Abstract: The interface between syntax and meaning, both semantic and pragmatic, has emerged as perhaps the richest and most fascinating area of current linguistics theory. This study applies some of these ideas to hyperbaton, offering an original new theory with broad applications for our understanding of Greek syntax. Students of epic will find a fresh perspective on orality in Homer while the general classicist will discover a more precise and explicit framework for the analysis of textual meaning in literary research.

Abstract: When the technology of alphabetic literacy was introduced into Scandinavia by the Christian Church, it changed the nature of communication practices in some discourses, such as law, dramatically; in others which were less implicated in the institutional practices of the Church, its effect was probably minimal, or at least gradual. During the first millennium there is evidence that the inscription of runes on stone, wood or bone had been widely, though perhaps not generally, practised throughout Scandinavia. The effect of Christian ideology on all aspects of Scandinavian culture was profound and in relation to writing practices the conversion effected more than a simple change-over of scripts: each technology had been adapted to particular kinds of communication and each preserved particular kinds of texts. Runic texts, necessarily restricted in length, gave voice to a limited number of discourses. Leaving aside transcriptions that are clearly adaptations of alphabetic text types – such as Latin prayers – communication in runes was primarily concerned with the discourses of memorializing, ownership and magic (Elliott 1989; Knirk 1993). The Christian textual tradition too had its favoured discourses, and religious texts were the first to be produced in the new manuscript culture of medieval Scandinavia. But at an apparently early stage of the new alphabetic industry – extant manuscripts do not allow us to fix precisely when – vernacular texts that were not translations of Latin works came to be written down.

Abstract: Part 1 Prologue: Introduction The Scale and Character of His Work The Import of Ong's Work Part 2 Ong's Life and His Work: Introduction Ong's Family Background Ong's Education Ong's Professional Life Part 3 Ong Studies Peter Ramus and Ramism: Introduction Survey of Ramus, Method and the Decay of Dialogue Paired Oppositions Conclusion Part 4 Ong the Religious Commentator: Introduction Survey of Frontiers in American Catholicism Survey of American Catholic Crossroads Discussion Ong's Own Religious Stance Conclusion Part 5 Ong the Intellectual at Large: Introduction Survey of the Barbarian Within Survey of "In the Human Grain" Discussion Conclusion Part 6 Ong the Cultural Relativist: Introduction Survey of "The Presence of the Word" Discussion The Import of Ong's Work Part 7 Ong's Literary and Communication Studies: Introduction Survey of Rhetoric, Romance and Technology Survey of Interfaces of the Word Survey of Orality and Literacy Discussion Conclusion Part 8 Ong's Two Culminating Psychological Studies: Introduction Survey of "Fighting for Life" Discussion of "Fighting for Life" Survey of "Hopkins, the Self and God" Discussion Part 9 A Concluding Assessment: Ong's Account of Cultural and Religious History Teaching and Learning From Deep Thinkers

Abstract: Making symmetrical knowledge possible - recent trends in the field of Southern African oral performance studies obscurity & exegesis in African oral praise poetry remaking the warrior? the role of orality in the liberation struggle & in post-apartheid South Africa (Dis)locating selves - Izibongo & narrative autobiography in South Africa the image of the book in Xhosa oral poetry orality & modernity in autobiographical representation - the case of Naboth Mokgale's life story Mandela, Africanism & modernity - a consideration of Long Walk to Freedom orality, literacy & the archive in the making of Kas Maine the emergence of the South African oral-style short story - A.W. Drayson's Tales at the Outspan by Craig MacKenzie 'Different people have different minds' - a personal attempt to understand Ju/'hoan storytelling aesthetics sister, spouse, lazy woman - commentaries on domestic predicaments orality & Christianity - the hymns of Isiah Shembe & the Church of Nazarites Chakide, the teller of secrets - space, song & story in Zulu Maskanda.

