Certain things are true in the ‘worlds’ described by fictional narratives: Although Batman doesn’t really exist, “Bruce Wayne is wealthy” is nevertheless true (in some sense) in virtue of the fact that Bruce is described as rich in the Batman comics. The metaphysical details of fictional worlds are notoriously unclear, but we can set that aside. What is clear is that the following thesis naturally suggests itself:

The panel transparency thesis: Characters, events, and locations within the fictional world described by a comic appear, to characters within that world, as they are depicted in the panels.

There are good reasons for thinking that we should take panels, no matter how odd their content, to accurately represent the appearances of fictional characters unless given some substantial evidence otherwise, including:

  1. Characters in comics sometimes comment on the strange appearances of other characters.
  2. Costumes based on comic characters typically resemble the characters as they appear in the panels.

Unfortunately, the panel transparency principle has disturbing consequences. For example, the Joker, during the events depicted in The Long Halloween, has six-inch teeth. In other stories, however, the Joker has normal dentition. So what is going on?

First, perhaps the Joker’s appearance changes dramatically from one story to the next. Sometimes he has six-inch teeth, and sometimes he doesn’t. This, however, implies that the fictional worlds described by mainstream comics differ drastically – in their basic physics and physiology – from the actual world.

Second, perhaps the Joker does not change appearance from comic to comic. Instead, different comics are describing different Jokers. Some of these Jokers have six-inch teeth, and other don’t. This, however, imposes an implausible proliferation of characters onto an already complex Batman continuity, and also fails to explain why the six-inch-toothed Joker remembers and reacts to events that happened to the normal-toothed Joker (and vice versa).

The obvious solution is to draw a principled distinction between those aspects of the art that accurately depict the appearance of the Joker, and those that are merely stylistic (presumably placing the length of the Joker’s teeth, as depicted in The Long Halloween, in the latter category). The problem is determining how we are to make such a distinction. It cannot depend on whether or not the art resembles the real world, since there are clearly characters in Batman comics that do not resemble anything in the actual world (after all, Killer Croc is not merely a regular dude with scaly green skin!) In fact, the only data we have regarding what Batman’s world looks like is the visual content of the panels –there is no independent ‘standard’ against which we can compare the panels to determine which aspects are accurate representions and which are merely stylistic. So why are we tempted to treat Sale’s depiction of the Joker’s teeth as stylistic, and other depictions as an accurate representation, rather than vice versa?


About roytcook

Roy T Cook is CLA Scholar of the College and John M Dolan Professor of Philosophy at the University of Minnesota - Twin Cities. He works in the philosophy of logic, the philosophy of mathematics, and the aesthetics of popular art. He is the co-editor of The Art of Comics: A Philosophical Approach (Wiley-Blackwell 2012, w/ Aaron Meskin), The Routledge Companion to Comics (Routledge 2016, w/ Aaron Meskin & Frank Bramlett), and LEGO and Philosophy: Constructing Reality Brick By Brick (Wiley-Blackwell 2017, w/ Sondra Bacharach).

21 responses »

  1. Thanks for starting things off with such a fascinating question, Roy. And what an image! For me, the experience you’ve described brings to mind Neil Gaiman’s Sandman series and the use of multiple artists throughout its run. Gaiman constructs Dream (Morpheus) as a shape-shifting figure by nature, so readers learn not to be so quick to identify him based on visual appearance. But even with the wide range of aesthetic styles and peculiarities in the story, Morpheus has a few familiar features — i.e. his dark hair and brooding expression — that remain consistent enough to convey a strong sense of his character no matter which image (or body) contains him.

    I would argue that a similar situation exists for a comic like The Long Halloween that is based on a long-running character title. As the world within a comic series evolves, it acquires its own standard, a set of rules against which future variations are based. Even the manner in which an artist encourages us to treat a representation as “accurate” or “real” in that world is a stylistic choice, one that operates within the larger standards of the series. Surely the art in the panels always conveys more than what we see and can verify; it also establishes precise moods and invites certain kinds of responses.

    So. I think we may be tempted to treat Sale’s depiction of the Joker’s teeth as stylistic because while it may not be “accurate,” it depicts a credible aesthetic understanding of his character. We’re being skillfully nudged to set aside our knowledge of human anatomy in order to appreciate how his trademark grin is being perceived in the story.

