment need not be identified by these propositions and my way of relating to them. Instead, I can be drawn to make the adjustment by my grasp of the whole context in which the frame stands out as crooked and needing adjustment. What I experience in this case is an invitation or a solicitation to make a certain adjustment; that’s what strikes me when I enter the room in this case. This view of practical engagement draws from Heidegger’s conception of understanding as a kind of know-how and his analysis of everyday equipment as ready-to-hand (available for use), Merleau-Ponty’s conception of motor-intentionality, and ecological views in perceptual psychology, especially the concept of affordances developed by James J. Gibson.Footnote 2 This kind of attitude, which is operative when things stand out as directly soliciting my engagement with them, has a different form from the attitudes that involve representing states of affairs in the way sketched out above. The Primacy of Practice thesis is the claim that the former attitude is basic and the latter derivative.

Before raising some questions about this thesis, let me first review the second core commitment, which is closely related to the first. While the Primacy of Practice thesis concerns the relationship between the form of intelligibility manifest in everyday practical engagement and that manifest in the cognitive attitudes, the second core commitment concerns which model of action is taken to be the paradigm for practical engagement. We can contrast Dreyfus’s preferred model of action—“coping”—with a more traditional philosophical model of action. We can call the traditional model “deliberative action” (following Wrathall, 2015, 194). On this model, action proceeds from a judgment about what to do, made on the basis of reflection or a process of rational deliberation. Typically, this involves careful consideration of what one wants to do or what one’s ends or goals are in acting, as well as the courses of action one believes will satisfy those desires or ends. This process is characterized by the formation of an intention to act which constitutes the agent’s reasons for acting and represents the conditions of satisfaction of that activity. This model of action places rationality and reflection at the heart of agency. What it means to act well is to act rationally—that is, to act in light of what one judges to be a good reason to act, and this judgment is epitomized in the conclusions of deliberative reasoning.

By contrast, what Dreyfus identifies with the term “coping” is a form of activity that responds immediately and fluidly to solicitations to act within a given practical context. Everyday activities that rarely issue from acts of rational deliberation, like getting dressed in the morning or navigating a crowded supermarket, fall within this model of action. When we are coping at our best in these activities, we do so without any explicit sense of effort, responding intuitively to the unfolding of circumstances without having to stop and think about our desires or ends, what is needed in order to satisfy these, or otherwise needing to represent the conditions of satisfaction of this activity. “Highly skilled, fluid actions,” Wrathall explains, “are experienced, not as the deliberative outcome of my aims and desires and beliefs, but as being drawn out of me directly and spontaneously by the particular features of the situation, without the mediation of occurrent mental or psychological states or acts” (2015, 195).

According to this second core commitment, coping is taken to be the paradigm for practical engagement generally. On this view, action that flows from rational deliberation, far from being exemplary of consummate action, is actually the hallmark of a defective practical engagement. It is only when I am not directly and fluidly responsive to the ways the practical situation solicits me to act that I am forced to consider explicitly what I am doing or trying to do and what reasons I have for so acting. This doesn’t mean that fluid coping is rote, mechanical, or insensitive to meaningful changes that affect appropriate responses. On the contrary, fluid coping is meant to embody skills that are highly sensitive to the nuances of the situation. In developing the coping model, Dreyfus drew not only from his reading of German and French phenomenologists, but also from observations and empirical work on expertise: experts, Dreyfus argues, are precisely those who are able to respond in highly skilled and nuanced ways to a range of situations in their domain of expertise without having to stop and think about what they are doing.Footnote 3 Careful deliberation, then, is characteristic of the early stages of learning a skill, when the skill is still new and has yet to be mastered. This model of expertise is meant to carry over into the everyday activities of navigating the world, which we often don’t think of as domains of expertise but with which we are often highly adept. The need to deliberate might arise when a given situation fails to present a clear possibility for action, or when one’s competence in a given domain is not up to what the situation demands. Such cases of “breakdown” often require more explicit consideration of one’s desires, beliefs, and whatever thinking is needed to get back into the flow of action.