Abstract: Introduction In New Guinea but also in other parts of the world many Bible translation projects were and are carried out in speech communities that did not know writing prior to the commencement of Bible translation projects in their languages. The term primary orality for societies that do not know writing was introduced by Ong (1982) and the addition of "primary" was meant to clarify that we are not talking about orality in societies that have a tradition of writing. Most Bible translators working in such primary oral contexts want to incorporate in some way or other the oral perspective of their readers and listeners in their translations (Noss 1981). The central question of my article I is what a primary oral context means for Bible translations. First, I will describe Ong's (1982) influential view of primary orality against the background of the academic debates which informed Ong's views. Then I will relate the findings of Ong to the study of corpora of primary oral texts from New Guinea. Finally, I will describe the relationship between the (macro)genre of Bible translations and primary oral genres such as myths, tales, songs or informal conversations. Although the present consensus in discourse studies is that there is no proof of absolute differences between literate and oral societies (in terms of mode of thinking or type ofdiscourse), there are good reasons to start our discussion of Bible translation and primary orality with Ong (1982) since Ong's picture of primary orality is still influential in the world of Bible translators.

Abstract: Orality is the exercise of human verbal communication. Orality transmutes into orature, oracy, or oral literature when either unconsciously or deliberately couched in esthetic forms rather than when deployed in perfunctory manner or primarily for content transmission. Chirograph-centered analysts such as Walter Ong (1982: 11–14) consider the term “oral literature” an oxy-moron. However, if the concept of “literature” is not indivisibly tied to language inscription, and its esthetic function foregrounded, then it equates with “verbal art.” Esthetic structures are culture-specific to the extent that they are grounded in the sound, syntax, semantic and idiomatic configurations of a particular language system, but such structures occur universally and attract hearer attention within each language community. Among these structures are syntactic and semantic parallelisms which produce rhythmic phrasing; stock attributions and idioms, and their converse–syntactic inversions and unexpected semantic manipulation; imagery, metaphor, and simile; rhyme and alliteration; irony in plot or word-choice; dialogue which advances plot and consolidates character and setting; witty verbal exchange producing humor or surprise; conflictual situations; opposed character traits; the evocation of contrasting moods. These are also the very structures employed in scribal literature. Given the traditionally limited use of literacy in most African societies (see Gregsen 1977: 174–93; Gerard 1981), orature genres, themes, styles, and performance techniques have historically been primary vehicles of communication, enculturation, entertainment, and societal acclamation. As cognitive and performative skills, these verbal traditions were among the few but highly significant possessions brought to the Americas by the enslaved survivors of transatlantic crossings.

Abstract: Of the many periods into which scholars habitually divide English literary and social history, the post-Conquest period surely ranks as one of the most interesting and most complex. The tumultuous years 1066-1250 witness not only the rise of most of those political and social institutions upon which England’s unique national identity rests, 1 but it is also the period in which literacy and its concomitant practices and habits of mind move beyond the walls of the monastic and scholastic cells where they had long been sheltered and begin to become more widely available, and increasingly necessary, to people situated at all levels of the social hierarchy. 2 But even though literacy comes to be increasingly central to English society in the early Middle Ages, documentary culture does not immediately displace or marginalize oral culture: English society does shift from being largely oral to being increasingly literate following the Norman Conquest, but this movement is marked by the continued interpenetration and interdependence of oral and literate culture, not by their conflict or rupture. Despite the growing importance of documents, orality remains an important component of medieval society because the literate skills of those who daily came into contact with official documents are almost entirely of a practical and rather limited nature: reeves and bailiffs needed to keep accurate records to manage their estates successfully, and lords and overseers needed to have the ability to ascertain the accuracy of these records for themselves so that they might

Abstract: Oscar Wilde was both an aficionado and a practitioner of literary crime. Most notoriously, his 1886 notes for a lecture on Thomas Chatterton are largely plagiarized from two biographies about the poet. Wilde9s plagiarism and self-plagiarism have formerly been understood as coded expressions of nonliterary transgressions, as roundabout forms of self-promotion, and as the result of the time pressures of a professional writer. In this essay I propose that we understand Wilde9s fascination with and commission of literary crime not only in light of his professed socialism but also through his well-known preference for talk over writing. By appropriating, recirculating, and donating language within literary circles, Wilde set up within a private print culture the lineaments of primary orality that he had encountered through his parents9 ethnographic studies of the nonliterate rural Irish. In promulgating these oral dynamics of circulation, Wilde helped construct primary orality as the irrecuperable other of literate culture. But he also participated in a growing counterdiscourse to private literary-property law, particularly the conventions of individual and serial ownership proper to copyright, that were becoming consolidated in late-Victorian England. While the Chatterton lecture notes work partly to consecrate literary crime as a creative act, Wilde9s story "The Portrait of Mr. W. H." (1889) warns that when ideas circulate like private property, they lose the power to unite their holders in a shared belief.

