The Psyche is Real:
Materialism, Scientism and Jung’s Empiricism
“What most people overlook or seem unable to understand is the fact that I regard the psyche as real…”[1]
“The ‘reality of the psyche’ is my working hypothesis, and my principal activity consists in collecting factual material to describe and explain it. I have set up neither a system nor a general theory, but have merely formulated auxiliary concepts to serve me as tools, as is customary in every branch of science.”[2]
“You seem to forget that I am first and foremost an empiricist,…”[3]
Jung struggled throughout his life to be understood for what he was—a true scientist—and for what his empirical method told him was true—that the psyche is real. Why was this? Why such a struggle? And why is this? Why is it that many people (especially in academia and science) still regard Jung as a “mystic,” not a scientist?[4] Why do so many still fail to understand Jung when he spoke of the psyche as real? Even at the
This blog essay considers Jung’s dilemma in trying to get people to understand how he worked and what he found in his explorations of the inner life. We will begin by examining the dominant philosophy of our culture (materialism) and the “knowledge base”[5] of our society (scientism) and then we’ll consider Jung’s form of science (empiricism) and how it differs from scientism. Finally we will examine Jung’s concept of the psyche, its features and centrality to Jung’s psychology.
Materialism: Why Few People Regard the Psyche as Real
The etymology or origins of the word “materialism” go way back thousands of years to the Indo-European root ma. “Matter,” “material,” “money” and “mother” all come from this root, all of these words referring to that which has physical form or substance.[6] We got our word “materialism” from Latin materia, the “-ism” coming along in the 18th century as part of the Enlightenment’s quest to escape the ideological clutches of the Church.[7]
Dictionaries amplify the root meaning of “materialism,” defining it as:
“the belief that all action, thought and feeling can be explained by the movements and changes of matter;…”[8]
“the tendency to care too much for the things of this world and neglect spiritual needs;…”[9]
“the ethical doctrine that material self-interest should and does determine conduct.”[10]
“the doctrine that nothing exists except matter and its movements and modifications…”[11]
“the doctrine that consciousness and will are wholly due to the operation of material agencies…”[12]
“a tendency to prefer material possessions and physical comfort to spiritual values; …”[13]
“a way of life based on material interests.”[14]
The astrophysicist Bernard Haisch defines “materialism” as “… the belief that reality consists solely of matter and energy, the things that can be measured in the laboratory or observed by a telescope. Everything else is illusion or imagination….”[15] The underlying assumption here is that “… everything will eventually be explainable in terms of electrical currents, chemical reactions, or yet-to-be-discovered physical laws—mind and spirit are mere epiphenomena.”[16]
I think the most overarching definition—the one most closely related to our purposes here—is the description of “materialism” as “the present-day physical model of reality that matter is all there is and all there can be.”[17] Intangibles like ideas, love, beauty, spirit, aren’t real. This denigration of intangibles has some serious implications, which we will consider below. Before discussing them, let’s examine some of the components of materialism.
Two of the most important elements of materialism are reductionism and randomness.[18] Reductionism is the belief that a complex system (like a living being) can be understood by reducing it to its constituent parts. You want to understand an ecosystem? Just identify all the various parts of it and study each one and presto! You’ll have it figured out. The idea that a living thing might actually be more than the sum of its parts—that it might have “emergent properties”[19]—is never considered in the reductionist’s mind-set.