These first two core commitments raise a number of questions for this school of thought. A question raised by some of its proponents is whether there really is a clear distinction between cognition and practical activity. Some have critiqued the “unthinking” character of many forms of practical expertise based on empirical evidence (see e.g. Montero, 2013, 2016), or argued that thought itself is a kind of activity that requires phenomenological investigation of the sort that the ordinary habitual activities have received (Braver, 2013). Others argue that cognition enhances our ability to act skillfully in many ways: making judgments, reflecting, and deliberating can reorient us to the practical situation so that we are in a better position to respond fluidly. So this phenomenological approach to action should not construe thought to be inimical to fluid coping.

Another question concerns the nature of the dependence relation asserted in the Primacy of Practice thesis: in what way is cognitive intelligibility derivative of practical intelligibility? There are at least two ways to understand this claim. First, we can understand this as the foundational claim that the cognitive attitudes are made possible by the practical attitude operative in fluid coping; this is the claim that the cognitive attitudes are grounded in or are explained by practical engagement. Second, we can understand the Primacy of Practice thesis as also including a genetic claim—that the cognitive attitudes arise out of a modification of a pre-existing practical attitude; this claim asserts a particular developmental story about the origins of the cognitive attitudes in experience. According to the genetic claim, we first engage in coping, responding immediately and skillfully to the solicitations of the environment. “At some point,” Dreyfus explains, “because of some breakdown, or just through intrinsic interest, I may come to focus on some aspects of this navigational know-how. I may begin to classify things as ‘obstacles’ or ‘facilitations,’ and this will change the way I live in the world” (Dreyfus & Taylor, 2015). By focusing on particular features of the environment, I can isolate these features from the context in which they have their practical significance, transforming my mode of engaging with the world: “analytic attention brings about a radical transformation of the affordances given to absorbed coping. Only then can we have an experience of objects with properties, about which we can form beliefs, make judgments and justify inferences” (Dreyfus, 2014, 123). While the foundational claim is the one that is central to the Primacy of Practice thesis, the genetic claim is often taken to be included in this thesis because the foundational claim is often justified by appeal to the genetic claim: it’s because propositional attitudes like believing and desiring only arise out of a modification of the pre-existing and ongoing practical attitude that we have support for the claim that those propositional attitudes are grounded in the more basic practical attitude. The problem with this strategy is that defending the Primacy of Practice thesis would then require an account of how exactly those propositional attitudes, or their intentional contents, emerge from skillful coping. Furthermore, even with such an account, there is the additional question of how this genetic account is supposed to support the foundational claim at the core of the Primacy of Practice thesis.Footnote 4

Attempts to justify the foundational claim independently of the genetic claim raise further concerns. One of the reasons offered to think that cognition is a derivative mode of intelligibility is that practical intelligibility is too fine-grained to be expressed in propositional terms: the seasoned boxer, for example, is able to respond to incredibly nuanced and subtle cues in her opponent’s movements that she would not be able to express fully in a declarative sentence. Another putative reason is that fluid coping is too indeterminate to be adequately captured by propositional or sentential attitudes, or by the conceptual apparatus that comes with logical analysis of these attitudes. Finally, the fact that attitudes like belief are taken to be in principle available to explicit thinking is sometimes offered as a reason to think that highly skillful exercises of practical expertise, the nuances of which are often not explicit even to the expert, are thus more basic than those cognitive attitudes. These strategies often appeal to Heidegger’s critique of the pervasiveness of the subject-predicate form of judgment, and the linguistic structures that judgment embodies (Heidegger, 1962, 196). But the model of judgment that is the target of Heidegger’s critique does not match up with more recent conceptions of the propositional and sentential attitudes that do not rely on this predicate logic or instantiation in a natural language sentence (for this argument, see Golob, 2014). There are prominent views on which one can believe things for good reasons “without being able to say what those reasons are” (Harman, 1973, 28) and in which propositions or their equivalents can be as fine-grained or as indeterminate as can be.

