 In fact, Leibniz’s purported analysis of consciousness in terms of reflection isn’t entirely clear. If Leibniz is arguing that a perception becomes a conscious perception when it is accompanied by a second-order perception, then Leibniz has a philosophical problem. Margaret Wilson’s argument against Curley’s similar analysis of Spinoza’s theory of consciousness above applies even better to Leibniz. Leibniz’s theory of mind entails that every mind represents the universe (the “universal expression” thesis), which would always necessarily include a self-expression. All minds would have higher-order perceptions of themselves and their mental states, undermining Leibniz’s ability to distinguish among conscious/non-conscious substances or conscious/non-conscious perceptions within a single substance. All substances would be conscious, and all mental states would be conscious mental states. (For a development of these criticisms as well as an argument that a higher-order theory of consciousness would violate one of Leibniz’s basic metaphysical theses, see Jorgensen 2009. For a possible response (but not decisive) to some of these objections, see Jorgensen 2011a.)