The article “Memories of Things Unseen” (2004) by Elizabeth F. Loftus explores the idea that human memory is both malleable and fallible. Throughout the article, Loftus makes claims about the nature of human memory, particularly in regard to the uncertainty and unreliability that she believes to be an inherent quality of memory. Loftus argues that memory can not only be modulated by the introduction of new information, but completely false memories can be implanted in individuals so strongly that they are believed to be fact. To support these assertions, Loftus refers to a number of scientific studies and research. For example, to support her claim that false memories can be wilfully implanted into subjects, Loftus cites a study undertaken by “memory investigators” in the 1990’s which showed that “After being fed suggestive information that ostensibly came from their relatives, a significant minority of subjects came to accept all or part of the suggestion and claimed it as their own experience” (Loftus, 2004, p. 145). This forms a clear example of false-memory.