Randomness is the belief that “… natural processes follow the laws of chance.”[20] The Universe and everything in it (including you and me!) are here because of random happenstance. There is no meaning, no purpose and no destiny in life. There is also no free will, since we all are mere creatures of chance. From this it logically follows that there is no god, no Divine intention or higher power working in the world. Materialism as our culture’s current paradigm is atheistic.[21]
It is also committed to rationalism, putting a premium on logic, the use of reason, the dismissal of superstition, and the denigration of what cannot be proven through the use of left-brain, linear mental processes (e.g. religion).[22] This vaunting of reason leads to concoctions that warm the hearts of economists, like Rational Economic Man. Rational Economic Man (this means you and me, in the materialists’ theory) lives by utilitarian values.[23] That is, when you and I go to the store to buy something, or when we invest our money or decide how to spend our time, we do what works for us, we determine right from wrong based on whether the action will get us what we want. We do what is in our best self-interest. The result? An ethics of expediency (if something gets us what we want, or makes piles of money, it’s right) and the greed of consumerism.[24]
These are some of the implications of materialism. Others include the repression of meaning and true satisfaction in life[25] (because “He who dies with the most toys, wins!” is a spiritually deadening philosophy). By killing the spiritual side of our humanity materialism fosters a sense of meaninglessness, which leads to depression and despair. Jung remarked on this when he said:
Many hundreds of patients have passed through my hands… Among all my patients in the second half of life—that is to say, over thirty-five—there has not been one whose problem in the last resort was not that of finding a religious outlook on life. It is safe to say that every one of them fell ill because he had lost what the living religions of every age have given to their followers, and none of them has been really healed who did not regain his religious outlook. This of course has nothing whatever to do with a particular creed or membership of a church.[26]
Materialism also distorts perception, by making it difficult, if not impossible for most people in Western societies to value non-material experiences, like psi phenomena.[27] One of the most frustrating aspects of teaching the “Developing Your High Sense Perception” workshop for me has been dealing with the profound disempowerment my students have endured thanks to this implication of materialism. Students stare at me in disbelief when I assure them that they can see auras, can read someone’s energy field, can access their higher (intangible) guidance. Materialism has brainwashed us to the point of deluding us about our true abilities! As a model, or paradigm, of reality, materialism colors our culture, influences our habitual way of perceiving things, forms our values and restricts our sense of what is possible.
It has also led to profound cultural pathology.[28] We see this in our health care crisis (leading so many to focus entirely on the body and to insist on all sorts of heroic measures to stave off death); in the epidemic of drug and substance abuse (pernicious ways to block out a sense of despair or meaninglessness); in the pervasive greed of our culture of “consumeritis;”[29] and in all the ways our environment is being degraded (in all the lamentations about the recent oil spill in the Gulf how many people have called us on our addiction to petroleum?).
Such pathologies spark criticism. The Dalai Lama, for example, reminds us that “The view that all mental processes are necessarily physical processes is a metaphysical assumption, not a scientific fact.”[30] Some 80 years before His Holiness wrote these words, Jung took materialism to task:
The dogma that “mental diseases are diseases of the brain” is a hangover from the materialism of the 1870’s. It has become a prejudice which hinders all progress, with nothing to justify it. Even if it were true that all mental diseases are diseases of the brain, that would still be no reason for not investigating the psychic side of the disease. But the prejudice is used to discredit at the outset all attempts in this direction and to strike them dead. Yet the proof that all mental diseases are diseases of the brain has never been furnished and never can be furnished,… for life can never be thought of as a function of matter, but only as a process existing in and for itself, to which energy and matter are subordinate… people… continue to regard the physical hypothesis as “scientific,” although it is no less fantastic [than vitalism]. But it fits in with the materialistic prejudice,… Let us hope that the time is not far off when this antiquated relic of ingrained and thoughtless materialism will be eradicated from the minds of our scientists.[31]
Jung wrote this in 1916. Ninety years later, materialism still has a stranglehold in our Western world, in large part because it is a core element in the “knowledge base” of our culture. This “knowledge base” is scientism.
Scientism: Why Jung Got Labeled a “Mystic”
Note the word: “scientism,” not “science.” What’s the difference? “Science,” as its etymology implies, means “knowing,” or a way of discovery that is an open-ended, unbiased search for the truth.[32] But scientism is neither open-ended nor unbiased. Rather it is a “kind of orthodoxy,”[33] dogmatic and dismissive of experiences that don’t fit within its belief system.[34] And its belief system is rigid, barring “genuine skepticism, [and] an honest search for better truths,…”[35] As a “degeneration”[36] or “perversion of genuine science,”[37] scientism “tends to reduce all reality and experience to mathematical descriptions of physical and chemical phenomena.”[38] Abraham Maslow, the founder of humanistic psychology, regarded scientism as “one of the most effective and prestigious neurotic defense mechanisms available”[39] in our modern world, functioning for its practitioners as a “security system, a kind of self-cloistering, a complicated way of avoiding anxiety and upsetting problems….”[40] As a “dogma… claiming to be the ultimate and final truth about everything,”[41] scientism is the “consensus reality orientation”[42] of our culture.