Abstract: The early years of the thirteenth century witnessed a new development in literary activity marked by the production of Old French prose texts based on previously popular verse compositions, as well as on preexisting Latin works. This monograph examines a number of links between the thematic of truth-telling and prose's expanded use, as seen in a select group of such vernacular prose creations. The book's first chapter provides an overview of the relationship of orality and literacy to prose's expansion, and also addresses the interre-

Abstract: This paper offers reflections about the possibilities of teaching the oral language. It starts from the conceptions put forward by the National Curriculum Guidelines (Brazil) for the primary school as well as from consensual criticisms that have disclosed the lack of pedagogical material and of curricula that can provide the spoken language and the oral productions with a didactic-pedagogical treatment adequate to the role they play both in the practical use of language and in the literary field. The reflections are developed from the concept that the language is an instrument, a medium for interaction and for the constitution of subjectivities; they adopt Bakthin’s concept of discourse genre and construct their contextual coherence based on the pedagogical praxis of the author in teachers education (preservice and in-service). It argues for a curriculum perspective that considers orality, within the present context of new technologies, as a complex, dynamic field, sufficiently apt to interactions with the written language, particularly with the literature. A draft of a model is suggested that proposes a didactic-pedagogical treatment of the activities of listening and oral production in clear conjunction with reading and written production activities. The model also introduces reflections about the possibilities and advantages of including, without prejudices, contemporary oral productions and those originated from the oral tradition.

Abstract: One essential point regarding the relationship between language and culture is related to the different functions of writing and to the ways it is socially appropriated in literate societies. This article is based on a specific way of employing writing by Jarawara Indians and on narratives about the Amazonian myth called Cobra Norato (Norato Snake) told by people living along the Madeira River, in the Brazilian Amazon. It then discusses the different relationships between orality and writing. Permeated by power relations, these relationships transform the alphabet, which is a social artifact constructed to express orality, into a social territory of differences, cleavage and exclusion.

Abstract: Residual orality in ancient Japan is explored here through the little-known Wome-no poem in Harima Fudoki, recorded c. A.D. 714. Through it, we examine the use of punning, and thereby recognize three main points hitherto unnoticed. The first is that the kō/otsu distinctions of Old Japanese were largely ignored for the purpose of punning. Secondly, punning could involve mental substitution of a synonym to evoke the relevant thought association. Thirdly, we discover that puns could hang on chiastic reversal. It is argued that all three of these devices are features of residual orality in ancient Japan, and it is demonstrated that they could be used in combination to convey to the audience an extremely cryptic or esoteric message. In short, this paper not only provides a deeper analysis of the Wome-no poem than ever before, but produces new and original evidence about residual orality in ancient Japan.

Abstract: In his study of Nigerian writing, entitled Strategic Transformations in Nigerian Writing, Ato Quayson recently proposed that we consider African literature "not as a mere precipitate of culture, but as a process of mediation upon it" (16-17). On this basis, he further argues for increas? ing attention to be directed at establishing a "typology of strategic filiations" (160) between what he describes as indigenous resources and contempo? rary African writing. In other words, such resources are to be studied not only for the background they bring to contemporary writing, but also in terms of their varied interactions with indigenous culture and historical events. From the perspective of both writers and critics of African literature, orality is surely one of such "indigenous" resources, and one from which much contemporary African prose takes its roots and inspiration. It is also one that provides the predominant framework within which the texts of Amadou Hampate Ba have been analyzed. This derives largely from Hampate Ba's deliberate location of his "creative" writing in an elaborate and multilayered context of metanarratives connected in diverse ways to the phenomenon of orality. Uetrange destin de Wangrin and Amkoullel, Venfant peul are in Hampate Ba's corpus exemplary of this particular emphasis. Using these two texts, I wish to re-examine here the connections between orality and writing in Hampate Ba's work. The direction of his thinking, I would con tend and hope to demonstrate, is not so much to privilege orality in its own right as to subordinate the survival of oral texts in a postcolonial Africa to the professional skills of ethnographers who both transcribe and translate.

