 That Einstein should deploy against the neo-Kantians in the early 1920s the argument that Duhem used against the conventionalism of Poincaré and Le Roy is interesting from the point of view of Einstein’s relationships with those who were leading the development of logical empiricism and scientific philosophy in the 1920s, especially Schlick and Reichenbach. Einstein shared with Schlick and Reichenbach the goal of crafting a new form of empiricism that would be adequate to the task of defending general relativity against neo-Kantian critiques (see Schlick 1917 and 1921, and Reichenbach 1920, 1924, and 1928; for more detail, see Howard 1994a). But while they all agreed that what Kant regarded as the a priori element in scientific cognition was better understood as a conventional moment in science, they were growing to disagree dramatically over the nature and place of conventions in science. The classic logical empiricist view that the moment of convention was restricted to conventional coordinating definitions that endow individual primitive terms, worked well, but did not comport well with the holism about theories