Materialism and reductionism are two of the components of scientism. Others include:
objectivism—the insistence on objectivity and facts stripped of all emotions[43] (what I call the Joe Friday syndrome: “Gimme the facts, ma’am, just the facts.”) “pseudoskepticism”[44]—the perversion of true skepticism that turns into debunking whatever does not fit into the scientistic worldview
quantification[45]—putting great faith in number-crunching and the use of “quants” (the terrible results of which we have seen recently in the economic meltdown of 2007-8, built upon quants’ not-so-clever creations)[46]
mechanism—regarding the machine as the model of reality[47] (hence “spare-parts” medicine)
determinism—the idea that everything is determined, without free will[48]
the “pathologies of cognition,”[49] Abraham Maslow’s term for the 21 ways that scientism warps our perception
prejudices—against religion, spirituality, idealism, intuition or “noetic knowing,” and psi phenomena[50]
“image investments”—a host of defenses against seeming to be ignorant or unable to provide answers to what’s going on[51]
arrogance[52]
“training into orthodoxy”[53]—Henryk Skolimowski’s term for the years-long period of training which graduate students undergo that inculcates the beliefs of scientism and squeezes out “heresies” like belief in intangibles
If, by this point, you are beginning to wonder if scientism has the scent of some sort of religion, consider that it even has a mantra, which goes like this:
Science tells us about physical reality. It cannot tell us anything about any possible non-physical realities. Since non-physical realities cannot be investigated by science, they do not exist. End of story.[54]
Such a mantra does not go unchallenged, even by some prominent scientists. For example, Bernard Haisch, astrophysicist, researcher and author of scores of scientific papers, recognizes that, as a model of reality, scientism “… explains away the reality of even [our] own thoughts,”[55] and far from being the unbiased exploration of reality, it “… has abrogated its responsibility to uncover objective truth” and “… has succumbed to a dogmatism of its own.”[56] Charles Tart notes the destructive results of scientism, as it “hinders progress in all areas of science… inhibiting new ways of thinking,…”[57] and “…denying or invalidating the spiritual… longing and experiences…” of people.[58] Its influence is especially pernicious because it arrogates to itself the “power and prestige” that we have given to science, as the knowledge base of our culture.[59]
It is this grip that scientism has on our culture that has led to Jung and analytical psychology being ignored almost completely in the sylvan grooves[60] of academe. Ninety years ago Jung challenged scientists:
It is really high time academic psychologists came down to earth and wanted to hear about the human psyche as it really is and not merely about laboratory experiments. It is insufferable that professors should forbid their students to have anything to do with analytical psychology, that they should prohibit the use of analytical concepts and accuse our psychology of taking account, in an unscientific manner, of “everyday experiences.” I know that psychology in general could derive the greatest benefit from a serious study of the dream problem once it could rid itself of the unjustified lay prejudice that dreams are caused solely by somatic stimuli…[61]
Jung recognized that dreams arose from more than just physical causes. He came to this and his other discoveries as a true scientist, using empiricism as his method.
Empiricism: Jung as a True Scientist
“Empiricism” comes from the Greek word empeirikos, meaning “experience” or “experiment.” It is defined in dictionaries as “the use of methods based on experiment and observation.”[62] Real scientists (i.e. not practitioners of scientism) regard empiricism as “genuine science,”[63] “an open-ended, error-correcting, personal-growth system of great power.”[64] It is a method posited on the belief that “direct inner experience… trumps logic and proof.”[65]
Time and again in his essays, letters and interviews Jung called himself an empiricist:
“… I am first and foremost an empiricist.”[66]
“… I was particularly satisfied with the fact that you clearly understood that I am not a mystic but an empiricist.”[67]
“… I am not a philosopher, I’m an empiricist.”[68]
And his methodology backed up his claim. Doing science—true science—begins with observation. It asks “What’s going on?” and proceeds to observe with an open mind. Data collection from direct personal observation and experience leads to the formulation of a hypothesis. Then the empiricist communicates his/her findings, sharing data so others can provide further insights, feedback and reports on their experiences with similar data. This leads to refinement of the hypothesis, further data collection, more sharing of results, and more refinement, until the collaborating group comes to conclude that the tentative hypothesis is likely to be valid.[69] The whole process is inductive, i.e. it proceeds from the facts to a conclusion—the opposite of deduction, where one starts with a belief and then seeks out facts that support it.