Nonetheless, one potential strategy for establishing a dependence relation between basic practical intelligibility and the cognitive attitudes is to point to the apparent logical structure of those attitudes. A feature of mental states is that their representational contents are isolatable from the attitudes that are directed toward those contents. As Gilbert Harman puts it, “The belief that Benacerraf is wise, the hope that he is wise, the fear that he is wise, and the desire that he be wise are all about Benacerraf, and all represent him as wise. The difference between these mental states is a matter of the difference in the attitude they represent toward Benacerraf’s being wise” (Harman, 1973, 57). Using Merleau-Ponty’s vocabulary of motor intentionality for basic practical intelligibility, Taylor Carman notes, “[W]hereas the propositional contents of cognitive attitudes are detachable or abstractable from the psychological attitudes in which they are embedded, motor-intentional content is constituted by and dependent on the concrete exercises of bodily skill they inform and govern” (Carman, 2013, 175).Footnote 5 So while a defining feature of propositionally structured mental states appears to be the separability of those attitudes from their representational content, a defining feature of coping or motor-intentional attitudes is the inseparability of those attitudes from their “content” or meaning. The goal of the Primacy of Practice thesis would be to show not just that thinking about the world requires first engaging in it, but that our ability to treat the content of our acts of thinking and judging as independent from those acts themselves requires identifying that content in terms of the ways we engage in and with the world. If, furthermore, there is reason to doubt that it makes sense to think of a propositional content or thought in the absence of an attitude that is directed toward that content, then there may be room for arguing that we need an account of the constitutive relation between our intentional attitudes and their content. The account of practical, embodied engagement may be able to provide an account of this constitutive relation between intentional attitude and intentional content. But more work would need to be done to show how this constitutive relation applies in the case of practical engagement, and how this informs the relation between intentional attitudes and their contents more generally.Footnote 6

The third core commitment of this school of thought flows from the extension of the model of fluid coping within a particular domain of expertise to practical engagement in a world more generally: just as we can be experts in particular domains like cooking, dancing, or chess, we are generally already experts at being in a world. Just as our understanding of what there is and what we are doing in a particular domain consists not in our beliefs about that domain or objects in that domain, but in our ability to navigate that domain skillfully, the same can be said of our understanding of the world and our place in it more generally. Thus the third core commitment: ontology is contained in background practices. If we think of our being-in-the-world as a kind of practical engagement that is in the background of more particular domains of practical engagement, then our understanding of that broadest of domains consists in our ability to navigate skillfully within it. This means being able to tell what ways of engaging are appropriate or inappropriate given the social and normative constraints that structure one’s engagement in that domain. Thus background practices (of being a body in a world, or of living with others) manifest and reinforce our understanding of what entities are and the kind of being they have. When I engage in a practice like shopping for groceries, I comport myself in distinctive ways when perusing the aisles, or paying at the register. In doing this, I’m also participating in and reinforcing an ontology—an understanding, for example, of groceries, or of what it means to be a human being. My comportment as I walk down the supermarket aisle expresses my recognition of grocery items as food, just as my interaction with the person at checkout expresses and reinforces my understanding of what it means to be a human being. To understand these categories of entities means seeing how they function within the practices in which they have meaning as the things they are. And like the objects on the supermarket shelves, the ontology of the entities of nature as they are studied by the natural sciences are also wrapped up in our practices. (For a model of natural science that construed its objects as functions of their role in scientific practices, see Haugeland, 2000, 2013).

To say that ontology is “contained” in background practices could entail one of two competing metaphysical theories, namely that background practices give us access to the entities we interact with, or that they constitute these entities. Thus this third core commitment about ontology makes room for both realist positions (that there are entities that have determinate structures that are independent of us and our practices; see Carman, 2003; Dreyfus & Taylor, 2015) and idealist positions (that entities do not have these independent structures; see Blattner, 1994, 1999).

