 Skeptics of cognitive penetrability point out, however, that experimental evidence for top-down effects on perception can be explained in terms of effects of judgment, memory, and relatively peripheral forms of attention (Firestone &amp; Scholl, 2016; Machery, 2015). Consider, for example, the claim that throwing a heavy ball (vs. a light ball) at a target makes the target look farther away, evidence for which consists of subjects’ visual estimates of the distance to the target (Witt, Proffitt, &amp; Epstein, 2004). While it is possible that the greater effort involved in throwing the heavy ball caused the target to look farther away, it is also possible that the increased estimate of distance reflected the fact that subjects in the heavy ball condition judged the target to be farther away because they found it harder to hit (Firestone &amp; Scholl, 2016). Indeed, reports by subjects in a follow-up study who were explicitly instructed to make their estimates on the basis of visual appearances only did not show the effect of effort, suggesting that the effect was post-perceptual (Woods, Philbeck, &amp; Danoff, 2009). Other purported top-down effects on perception, such as the effect of golfing performance on size and distance estimates of golf holes (Witt et al., 2008), can be explained as effects of spatial attention, such as the fact that visually attended objects tend to appear larger and closer (Firestone &amp; Scholl, 2016). These and related considerations suggest that the case for cognitive penetrability—and by extension, the case against low-level modularity—is weaker than its proponents make it out to be. 