    • roytcook says:


      Thanks for the thoughtful response.

      While your response sounds eminently reasonable to me, I worry about how we should (or even whether we can) apply it to fictional worlds described in comics that do not have runs long enough to determine such standards. For example, imagine a one-page comic by Sale similarly depicting a character with saucer-sized bug-eyes. Should we interpret that character as appearing roughly human, treating the eyes as stylistic or meta(phorical)? Or should we interpret him as really appearing inhuman? Here there just don’t seem to be any standards to apply.


      PS: The Morpheus example is a particularly challenging one! I am going to need to think about that one some more.

  2. Boris Smelov says:


    Your mention of the bug-eyed character is an interesting one. If there were such a character in a comic like The X-Men, I would immediately read them as having a grotesque physiognomy. If, however, such a character appeared in an R. Crumb comic, I would interpret them as a simple charicature of a normal human. Batman seems to lie somewhere in between those two extremes. It is fantasmagorical enough to support creatures such as Man-Bat and Killer Croc, but allegorical enough to support the Joker’s shifting appearance. I don’t think most comics could pull off the balance that Batman achieves in this respect. At least, I can’t think of any others where such a seeming inconsistency would fit into the flow.

    • roytcook says:

      Interestingly, I just found a call for papers for a volume titled: ‘The Joker: Critical Essays on the Clown Prince of Crime’. I think I might try to write up these ideas in an essay for that volume. Your comments about how Batman comics are particularly good places to ask this sort of question, based on the balance found there between Crumb-style caricature and X-men style realism, has convinced me that the topic really is particularly interesting in the context of Batman and the Joker (rather than this merely being a cute example!). Thanks.

  3. Boris makes a great point with the juxtaposition of X-Men and Crumb’s work. And I agree that Batman seems to be more elastic in this respect (also comics that feature a lot of parody – like The Tick? Or your beloved She-Hulk?)

    But Roy, your reference to “saucer-sized bug eyes” immediately brought to mind for me this somewhat infamous image of Ebony White who is drawn quite differently than other people on the page: http://www.comicvine.com/the-spirit-ebonys-x-ray-eyes/37-254910/all-images/108-462273/spirit_400915_01/105-1603164/. In instances like this, where the gross exaggerations are derived from cultural stereotypes, the normative standards are set by societal practices — in this case, deeply problematic minstrel images of African Americans that were popular at the time. This may be straying a bit from your original question, but I guess what I’m suggesting is that internal or external measures of evaluation will always be present. Aren’t we always grasping for context clues, even for the hypothetical one-page comic?

    • roytcook says:

      I agree we are always grasping for clues, both clues internal to the story and external clues (such as our knowledge of currently popular minstrel images in the Ebony White case, or knowledge of Clinton’s political image when Trudeau depicts him as a literal waffle). In some cases there is enough context and other relevant data to settle the issue. The real worry, I guess, is whether there is always enough information to settle these questions, or whether we are sometimes forced to make an arbitrary choice.

      Another thing worth noting: The problem regarding the Joker’s teeth is different from the standard observation about narrative art – that the author doesn’t, and can’t, describe everything, so we need to fill in details (and different readers will fill in the details differently). In short, we are pretty used to the fact that some literally descriptive content regarding the fictional world of the narrative will need to be filled in by the reader. The worry at issue here, however, is which parts of the information that IS supplied by the artist should be taken to be literally descriptive of the fictional world of the narrative.

  4. Roy,
    This is the first time that I’ve seen this particular image of the Joker, and your question makes me think of a number of other examples of this discrepancy of appearances.

    First, a non-comics example. In the Lord of the Rings novel, Tolkien describes an ancient demon called a balrog, and the rather short passage is light on detail, meaning that there are several possible interpretations of what a balrog “really does” look like. How tall is it? How broad is it? Does it have wings? These physical characteristics of the demon are indeterminate in the text. In high contrast, Peter Jackson’s film adaptation concretized the balrog’s appearance, making it seem like a giant, sort of a hybrid of human, bull, and dragon. Naturally, fans responded to Jackson’s portrayal with a mixed feelings.

