  Place spoke of constitution rather than of identity. One of his examples is ‘This table is an old packing case’. Another is ‘lightning is an electric discharge’. Indeed this latter was foreshadowed by Place in his earlier paper ‘The Concept of Heed’ (Place 1954), in which he took issue with Ryle's behaviourism as it applied to concepts of consciousness, sensation and imagery. Place remarked (p. 255) 