Howe does not accept the currently widely held theory that memory includes several rather distinct systems, such as explicit memories and implicit memories (the latter are especially relevant to repressed or dissociated traumatic memories). He repeatedly cites the principle of parsimony, demanding one-sidedly that those who differ with him on this issue produce "incontrovertible evidence" for their position (p. 15), although the evidence he offers for his own views is considerably short of incontrovertible. To his credit, he calls for empirical investigations that might falsify his own "theoretical speculations" on memory (p. 149). But he then ignores much of the literature that, in my opinion, does just that (e.g., reference 4). He fails to mention a book that is perhaps the single most important contribution to the topic of traumatic memories. The winner of APA’s 1998 Guttmacher Award, Memory, Trauma, Treatment, and the Law by Brown et al. (5), clearly demonstrates that traumatic events can be forgotten, then later remembered (e.g., pp. 390–394).