    To a much greater degree than a purely linguistic text, comics restrict the reader’s world view. When I read Tolkien, I can imagine what a balrog looks like, or what an elf looks like, or an orc, etc. But when I read comics, the image is given to me by the artists. Perhaps variations in images are a technique that artists use to accommodate a reader’s expectations. But more importantly, changes in physiognomy (hat tip to Boris!) for me register as an expression of emotional or psychological state. I recently re-read Miller’s The Dark Knight Returns. As the inner state of the Joker changes, so does his outward appearance. It’s more than just his cosmetic choice (lipstick, etc.). It appears that even his facial bone structure changes somewhat, and at the end of the story arc, the Joker has physically transformed in ways that are impossible in the “real world.”

    Your question: “why are we tempted to treat Sale’s depiction of the Joker’s teeth as stylistic, and other depictions as an accurate representation, rather than vice versa?” Qiana’s reponse makes a lot of sense to me: that readers figure out what the rules are (whatever those rules are) and measure each image, each panel, each page against their own expectations. Your question about the difficulties of interpreting a one-panel comic is a tough one. I think that for most readers it would be a text that would be highly indeterminate: not enough information to form a set of expectations about that world. Nevertheless, the reader would bring a lot of expectations about other texts (other comics, etc.) to that image and would be able to make meaning out of it.

    • roytcook says:

      My responses to Boris and Qiana above also address some of these issues.

      Your first paragraph made me think of a related issue – how we sort out inconsistencies in fiction. For example, in the Conan-Doyle’s Holmes stories, it turns out (on a quite literal reading of the stories) that Watson has a unique war wound, but that unique wound seems to be located in two places (I think it is described as being in his leg, but also in his shoulder – obviously, the differing descriptions occur in different stories).

      Now, such inconsistencies don’t ruin the stories for us (thank goodness!) But I do feel some discomfort when asked where this unique war wound is located. The wound does play a role in some of the narratives, and it is clearly intended to be unique, but I don’t see any reason to think that, in the story world described by Conan-Doyle, that there is any reason for locating it in one of these body parts rather than the other. And I certainly don’t feel like the wound is located in both places at once! There just seems to be some sort of indeterminacy (due to an overdeterminacy) here.

      The Joker’s teeth example is similar, although not I think quite the same. We have conflicting visual descriptions of his appearance. While there are lots of contextual and narrative ‘clues’ as to his appearance, there doesn’t seem to be any definitive criteria determining which aspects of these various depictions are literal rather than metaphorical or stylistic. So the appearance of the Joker seems to be vastly underdetermined (given the very different versions of the Joker depicted by different artists).

      The reason the cases seem different, however, is that when considering Watson’s war wound, the natural (and I would say correct) thing to say is that Conan-Doyle made a mistake. This response is not tempting in the case of the Joker’s teeth, however – there is no sense in which Sale did anything wrong, mistaken, or even troubling when he drew the Joker as having completely different dentition than in previous depictions. The differing visual depictions of the Joker – while incompatible with each other if taken literally – do not in fact strike us as involving any real contradiction or inconsistency. Whatever is going on, it is something different.

  5. Patrick Maynard says:

    Roy, glad you’re raising this question. As far as I know, I’ve been the only philosopher doing so in print, notably in Drawing Distinctions (2005), pp. 225-7. I’ll email an unpublished paper that says some more, with more examples than the editor would allow in the book. Patrick

    • roytcook says:


      Thanks. Actually, I didn’t know about the discussion in Drawing Distinctions – I will definitely look at it (and include reference to it in the paper I might write for the Joker volume mentioned above). For me the issue first arose when considering how drawings of photographs work in comics – I originally discuss the Joker’s teeth (briefly) at the end of a forthcoming paper in the Journal of Aesthetics and Art Criticism (a special issue on photography). This discussion was intended to be a sort of follow-up to the brief comments made there.

      (As somewhat of a newcomer to the philosophy of art, I take it as a deeply good sign when I stumble upon something that other, more established thinkers have already been thinking about. In graduate school, after proving what I took to be my first ‘real’ substantial, novel theorem, I was probably more pleased to have learned that Tim Smiley had already proven it years earlier than I would have been had it been original and publishable!)

      Please do send me the unpublished paper!


  6. charleshatfield says:

    A very interesting first volley! Thanks, Roy and everyone.

