Aron Gurwitsch's interpretation of Husserl's doctrine of the noema depends upon a criticism of Husserl's philosophy of perception, specifically of the distinction Husserl makes between the intentional essence and the sensuous matter within the perceptual act or, in Husserl's alternate terminology, the perceptual apprehension and its sensuous contents. Gurwitsch contends that this distinction presupposes a phenomenological version of the constancy-hypothesis,¹ and his critique rests, consequently, upon a phenomenological reinterpretation of Gestalt psychology's critique of traditional dualisms in psychology and their adherence to the constancy-hypothesis.²