Abstract: Tradition is the illusion of permanence. -Woody Allen In the section of Plato's Phaedrus (274 B, C) dealing with the superiority of the spoken word and the invention of writing, Socrates asks Phaedrus if he knows how to "best please God, in practice and in theory, in this matter of words," and Phaedrus acknowledges that indeed he doesn't and inquires if Socrates knows how to do so. Socrates tells his old friend that "I can tell you a tradition that has come down from our forefathers, but they alone know the truth of it" (Hackforth 1972:156). Evidently Plato viewed tradition as something from the past, but obviously he didn't see tradition as something unchanging or unalterable and had no reservations about reinventing (or even inventing) tradition as a rhetorical strategy in his dialogue; for while Plato borrowed the characters in Socrates' narrative of the invention of writing from Egyptian legend, the story Socrates relates apparently is of Plato's own fabrication. The word tradition, ultimately from Latin, came into the English language from Middle French, and by 1380, according to the Oxford English Dictionary (1971, s.v. "tradition"), generally meant 'That which.. is handed down; a statement, belief, or practice transmitted (esp. orally) from generation to generation." As the concept developed, it has come to mean, according to one definition in Webster's Third New International Dictionary (1981, s.v. "tradition"), "cultural continuity embodied in a massive complex of evolving social attitudes, beliefs, conventions, and institutions rooted in the experience of the past and exerting an orienting and normative influence on the present." In dictionary definitions as well as in common usage, linkage with the past and cultural continuity are typical qualities of what we have come to think of as tradition. Like Plato, our forefathers in folklore studies did not question the meaning and importance of tradition; oral tradition, in fact, was synonymous with folklore. Likewise, in literary studies, the modernists as well as the ancients considered the meaning of tradition self-evident: a body of conventions inherited from the past as distinct from an author's own creations. As Cunningham observes, although historical, literary tradition is not the same as history, for tradition, as Levi-Strauss observes of myth (LeviStrauss 1965:87 ff.), is synchronic as well as diachronic: Consequently, though a tradition is historical in that it issues from an historical process, it is not in itself its history. It exists at each moment in completed form. For a tradition is rather, both in the terms in which it must be described and reconstituted by the literary historian and in the actual way in which it is attained and apprehended by a given writer at a given time, a context of notions, often jumbled and sometimes not too consistent with one another, together with the methods and attitudes by which these notions are grasped and applied. A tradition can be located in a body of texts and interpretations current among a given group of writers and readers. Such a description applies equally to the traditions in which Chaucer and Shakespeare wrote and to those which are now current: one must be learned as well as the other, and in the same way. ... [T] he notions which constitute a tradition are not ideas merely, but principles of order. They are schemes which direct the production of works... [Cunningham 1960:19] Since the 1980s, however, the concept of tradition, as well as of other familiar concepts, has been argued and deconstructed by postmodernists. One book that inspired students of folklore, literature, and culture studies to examine the meaning of tradition was Hobsbawm and Ranger's The Invention of Tradition, published in 1983, in which Hobsbawm in the introduction distinguishes between invented traditions and genuine traditions. Hobsbawm explains that "`Invented tradition' is taken to mean a set of practices, normally governed by overtly or tacitly accepted rules and of a ritual or symbolic nature, which seek to inculcate certain values and norms of behavior by repetition, which automatically implies continuity with the past" (Hobsbawm and Ranger 1983:1). …

Abstract: This paper surveys the shift from orality to manuscript and print and ultimately to electronic technologies, drawing on the work of Walter J. Ong in particular, and explores the accompanying changes in the balance between talking, listening, reading and writing. It argues that the Cinderella profile component of English-listening-deserves more attention than it is currently receiving. In the wake of the digital revolution, consideration is given to the possibilities for, and hindrances to, listening in the English classroom.

Abstract: (2000). Penelope, or, myths unravelling: Writing, orality and abjection in Ulysses. Textual Practice: Vol. 14, No. 3, pp. 519-529.

