 Both Siegel’s pine tree case and the case of hearing a new language fundamentally involve phenomenal contrasts. That is, the motivating intuition in both cases is that there is a contrast in sensory phenomenology between two perceptual experiences. Interestingly, in both cases the phenomenal contrast is due to learning. The question in both the pine tree case and the new language case is what explains the difference in sensory phenomenology. Siegel argues that the best explanation in the pine tree case is that the property of being a pine (and, more generally, natural kind properties) can come to be represented in perception. O’Callaghan (2011) argues that the best explanation for the difference in sensory phenomenology in the new language case is that we come to hear phonological features specific to the new language. Brogaard (forthcoming) argues that the best explanation in that case is that we come to hear meanings in the new language.