Barsalou is right in arguing that perception has been unduly neglected in theories of concept formation. However, the theory he proposes is a weaker version of the classical empirical hypothesis about the relationship between sensation, perception, and concepts. It is weaker because it provides no principled basis for choosing the elementary components of perception. Furthermore, the proposed mechanism of concept formation, growth and development – simulation – is essentially equivalent to the notion of a concept, frame, or theory, and therefore inherits all the well-known problems inherent in these constructs. The theory of simulation does not provide a clearly better alternative to existing notions.