Whereas there has been a healthy debate on the ontology of the objects of natural science in this school of thought, on the topic of social ontology there is still considerable room to grow. Of particular interest would be an ontology of some basic categories of identity, including race, gender, and sexuality. Although examples are often given that make use of the idea of what it means to be a woman, or Japanese vs. American (Dreyfus, 2013), the implications of the larger model of ontology has yet to be explicitly thematized in relation to these social categories. To wit: given that our understanding of what entities are is expressed in our ability to navigate practices in which they play a role, what are race, gender, or sexual orientation? An articulation of background practices for which race, gender, and sexuality play a shaping role—practices that are surely more pervasive than is typically recognized in much of philosophy—could offer a compelling account of the ontology of these categories. Such an account may prove quite valuable given some of the alternatives. For example, essentialist views about race and gender often involve the claim that there is a fact of the matter concerning these categories that could be stated and understood independently of the practices in which these categories make sense. On the other hand, social constructivist views are sensitive to the historical and social conditions that give rise to these categories, but these views generally provide accounts of where these categories come from or how they function rather than what these categories are.Footnote 7 A pragmatist and phenomenologically sensitive view of ontology that views ontological categories as they are expressed in our practices, like that offered by the Dreyfus school, may offer some compelling answers to the relevant ontological question about these social categories, if there are those willing and able to develop these accounts.

The last core commitment concerns the broadly ethical dimension of human life, namely that a meaningful life comes from taking a stand on one’s existence. This claim is broadly ethical in the sense that it concerns how one should live, but the claim springs from the previous core commitment concerning ontology. Many of the background practices that shape our basic understanding of entities and of ourselves are pervasive but are themselves contingent. Since it is in these background practices that we can come to understand what it means to be, say, a human being, this understanding is itself contingent. This reflects the fact that human existence is fundamentally contingent, finite, and vulnerable, that our lives are deeply marked by our mortality and our place in human history, and that our basic frameworks for understanding the world and ourselves can change, fade, or collapse. Recognizing this contingency and vulnerability, in who and what we are, is essential to finding meaning and purpose in our lives. On this view, more traditional sources of meaning that come from things that are eternal and unchanging are ruled out: metaphysical construals of God, the afterlife, the eternal soul, or immutable structures of experience are incompatible with the ways we understand human life from within our contingent practices.Footnote 8 One assumption on this view is that the recognition of the contingency and vulnerability of one’s meaning-giving practices can itself be a source of meaning: an individual can sometimes “sense that their culture’s finite understanding of what is meaningful and worthy is not grounded in reason or God but depends on them, so they devote themselves wholeheartedly to articulating the culture’s current understanding of being” all while remaining open to “the vulnerability of their current understanding of being” (Dreyfus, 2017, 70). It’s in part because of the recognition that my basic framework for understanding myself and the world is itself contingent and vulnerable that I can invest that mode of understanding with purpose and meaning. Combined with the previous core commitments and their implications for the contingency of our modes of understanding, this recognition is required for finding meaning in life—it’s the only option we have left after alternative sources of meaning have been ruled out.

There are, however, obstacles to our recognizing the contingency of our background practices, obstacles which Dreyfus and others unpack in their readings of Heidegger on technology. Although our sense-making practices have always been historical and contingent, there is a tendency in the history of philosophy to offer an account of all entities that prioritizes a particular understanding of being. “Metaphysics grounds an age,” Heidegger argues, “in that through a specific interpretation of what is and through a specific comprehension of truth it gives to that age the basis upon which it is essentially formed” (Heidegger, 2002, 57). This all-encompassing and exclusive understanding of things and people, what Julian Young (2001) calls “the absolutization of a horizon of disclosure” (37), reaches a particularly condensed form in our current age, defined by our relationship to technology. While the medieval age understood the basic ontological categories in terms of the demand to conform to God’s will, and the modern age understood these in terms of the mastery of nature through reason, the technological age attempts to understand things and people such that they are reliably efficient and predictable, not to promote any particular goal or ideal, but to maximize options for consumption and commodification (Dreyfus, 2017, 185). This offers a particularly potent form of the tendency toward an all-encompassing and exclusive understanding of being, since every attempt to offer an alternative understanding of things and people is construed within technological practices as just another option, implicitly reinforcing technology’s injunction to maximize options. Following his reading of Heidegger, Dreyfus observes that we are “caught in especially dangerous practices, which… produced man only finally to eliminate him, as they more and more nakedly reveal a tendency toward the total ordering of all beings” (Dreyfus, 2017, 162). These dominant background practices “eliminate man” to the extent that they ignore the role that human beings play in establishing those practices in the first place and sustaining them through continued participation in these practices.