Jung described how he worked in several passages in his letters:
“The empiricist does not think from above downwards from metaphysical premises, but comes from below upwards from the phenomenal world,…”[70] (This is the way of induction).
“… the empiricist… in order to do justice to his task, can appeal to nothing except the given realities.” (He focuses on facts, not theories).[71]
“… our empirical psychology is based entirely on the experience of individual cases,…”[72] (Rather than try to fit people into some arbitrary theory, Jung began by taking each patient as an individual, with a unique set of experiences).
“One should not misconstrue the findings of empiricism as philosophical premises, for they are not obtained by deduction but from clinical and factual material.”[73] (Jung got the material for his psychological system from his own experiences and those of his patients).
“The point of view I have adopted is that of modern empirical psychology and the scientific method… Psychology cannot establish any metaphysical “truths,” nor does it try to. It is concerned solely with the phenomenology of the psyche…. For modern psychology, ideas are entities, like animals and plants. The scientific method consists in the description of nature.”[74]
And part of nature, Jung argued, is intangible. Here is where Jung parted company with materialism and scientism: Intangibles—like ideas, dreams, the psyche—are real. They exist. We deny their existence at our—and our society’s—peril.
The Psyche, Its Features and Role in Jung’s Thought
“Psyche” means “soul” in Greek. In some places in his writing Jung uses the two terms interchangeably. For example in his essay “Psychology and Alchemy,” he writes:
…with Western man the value of the self sinks to zero. Hence the universal depreciation of the soul in the West. Whoever speaks of the reality of the soul or psyche is accused of “psychologism.”[75]
From our discussion of materialism and scientism, we can understand why Jung was so often accused of “psychologism.”
Elsewhere Jung describes the psyche as “peculiar.”[76] Autonomous[77] and unconscious,[78] it is mostly unknown to us, and beyond our ability to fully grasp.[79] While it is linked to both the organic and inorganic worlds,[80] it is independent of physical data to some extent,[81] and it has the curious ability to relativize both time and space[82] (i.e. it plays a role in psi phenomena). As “… a complex whole actuated not only by instinctual processes and personal relationships but by the spiritual needs and suprapersonal currents of the time,…”[83] the psyche in its “creative capacity,”[84] opposes entropy[85] (the principle in thermodynamics that postulates increasing disorder in a system over time). Because of the action of the psyche, living systems are “negentropic,” i.e. they are able to maintain a state of order or equilibrium while they are alive.
Maintaining equilibrium is another feature of Jung’s image of the psyche. He notes repeatedly that “… the psyche is a self-regulating system, just as the body is,…”[86] As a quality of matter, the psyche is dependent on the body’s nervous system.[87] It has a structure[88] and is accessible to the scientist through empirical methods.[89]
What role does the psyche play in Jung’s thought? Before addressing this question, we might well recall what we discussed above. “Psychiatry” and “psychology” both come from the root word “psyche.” This suggests that, in any form of psychiatric or psychological activity, the psyche would be the central focus. But in actuality, due to the pernicious influence of materialism and scientism, the vast majority of psychiatric training programs, college departments of psychology, and state boards of mental health licensure act as if “psyche” has no place in their work! The psyche being an intangible, they ignore or dismiss it. They are so locked into the materialist ethos that they can’t recognize the core element in their profession.
Jung, of course, is different. He recognized the psyche as one of the three central elements of his system:
… the structure of opposites and their symbolism, the anima archetype, and … the unavoidable encounter with the reality of the psyche… these three main points play an essential role in my psychology,…[90]
Elsewhere Jung called the psyche “… reality par excellence,”[91] the “auctor rerum… the ground and substrate”[92] of reality, “…the greatest of all cosmic wonders and the sine qua non of the world as an object.”[93]
Jung went further than these encomiums in his regard for the psyche. He regarded it as “the world’s pivot:… the one great condition for the existence of the world,”[94] and the factor upon which the future of the world depends:
… nowadays particularly, the world hangs by a thin thread, and that thread is the psyche of man.” “We are the great danger. The psyche is the great danger…[95]
When asked about our prospects, Jung put the psyche front and center:
… the careful consideration of psychic factors is of importance in restoring not merely the individual’s balance, but society’s as well. Otherwise the destructive tendencies easily gain the upper hand. In the same way that the atom-bomb is an unparalleled means of physical mass destruction, so the misguided development of the soul must lead to psychic mass destruction.[96]
Jung was not sanguine about the future of the world, as I have noted in earlier blog essays. He continued his remarks above with this warning:
The present situation is so sinister that one cannot suppress the suspicion that the Creator is planning another deluge that will finally exterminate the existing race of men.[97]
If we want to rise to the challenge facing us in these critical times, Jung would ask us to turn within, to our souls, to the psychic reality that is at the root of our being. Stand up to the foolishness of materialism and the life-killing stupidity of scientism! These features of our contemporary world are the most fearsome weapon of mass destruction we face now, all the more threatening because they are unrecognized as such.
