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I have read through the Commons & Pekker article on the formal structure of MHC. That does seem straightforward from the formal point of view. Higher-order actions are defined by means of rules for the coordination of some lower-order actions. However, when I look at the detailed MHC stages that this formalism is supposed to cover, I see much more complexity than is available within the formal structure by itself.? The detailed MHC claims about humans are: From pre-operational down (MHC levels 6 to 1), we have?deductions / sequences / relations-among-concepts / concepts / open-ended classes / stimulus discrimination. My queries:? Are deductions not more than rules and coordination of sequences? Are sequences not more than rules and coordination of relations-among-concepts? Are relations-among-concepts not more than rules and coordination of concepts?? Etc. Certainly, deductions involve rules and coordination of sequences (etc.), but they do much more than that! What I see, is that there is enormous AMOUNT of empirical content in the 14 ‘Orders of Hierarchical Complexity?that Michael and others have formulated!?Much MORE empirical content than described by the formal structure of the Pekker paper! Real psychological stages are a lot more complicated (and interesting) than the examples of distributive laws in arithmetic. My question to Michael: can you produce arguments for the details of the 14 ‘Orders of Hierarchical Complexity?? I look back through all your papers at www.dareassociation.org, but seem only to define assertions of these 14 orders, not arguments for them. You assert, for example, that there are 2 stages within each of Piaget’s stages. Where do you argue this? Why 2 and not, say, 3? Are you able to point to an online paper or discussion where you introduce those component stages? I see a lot of discussion on the postformal stages, but really I am more interested in the earlier stages up to formal. The Commons et al (1998) paper appears promising, but still (in its Table 1) just asserts all the 14 stages without discussion. I would be very grateful, if I could learn the proper basis of the MHC.