This report attempts to determine to what extent the thesis that observation is theory-dependent holds in the area of verbal learning theory. This area was chosen because: (1) a philosophical criticism of verbal learning theory will contribute to the difficult task of investigating the border area between philosophy and psychology; and (2) no one theory has yet emerged as pre-eminent so that the difficulties of handling competing theories are not existent. While no "theory" has yet been produced three general positions have emerged: gestaltism, functional associationism, and transformational linguistics. Discussed are: (1) some of the grounds for suspecting that the theory-dependency thesis holds for verbal learning theory; (2) that theoretical terms must be ultimately definable in terms of operations describable in some theory-neutral observation language; (3) some of the criticisms of operationalism to the more general question of whether there can be a theory-neutral observation language at all; and (4) details of the controversy between Skinner for the associationists and Chomsky for the transformational linguists. An appendix includes a paper which explains the philosophical underpinnings of the theory-dependency thesis as presented by Wittgenstein. (Author/CJ)