 It was Bayle himself in the famous note B of the Pyrrho article who took Foucher to be extending Malebranche’s arguments: “if the objects of our senses appear to us coloured, hot, cold, smelling, tho’ they are not so, why should they not appear extended and figured, at rest, and in motion, though they had no such thing.” Although a parallel is established, the argument is obviously not very strong. Now, the most notable mutatis mutandis argument employed by Berkeley against the distinction is based on the relativity of sense perception: the perception of both varies under varying conditions, so if the variation of secondary qualities is a reason to place them in the mind, it is also a reason to place the primary in the mind. This argument is not to be found in Foucher or in this article, but it does appear in note G of the Zeno article, unconnected with Foucher: “the modern Philosophers, though they are no Sceptics,” have made secondary qualities no more than perceptions in the mind; “why should we not say the same thing of extension?” Bayle again deploys the weak parallel argument above, and then continues: “Observe also, that the same body appears to us little or great, round or square, according to the place from whence we view it: and certainly, a body which seems to us very little, appears very great to fly.” A problem for this text as a source for Berkeley is that this very argument is to be found better presented in Malebranche, who is cited here along with other moderns such as Lamy and Nicole, who are supposed to be undone by it. Given that Malebranche is cited by Berkeley more often by Berkeley’s notebooks than anyone but Locke, it would seem more likely that Berkeley went straight to Malebranche for his arguments on the primary-secondary distinction.