Reports of clinical happenings are coming under increasing suspicion because of their piecemeal nature and their problematic reliance on memory. Recent research on eyewitness testimony has raised the further concern that memory of an event can be easily and unwittingly influenced by something heard or seen after the fact. Once the psychoanalyst's memory has come under the influence of whatever theory is dominant, we can expect both an overselection of clinical happenings consistent with that theory, and an unwitting alteration of those that do not agree. Seemingly true case reports may be more virtual than veridical.