    An added wrinkle for your consideration: it has often been argued that comics is not a neutral or transparent medium, that in fact we seldom if ever forget we’re reading a comic while we read it. I think here of Ole Frahm’s argument about comics as an inherently ironic form of representation (see “Weird Signs: Aesthetics of Comics as a Parody,” IJOCA 2.1, Spring 2000), or some of Jared Gardner’s comments on comics’ refusal of transparency (see e.g. our conversation at http://thepanelists.org/2011/04/charles-jared-talk-comics-and-narrative-theory), or of your own recent ICAF paper, Roy, on self-referentiality in comics, a quality that some have argued is fundamental to the form.

    If it is true that we seldom forget the comics-ness of a comic as we are reading it, then it may follow that comics readers are always aware of, and willing to make allowances for, cartoonists’ habits that wreak havoc with the conventions of realism. I suspect very few comics readers stop to wonder if indeed the Joker has six-inch teeth. Rather, I imagine that most of them, or at least most of those who like Tim Sale’s work, accept the rather bizarre extremes of the art as part of, essentially, Sale’s performance.

    In other words, I suspect that only readers who dislike Sale’s work, or are momentarily driven “out” of the story by Sale’s stylistic flourishes, are likely to ask (and even then only in a spirit of satiric mockery), “Since when does the Joker have six-inch teeth?”

    What I want to suggest here is that there is, at least in a metaphorical way, a performative dimension to cartooning that exempts its representations from a strict realism. I’m not an aesthetic philosopher, of course, so I’m not able to take the discussion in that direction, but I’d argue that some consideration of reader’s awareness (or self-awareness) has to part of the answer to your question. Comics readers know that they are reading comics, and so they tolerate or even expect visual flourishes that distinguish the individual styles of artists as such. Sale’s outrageous Joker dentition, for me, falls into the category of welcome graphic excess: the outlandishness of caricature, the extremes of improvisatory narrative drawing, the sheer pleasures of pushing the art farther, into more distinctively personal and more bizarre territory.

    In short, I tend to see cartooning style as an issue only partly tied to representation. So I don’t always stop to wonder if the weirdness in a drawing is supposed to be recognized as weird by the characters who inhabit the diegesis. Rather, I delight in the artist’s performance as such. This suggests to me that attempts to read comics as narrative in a medium-neutral or transmedial way are always gone to run afoul of comics’ basic refusal to play by those rules!

    • roytcook says:


      Thanks! Lots to think about here.

      I think I agree with you for the most part about reader reactions to these artistic ‘flourishes’ (both in the sense of how readers actually react and in the sense of how they should react). The worry, then, is that it is not clear how audience reactions connect up to the actual facts within the story.

      In short, it seems like the following claims are compatible:

      (1) The audience for a comic typically will not (and arguably should not) worry about whether certain aspects of the art are stylistic or realistic (where by ‘realistic’ we mean accurately portraying aspects of the fictional world described by the story).

      (2) There is nevertheless a fact of the matter regarding whether particular aspects are or are not realistic in this sense.

      In short: Just because the question is irrelevant to properly experiencing the comic as a reader, that doesn’t mean that the question is irrelevant in general.

      Compare: Whether or not mathematics is a cultural construct or an objective theory of platonic abstract objects is irrelevant to the mathematician while doing mathematics – he should just go on proving theorems. This doesn’t mean that there isn’t a fact of the matter regarding what mathematics is about, and it doesn’t mean that the question isn’t a legitimate (and important) one to ask more generally!

      Thus, I think we can still ask whether:

      (1) The Joker has normal dentition.
      (2) The Joker has six-inch teeth.
      (3) There is no fact of the matter (within the world described by the story) regarding the Joker’s teeth.

      And (so I claim) this question ought to have an answer. Furthermore, the answer presumably ought to be determinable from the content of the panels. My worry is that it just isn’t so determined.

      Furthermore, it isn’t clear to me that we even have a good grasp on when the answers to such questions are and aren’t determinate – that is: in what sort of cases should we expect an answer of type (1) or (2), rather than an answer of type (3)?


      • charleshatfield says:

        Fascinating, Roy. I agree that your initial question is far from irrelevant. Certainly I didn’t mean to simply cancel the question.

        But what I’m trying to point out here is that comic art, as graphic art, is not entirely susceptible to arguments based on representation. Questions about a represented world (diegesis) or the characters within it, the kind of questions you’re suggesting ought to be answerable “from the content of the panels,” run afoul of comic art’s continual tilting toward abstraction.