Abstract: However de® ned, science need not be divorced from its daily, human dimensions. This means those aspects that exist beyond the written word or the processes leading up to its inscription. Within the past two decades, scholars such as Bruno Latour and Steven Woolgar have pioneered an `anthropological’ approach to the study of science, taking into account many details of laboratory and textual work previously left unexamined or deemed irrelevant (Latour and Woolgar, 1986), yet there is a prominent domain that these writers have left by the wayside, that of science education. Our effort here is to take up this domain in a particular way, at a beginning level to be sure, but with a focus different from that of the `science anthropologists’. It is a curious aspect to scholarly studies of science that they do not ordinarily include teaching as an integral part of technical disciplines. What are called `science studies’ and `science education’ , for example, commonly have little or nothing to do with one another. Social, literary, and historical examinations of science lavish their attention on texts, and the lives or conditions that helped produce them. To a large degree, of course, this is necessary: scienti® c knowledge resides most ® nally (and accessibly) in its written products, yet such is not the whole story, by any means. If one includes in this greater entity, `science’ , all of the central processes that comprise its creation, then a different dimension of activity must be added. The making and exchange of technical knowledge among individuals takes place in a variety of ways, only some of which involve textual means. Science is rarely divorced from the immediacy and presence of the human. Teaching and learning, for instance, are among the most basic ways in which professional understanding is

Abstract: Since the Negritude Movement the question of identity of African Literature has been asked in different ways both by writers and literary critiques In her last book African Novels and the Question of Orality (1992), Eileen Julien gives us a sharp summary of the debate on orality and writing After having discussed the main positions ranking from racist Eurocentric conceptions to blind and unconditional advocating of Africanity, she concludes that the question of orality and writing/ literacy is actually a biased one for it makes out of an "accidental fact" an "essentialist myth" Furthermore, it confines a series of African literary productions (written or oral) in the single tight room of orality Indeed, most of the time essentialist discourse is not based on any text, but it is part of a general anthropological consideration, or a metalanguage used by writers themselves to account for their source of inspiration Insofar, it is no wonder that textual evidences cannot support most of the claims On the other hand, a too powerful anthropological approach like the one illustrated in Miller's Theories of Africans, tries to take culture-actually the cosmogony or belief system-into account, and therefore often forgets that we are dealing with a fictional work and not with a sociological essay I would like to contend that not every detail in a literary production is necessarily based on "key-values" like the Mande nyama (vital forces) or on ethnicity This paper intends to offer a reading of Monne by the author of The Suns of Independence, Ahmadou Kourouma, as possible theory of African literature Kourouma's position in this novel reconciles in a literary discourse the two types of metadiscourse mentioned above Indeed, Monne is not only a fictional work, but also a deep reflection on the philosophy of narration Whereas Georges Ngal is very explicit about the question of discourse in his novel Giambattista Vico ou le viol du discours africain, Kourouma remains implicit He practices a deconstruction of discourse by using parodic features, and by narrating the same events from different perspectives These procedures are so consistently carried out that they become a real aesthetics of narration, of "Lying"1 Monne is about a king named Djigui, and his reign during the French colonization Djigui, King of Soba is informed that "Fadarba" and his troops are coming He is told that nobody can resist them Samory, a more powerful King, asks Djigui to join him in the battle against the invaders It is not a simple alliance, but a submission After a moment of hesitation, Djigui eventually accepts to be a vassal of Samory Samory adopts a new guerilla strategy, which consists of simply moving away with the population of his kingdom But Djigui cannot follow him in that because he does not want to leave his homeland, and he does not want to flee: he is ready to fight and die

Abstract: Besides standardized punctuation, which the printing press contributed to formalizing according to a logico-syntactic system, other uses may be found prior to the formation of the system and in parallel with in less cultivated or popular writing down to the compositions produced by today's teenagers in school. These uses attest the writers' awareness of semantic and intonational distinctions typical of orality. Thus several impossible positions in the system are marked by punctuation, whatever the type; this may be observed in particular in the interruption in the unity of the sentence (or subdistinctio)