How do you come to learn for yourself that the psyche is real? Trust your own experience, work with your dreams, pay attention to your inner life, and turn a deaf ear to the scientistic materialists! (This will require some independence of thought, as our society is deeply permeated with scientism). Listen to Jung and follow his example of relying on your own inner wisdom, and you too will come to know what Jung knew: that the psyche is real.
Bibliography
Haisch, Bernard (2006), The God Theory.
Harman, Willis (1988), Global Mind Change.
Hergenhahn, B.R. (1994), An Introduction to Theories of Personality.
Jung, C.G. (1960), ”The Structure and Dynamics of the Psyche,” CW 8. Princeton:
________ (1959), “Aion,” Collected Works, 9ii. Princeton:
________ (1970), “Civilization in Transition,” CW 10. Princeton:
________ (1969), “Psychology and Religion: West and East,” CW 11. Princeton:
________ (1953), “Psychology and Alchemy,” CW 12. Princeton:
________ (1976), ”The Symbolic Life,” CW 18. Princeton:
________ (1973), Letters, ed. Gerhard Adler & Aniela Jaffé. 2 vols. Princeton:
________ (1977), C.G. Jung Speaking: Interviews and Encounters, ed. William McGuire & R.F.C. Hull. Princeton:
Lewis, Michael (2010), The Big Short.
Lewis, Charlton & Charles Short (1969), A Latin Dictionary.
Markopolos, Harry (2010), No One Would Listen.
Moelaert, John (1974), “The Epidemic in Our Midst,” Earthkeeping:
Sharf, Richard (1996), Theories of Psychotherapy and Counseling: Concepts and Cases.
Skolimowski, Henryk (1996), “The Methodology of Participation,” Revisioning Science, ed. Susan Mehrtens.
Solomon, Deborah (2010), “Math Is Hard: Questions for Harry Markopolos,” The New York Times Magazine (February 28, 2010), 14.
Tart, Charles (2009), The End of Materialism.
[1] Jung, Collected Works 11, ¶757. As has been the convention in these blog essays, Collected Works will hereafter be abbreviated CW.
[2] CW 18, ¶1507.
[3] “Letter to Pastor Ernst Jahn,” 7 September 1935; Letters I, 195.
[4] I hear this often in my work as a college professor from some of my students who venture into psychology courses and come away surprised at the prejudiced attitude of their professors in departments of psychology. Such attitudes are not uniform however: I own two recently-published textbooks in psychology, both of which actually mention Jung and his work; cf. Sharf (1996) and Hergenhahn (1994).
[5] I first heard the concept of science as the “knowledge base” of Western society from Willis Harman, President of the
[6] Lewis & Short (1969), 1118.
[7] Tart (2009), 295.
[8] World Book Encyclopedia Dictionary II, 1196.
[9] Ibid.
[10] Ibid.
[11] Tart (2009), 295.
[12] Ibid.
[13] Ibid.
[14] Ibid.
[15] Haisch (2006), ix.
[16] Tart calls this “promissory materialism;” Tart (2009), ix,13,241.
[17] Haisch (2006), 67.
[18] Ibid., ix-x.
[19] Like “mind,” “consciousness,” wholeness, the capacity to reason, love or create; see ibid., 24.
[20] Ibid., x.
[21]Ibid., x; Tart (2009), 28-29.
[22] Tart (2009), 75, 246.
[23] Ibid., 28. The new discipline of “behavioral economics” is challenging the concept of Rational Economic Man, in the recognition that we aren’t always logical or rational in the choices we make, economic or otherwise.
[24] Tart (2009), 377.
[25] Ibid., 34.
[26] CW 11, ¶509.
[27] Tart (2009), 13.