        In other words, paraphrasing Crumb, they’re all just lines on paper, folks. Even as they tell stories and portray characters. Fundamentally, comic art is an unstable graphic performance, and it is only the skill of the artists (and our own investment in the narratives) that makes us forget that fact and ask questions about realism, etc.

        What I don’t quite get is why you describe your interest as a “worry.” 🙂

    • Boris Smelov says:


      A thought occured to me in reference to your mention of the fact that we never forget we’re reading a comic book while doing so. I was recently explaining the concept of the Uncanny Valley to a friend ( http://en.wikipedia.org/wiki/Uncanny_valley), and it struck me that comic books are in a sort of uncanny valley of their own. If you look at the graph in the second section of that wikipedia page, we see a scale of familiarity, with zombies and human-like robots falling into the valley. But let’s imagine a similar graph with similarity to real life on the x-axis, and immersion on the y-axis. Real life would obviosuly be all the way on the right. Movies are asymptotically close to real life, and as such are (usually) almost perfectly immersive. Novels, on the other hand, are so far away from our experience of real life — we don’t live in a world of black symbols on a white background, after all — that when they ask for details, we can fill them in completely from our own experience. Even when a novel describes something absurd or improbable, we can at least divorce it from our everyday experience to not be disturbed, and take it on its own merits. This is much like watching a cartoon. Clearly, people in cartoons look nothing like humans and live in a world with different rules of physics and logic, but they are abstract enough that we can dismiss such discontinuities and enjoy the cartoon none the less.

      Comics, however, are like those Japanese hospitality robots, or the horrific zombies in movies like Polar Express. Those depictions of humans are too close to humanity, but not enough like humanity to be convincing. Something in our psychology moves them from the category of cartoon to the one of malicious impostor. Comics seem to be something like the narrative version of this. They are much more like reality than a novel — they depict objects in space visually, indicate motion and change visually, take pains to pantomime sound — but not enough like reality — no actual movement, the same face many times on one page, the Joker’s teeth. We cannot accept comics as like reality either because we can’t tell them apart (films), nor because we supply all the details ourselves (novels). So as we look panel to panel, as we turn pages, we are too distracted by this in-between nature of the comic book to be truly immersed. The form of the comic book is too much like reality, while the content is not enough like it.

      • roytcook says:


        I think this is right (it is also why I don’t understand why The Polar Express is a kids film, since very few films creep me out quite as much!) But I do think with comics we typically are ‘immersed enough’ in the fictional narrative being portrayed in the panels (regardless of how stylized those panels might be) to ask about what is, and isn’t, the case within the fiction, and how this relates to the literal content of the panel.

        So I guess my point is this: You (and Charles, and Patrick) aren’t really disagreeing with me (or, at the very least, I can take you points while retaining the puzzle I am interested in). Instead, I still think it makes sense to ask how long the Joker’s teeth are in the fiction, and your points just further emphasize how extremely complex the answer (if there is one) will have to be.

  7. roytcook says:

    I guess the intuition I have is that if comics, regardless of the tilt towards abstraction, nevertheless tell stories and portray characters, then there ought to be facts of the matter with regard to what happens in these stories and what the characteristics of these characters are (in the loose sense of some claim being either true, false, or undetermined). Then my ‘worry’ is that we don’t seem to have a good grasp on the connection between what is portrayed in the panel and what actually is the case in the world described by those panels.

    I guess my unspoken assumption is that the relation between comics and the worlds described by comics is similar to the relation between novels and the worlds described by novels – that ‘diagesis’ works similarly in the two cases. But your suggestions regarding comics being fundamentally ‘unstable’ might just indicate that the relations between comics and the fictional worlds they describe operate in a fundamentally different way. But then I think we need to say more about exactly how that works.

    In particular, it would be nice to have some positive account of when (if ever) we should assume that some visual depiction in a comics panel is an accurate description of objects and events in the world inhabited by Batman. Most of the views you have mentioned are negative, providing reasons for why we often don’t (and often shouldn’t) take in-panel content to be accurate depiction. But surely we are able to, and should, take such content literally some of the time?

    In short: It doesn’t seem to me that questions about realism ALWAYS run afoul of the tilt towards abstraction. And if they don’t always do so, then it is fair to ask under what conditions they do and don’t do so.


    PS: It is worth mentioning that I find the ‘performance’ metaphor as applied to comics extremely misleading. But that is a topic for another post!