Abstract: MILTON IS A POEM HEAVILY COMMITTED TO THE GRAPHIC NATURE OF acts of writing and to its own writtenness. The only one of Blake's works specifically called a "Poem," its subtitle--"a Poem in 2 Books"-makes clear that its poetic status is specifically attributed to its written form as a book. Moreover, its ostensible subject matter is the rewriting of the works and influences of an earlier writer and therefore presupposes a significant value in the written word, its transformations and its transformative power. Within the poem itself, Milton is depicted writing "In iron tablets" (17:10) and "in thunder smoke and fire" (7:13); the Shadowy Female wears a garment "written all over ... in Human Words" (18:12), while Ololon descends to Milton at the end of the poem in "Clouds ... folded as a Garment dipped in blood / Written within & without in woven letters" (42:12-13).(1) Yet, the moment of action for the character of Milton in the poem springs from a specifically oral event--a Bard's song.(2) The portrait of Eternity that appears at the beginning of the second book of Milton advocates the power of breath and the spoken word as the forces behind the "Wars of Eternity" (30:9), the construction of "the Universe stupendous" (30:20) and the creation of all "Mental forms" (30:20). In addition, Milton's journey is the rewriting of more than just his written record: the object of correction is Milton's body of texts as transformed by discourses both oral and written which influence and are influenced by cultural fields of religion, politics, and aesthetics (to name just a few).(3) The competing modes of representation and communication--writing and speech, the graphic and the oral, or what Ong has termed literacy and orality(4)--do not result in a polarity of practices, however; nor do they resolve in a privileging of one over the other. Instead, the conceptual fields which characterize writing and speech interpenetrate and form an apocalyptic discourse that incorporates important dimensions of both modes of representation. The refrain from the Bard's song--" Mark well my words! they are of your eternal salvation"(5)--most forcefully manifests this interpenetration and overlap. It communicates orally the urgent message that Milton must revise his written legacy if he (and the culture he influences) is to be prepared for the Last Judgment; it also self-consciously represents the work of a graphic medium to "Mark" or represent the fleeting moments of orality for the reader. The refrain draws both Milton and the reader into a field of discourse in which the spoken is marked or inscribed by the written and the written is an agency of the inspired moment of speaking prophecy. Robert Essick sees this interpenetration of the written and the spoken, the graphic and the oral, as a fundamental dimension of Blake's "model of verbal production."(6) By linking the written and the spoken, Blake engages in what Essick terms a form of "oral writing [which] brings a printed text something of ... [an] increased presence of the accidental productions of spoken language" (191).(7) The recovery of the kind of spontaneity which characterizes the oral complements and revitalizes the premeditated and fixed dimensions of graphic media, as Essick argues, and reincorporates the immediacy of inspiration with the studied reflection of execution. While Essick's arguments about Blake's "model of verbal production" inform the background of my essay, I am here more directly engaged in exploring the way in which the graphic and the oral, the written and the spoken, are used as conceptual fields in Milton. As a conceptual field, writing has been traditionally allied with permanence, rational reflection and the dissemination of its content widely over the material contexts of time and space. In contrast, speech has been characterized by immediacy, spontaneity and a passionate expressiveness. In facing this dichotomy, Blake resists the temptation to make his own acts of writing conform to either one of these conventional oppositions. …

Abstract: After the long predominance of a literary tradition,' modern Western cultures have returned to orality with a 'leap from the being writtenoriented to the being oral-oriented.'2 In the case of Italian, such shift 'dalla scritturalita verso l'oralita,'3 culminating in the Eighties, has led linguists to theorise, on the language continuum, the central varieties of 'italiano dell'uso medio,'4 and 'italiano neo-standard.'5 Moving

Abstract: Untold years of cultivation had rendered it unsuitable to the naturally wild appetites of the human heart. A language that can be spoken only by rote is a language that cannot speak back, even if the speaker is Cicero, Quintilian, or Thomas More. Once the Latin curriculum was replaced by literature in an indigenous language, modern literary criticism could not exist. Now the text could speak back, for its language, whatever the source, bore meaning, to some degree or another, according to some terms or others. Now the text contained words that the reader necessarily employed in spinning her own narrative identity, her own sense of self. The act of reading was more than an encounter with words as things, but a participation of feeling, just as surely as if the reader participated, however unwittingly, by the author's physical touch. Like it or not, the text was alive because it was written in a living language, and so the text was the center of attention. It could be no other way. The study of literature could no longer exist essentially as imitation for the sake of sounding good to people in a language that neither speakers nor hearers could feel meant very much. Within little more than a generation, the study of literature had evolved in a 12. The Vernacular Matrix, supra note 2, at 204. English literature became a common subject of graduate study in America, and undergraduate study at Oxford and Cambridge, only after the First World War. ORALITY AND LITERACY, supra note 10, at 163. The Harvard curriculum experienced by Eliot stood in sharp contrast to the Latin based curriculum studied by Ezra Pound at the University of Pennsylvania. The Vernacular Matrix, supra note 2, at 204. 2000] The John Marshall Law Review