If we can break through these dominant modes of thinking and recognize our practices’ finitude and contingency alongside our own, we can derive meaning in our own lives by taking a stand on how each of us fits into our culture. One way to re-engage in practices with a recognition of this contingency is to become what Dreyfus calls a “social virtuoso”—someone who is an expert in the current cultural environment, and who seeks to manifest that culture in a distinctive way and thereby to reinvest in that culture by clarifying its style (Dreyfus, 2017, 40). Or one could become a “cultural master,” a “charismatic figure” who introduces some set of marginal practices into the mainstream culture, effectively changing the mainstream culture itself (Dreyfus, 2017, 41). A marginal practice is a background practice that exists outside or alongside the background practices that dominate the culture and the age. Dreyfus gives examples like the practices of publishing and the independent dissemination of ideas introduced with the printing press at the dawn of the modern age, which began as a marginal practice, and came to define the modern age (Dreyfus, 2017, 52). Dreyfus also points to the little sacred moments, like making the perfect cup of coffee on a winter’s day, that can offer a reprieve from the dominant modes of technological thinking when one approaches routine practices with a sense of ritual, attentiveness, and care (Dreyfus & Kelly, 2011, 255–258). Sacred moments like these do not offer full-fledged alternatives to the dominant modes of thinking and acting, but they offer reprieves that may allow individuals to get a better sense of their relationship to and independence from the dominant background practices.

But, it should be noted, it’s not only the practices which are marginal in relation to the dominant ones, but also importantly the practitioners of those practices who are marginalized within the wider culture. This point is under-developed in the Dreyfus school, and as a result the examples of “marginal practices” tend toward familiar examples from history or toward mundane examples (like making the perfect cup of coffee). But if we think of marginal practices in light of the marginalization of the people who engage in those practices, the discussion is greatly enriched. Consider the practices that emerged within gay communities in response to the AIDS crisis in the U.S. As a result of being excluded from the dominant culture, the health needs of LGBTQ individuals were at first largely ignored even as those same communities were devastated by the AIDS epidemic. In response, organizations like the Gay Men’s Health Crisis emerged to promote practices of safe sex among a community that had been excluded from the “monogamous” sexual and relationship practices extending from the traditional institutions of marriage and the nuclear family to various aspects of personal and professional life. As a result of these efforts, widespread education campaigns emerged to spread a new model of healthy sexual practice—use of condoms, open communication about sexual history, etc.—as an alternative to the dominant practices surrounding monogamy, abstinence, and sexual shame. As one chronicler of this history notes, “gay people invented safe sex” (Crimp, 2004, 64). Not only did these safer-sex practices develop on the margins of dominant sexual practices; they developed precisely because of the marginalization of those who developed them. It is because of this marginalization that genuine alternatives to dominant practices could emerge. While we might find little sacred moments in our everyday activities that can offer sanctuary from the dominance of the current paradigm, the practices developed within marginalized communities have the potential to offer rich and compelling alternatives to the dominant and pervasive practices of the age. It’s within those groups that we can hope to find examples of individual “cultural masters,” or change-making communities, with the resources to forge new possibilities for redirecting or enriching available practices.

My hope in this chapter has been to raise some questions and concerns for the productive research program launched by Dreyfus and championed by his many colleagues and students, in order to identify areas on the horizon that are ripe for further philosophical investigation.Footnote 9