[28] Ibid., 246.
[29]This neologism was coined by Canadian conservationist John Moelaert; see Moelaert (1974), 219.
[30] Quoted in Tart (2009), 2.
[31] CW 8, ¶529.
[32] Tart (2009), 6, 192-3.
[33] Haisch (2006), 25.
[34] Ibid., 50,60; cf. Tart (2009), 33.
[35] Tart (2009), 12.
[36] Ibid., 53.
[37] Ibid., 192.
[38] World Book Encyclopedia Dictionary, II, 1736.
[39] Tart (2009), 12.
[40] Ibid., 54.
[41]Ibid., 75.
[42] Ibid., 82.
[43]
[44] Tart (2009), 64-65.
[45] Haisch (2006), 64.
[46] For an entertaining and well-written account of the nightmare inflicted by the “quants” on the global economy, see Lewis (2010). It would be unfair to imply that all activities by “quants” are negative: Harry Markopolos, the Madoff whistle-blower, identifies himself as a “quant” and he has been instrumental in exposing the ineptitude at the Security and Exchange Commission; for his account of the years he spent trying to get the S.E.C. to investigate Madoff, see his well-written book No One Would Listen.
[47]
[48] Ibid., 55-56.
[49] Tart (2009), 37. The 21 forms identified by Maslow are: “a compulsive need for certainty;” “premature generalization;” “hanging onto a generalization in spite of new information that contradicts it;” “denial of ignorance;” “the need to appear decisive, certain, confident;” “an inflexible, neurotic need to be tough;” “a lack of balance between our masculine and feminine sides;” “rationalization;” “intolerance of ambiguity;” “social factors biasing the search for knowledge;” “grandiosity;” “pathological humility;” “overrespect for authority;” “overrespect for the intellectual powers of the mind;” “intellectualization;” “dominating, one-upping or impressing people;” “fearing the truth;” “rubricizing;” “compulsive dichotomizing;” and “a compulsive seeking and need for novelty.” Tart explains these in depth on pages 55-61.
[50] Ibid., 40.
[51] Ibid., 57.
[52] Ibid., 38, 241.
[53] Skolimowski describes this process in detail in Skolimowski (1996), 160-9.
[54] Haisch (2006), 38.
[55] Ibid., 137.
[56] Ibid., 146.
[57] Tart (2009), 53.
[58] Ibid., 241.
[59] Ibid., 194.
[60] No typo: I use this pun on the hackneyed phrase describing the cloistered realm of academia—“the sylvan groves of academe—to point up how the academy has succumbed to the hidebound thinking of scientism.
[61] CW 8, ¶529.
[62] World Book Encyclopedia Dictionary, I, 644.
[63] Tart (2009), 290.
[64] Ibid., 54.
[65] Haisch (2006), 58.
[66] “Letter to Pastor Ernst Jahn,” 7 September 1935; Letters, I, 195.
[67] “Letter to Norbert Drewett, O.P.,” 25 September 1937; Letters, I, 237.
[68] “Letter to Swami Devatmananda,” 9 February 1937; Letters, I, 227.
[69] Tart explains this process in detail; Tart (2009), 43-50.
[70] “Letter to Pastor Ernst Jahn,” 7 September 1935; Letters, I, 196.
[71] Ibid.
[72] CW 18, ¶1312.
[73] CW 18, ¶1510.
[74] CW 18, ¶742.
[75] CW 12, ¶9.
[76] CW 10, ¶655.
[77] CW 11, ¶555; cf. CW 12, ¶60.
[78] CW 12, ¶60.
[79] CW 12, ¶564; cf. “Letter to Pastor Ernst Jahn,” 7 September 1935; Letters, I, 196.
[80] CW 10, ¶655.
[81] CW 11, ¶555.
[82] CW 10, ¶655.
[83] CW 10, ¶1046.
[84] CW 12, ¶249.
[85] CW 8, ¶375.
[86] CW 8, ¶159.
[87] CW 8, ¶607.
[88] CW 11, ¶777.
[89] CW 8, ¶441.
[90] CW 18, ¶829.
[91] CW 9ii, ¶120, note 92.
[92] CW 18, ¶1116.
[93] CW 8, ¶357.
[94] CW 8, ¶423.
[95] Jung (1977), 303-4.
[96] CW 8, ¶428.
[97] Ibid.
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