  8. Steve Nelson says:

    I just wanted to add my two cents into this discussion, since it’s expanded a bit from just the issue about visual depictions of characters to their properties in general. The inconsistency about Watson is a great example, but I also like the less challenging (but still somewhat contentious) issue of whether Dumbledore from the Harry Potter stories is gay or not.

    As far as I know, there’s no explicit mention of Dumbledore’s sexual orientation in Rowling’s books, but a few years ago she ‘outed’ him at a talk at Carnegie Hall. Someone asked her if Dumbledore had ever been in love, and she said:

    “My truthful answer to you… I always thought of Dumbledore as gay. Dumbledore fell in love with Grindelwald, and that added to his horror when Grindelwald showed himself to be what he was. […] Yeah, that’s how I always saw Dumbledore. In fact, recently I was in a script read through for the sixth film, and they had Dumbledore saying a line to Harry early in the script saying I knew a girl once, whose hair…. I had to write a little note in the margin and slide it along to the scriptwriter, `Dumbledore’s gay!'” (http://www.the-leaky-cauldron.org, accessed 5/10/08)

    Now, this plays into an even wider issue in aesthetics, which is how much the intentions of the author/artist matter when it comes to the characteristics of the characters. I don’t really have a view about this, partly because I think that any view that gets it right will have to be quite nuanced and flexible with different kinds of art forms.

    But this at least raises one more question we might ask about the Joker’s teeth–what did the artist think about the Joker while he was drawing those teeth? Did he intend to be drawing the Joker as the Joker really is, or did he intend to be doing more of a caricature?

  9. Mark Herr says:

    I’ve been thinking about this for a bit, and I think it might be worth taking issue with the panel transparency thesis:

    The reason that I’d worry about it, in general, is that it seems to me that comics are at their broadest classification narrative art with a significant visual component (not visual art with a narrative component). The other sorts of cases that I’d want to put under this general classification aren’t obviously cases where the transparency thesis would be true (even though many of them are cases where it would be even more potentially applicable). For example, it’s common to see plays put on in relatively minimalist ways , not even to the extent of black box theaters, but certainly that, and we don’t feel a pull to assume that in the fictional world of the play things really look that way. (Or there are cases where the genders of the actors are reversed, or where props aren’t used or are unconvincing, or characters of one race are portrayed by actors of a different one as is often the case with Othello.) And this is occasionally true in movies as well (e.g., Dogville).

    It would be weird, though, to assert the transparency thesis when it comes to comics (which are already relatively stylized unless you want to suggest that people in them are two dimensional, or have visible pen strokes on their faces), but to deny it for plays, which actually have real, live human beings depicting human beings. I don’t mean that this isn’t necessarily a puzzle for these cases, because it clearly is, but isn’t it the same puzzle? Basically all versions of narrative art have to deal with representing only very limited parts of the world while telling a story, and ones which are significantly visual often just have to have a way of indicating (often I think just by reference to the story) what parts are and aren’t relevant. (Novels, noticeably, don’t have this problem in the same way since the author always has the option of simply not saying whether, for example, one character is taller or shorter than another. But once pictures or photographs or actual people get involved that stops being an option.)

  10. […] example of this line of thought, see Charles Hatfield’s responses to my very first PPP post here (such thoughts regarding the inherently metafictional nature of the comics art form are a recurring […]

  11. Where did u actually pick up the tips to publish ““Does
    the Joker Have Six-Inch Teeth? ”? Thanks ,Joie

  12. Adamantium says:

    “why are we tempted to treat Sale’s depiction of the Joker’s teeth as stylistic, and other depictions as an accurate representation, rather than vice versa?”
    Apologies for not reading the existing comment thread, but for me the answer is just so simple: in a word, “context.” While I’m not a comic book fan, I assume that the unusual size of the Joker’s teeth in that one comic is never referred to again, i.e. if a new edition of the comic was to be released in which he had normal teeth, there would be absolutely no callbacks in later works or foreshadowing in earlier ones that would also need to be changed in order to maintain continuity. From the fact that the unusual tooth size might as well, but for that one volume, never have existed, we can fairly confidently infer that it was a non-canonical artistic embellishment. The distinction between this constituting “substantial evidence” and the Panel Transparency Thesis being outright false is entirely semantic.

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