 Superficially considered, this concept of theory shows some similarity to neo-positivistic ideas and would be subject to similar criticism. For example, the discussion of the so-called ‘theory-laden’ character of observation sentences casts doubts on such notions as “directly observable facts”. Nevertheless, the adherents of the Ludwig approach would probably argue for a moderate form of observationalism and would point out that, within Ludwig’s approach, the theory-laden character of observation sentences could be analyzed in detail. 