In our politically correct Western culture, Modern Orthodox Jews face an unrelenting intellectual struggle. We embrace the concept that “all men are created equal”[1] and staunchly affirm the inherent moral value of mankind. Yet, even as we interact with our non-Jewish neighbors, we preach a religion that glories in exclusionism. We celebrate the concept of chosenness with the weekly Sabbath, teach it to our children, and, for those of us in YU, encounter it in our daily Jewish Studies program. Our cherished religion and prevailing intellectual culture clash wildly. How can the true faith of the benevolent and perfect God exclude 99% of humanity? Must we be different?
Moses Mendelssohn and Hermann Cohen were two of the early modern Jewish philosophers to tackle the disturbing paradox of religious and cultural beliefs. Unlike the modern day Orthodox community, however, they attempted to recast traditional Judaism as a universalistic faith that offers equal spiritual opportunity to all of mankind. Nevertheless, despite their differences from the mainstream views, we may find their quests instructive. Thrust into a conflict between religious and cultural principles, it becomes easy to lose sight of our distinctiveness in the face of our universalist atmosphere. This essay, through a study of Mendelssohn and Cohen, seeks to accentuate exclusionist aspects of Judaism. Indeed, the traditional doctrine of Jewish election that the two philosophers sacrificed in order to accomplish their goal of reconciliation serves to highlight just how Orthodox Judaism spiritually elevates the Jewish nation above the rest of the world. Though this essay makes no attempt to define the precise nature of the differences between the Jewish and non-Jewish nations nor offers alternative paths to reconcile religion with culture, it underscores an element of Orthodox Judaism all too easily deemphasized: we are the consummate spiritual “other.”
In order to understand Moses Mendelssohn (1729 – 1786), we must first outline his cultural context. Mendelssohn embodied the values of the Enlightenment — a sweeping intellectual movement infatuated with the power of rational thought. The foundation for much of our modern day epistemology, the movement established reason as the sole standard of truth. Religion, a sphere whose basic tenets were previously beyond rational critique, came under increasing fire. As the Enlightenment pioneer John Locke wrote, “If they [the devout] know it [religion] to be a truth, they must know it to be so, either by its own self-evidence to natural reason, or by rational proofs.”[2] Indeed, Christian philosophers of this age employed rational metaphysics in attempts to prove the existence of an omniscient and omnibenevolent God and to establish rational bases for morality. Since all humankind possesses the rational faculty required for this endeavor, the movement sparked a universalistic trend that lasts until today.[3] With God omnibenevolent and with rationality (the means of attaining morality and salvation) available to everyone, an environment of tolerance developed. Indeed, as Hebrew Union College professor Michael Meyer writes, “a universal human nature, universal natural law, and universal rationality” made the persecution of religious minorities, such as the Jews, “a gross anomaly.”[4]
Thus, even as anti-Semitism continued, a process known as Emancipation began, in which for the first time in over 1500 years of exile Jews gradually attained full citizenship and legal protection under European law. This newfound ability to engage in society and the widespread acceptance of the universalistic religion of reason, however, presented a grave challenge to Jewish doctrine. According to classical Jewish thought, such as that propounded by R. Sa’adyah Ga’on, religious values bifurcate into mitsvot sikhliyot — laws arrived at through reason — and mitsvot shim’iyot — law that originated in Revelation.[5] Though R. Sa’adyah presented Revelatory law as fully consistent with and accessible by reason, he affirmed it as the heritage solely of the Jewish nation. As Michael Meyer explains, Enlightenment Christians besieged this conception of Judaism and its intellectual elite with attacks on its rational foundations. If God is omnibenevolent, how does one explain the exclusionism of Revelation? If God cares for all those He created in His image, why limit it only to a “small Asiatic people”?[6] Julius Guttmann points out, “If Revelation were truly necessary for making them [religious truths] known, it would contradict the [universal] goodness of God.”[7] So, if all people with rational abilities can discover religious truths and attain ethical perfection, what need is there for Revelation in the first place? Moses Mendelssohn, both a God-fearing Jew and a leader of and spokesman for the burgeoning Haskalah (Jewish Enlightenment) movement undertakes in his masterpiece, Jerusalem, a delicate mission to legitimize Judaism as a rational, universalistic religion without sacrificing its identity. [8]
Mendelssohn affirms that religious truths are demonstrable through reason and, as a result, obtainable by any with a rational faculty.[9] Thus, Judaism remains compatible with an omnibenevolent and rational God who extends the hope of salvation to reasonable people. All aspects of religious value remain within reach of mankind. What of Revelation and the ceremonial laws that distinguish Judaism? Mendelssohn strips Revelatory law of its inherent religious value and finds a different significance for its existence. He concludes that ritual laws, rather than embody purely religious values, “relate to eternal truths, or are founded upon them, or remind man of them, and arouse mankind to be mindful of them…[it stimulates] the spirit and the soul…it connects action with contemplation, life with theory.”[10] God, in an act of divine grace, transmitted to the Jews the practices that lead to moral perfection. They safeguard morality and counter the pagan influences that have historically threatened it.[11]
Mendelssohn now confronts the problem of Judaism’s exclusivity in its claim to this Revelatory safeguard. He removes the law from the rational sphere and expresses it as a divinely legislated path to achieve religious perfection, imposed by God solely on the chosen people.[12] Though a person can find meaning in the law, he can grasp neither the otherworldly intelligence nor motivation behind their legislation. Thus, as the law transcends any rational challenge it remains, pursuant to a new Revelation, an obligation only for Jews. Whereas the Gentile finds his way to morality and ethical action through reason, the Jew supplements the rational way with that of the law.
Our outline of Mendelssohn’s basic position now complete, we can finally ask the question: What are the major implications of his philosophy? Let us restate two of his key principles: First, only rationally accessible morality and ethics, as opposed to Revelatory law, possess inherent religious value. Second, Revelatory law serves to focus and guide us on the pursuit of rational morality. The practice of the law itself, however, applies only to Jews and imparts no inherent religious value. Nathan Rotenstreich points out a glaring weakness in these tenets. He asks, if everyone can access morality purely through rational means, and if the laws of Torah are not required for salvation, “why should Jews continue to abide by them?”[13] Indeed, four of Mendelssohn’s six children chose the “rational path” toward salvation rather than the rigors of Jewish law.[14]
Moses Mendelssohn’s seduction by the forces of Enlightenment rationalism and universalism runs counter to the classical doctrine of many Orthodox Jews. Indeed, R. Aharon Lichtenstein discusses the friction sometimes created between religious doctrine and reason that Mendelssohn attempts to circumvent. He argues, “Mendelssohn’s contention that [dogma] does not figure at all [in the rational sphere within Judaism] is patently false.”[15] As opposed to Mendelssohn, who subjugates religion to reason, Modern Orthodox Jews sometimes accept tenets that conflict with reason, though we attempt to avert the collision. Thus, we can assert that all humans are created be-tselem Elokim (in the image of God) even as we grant independent value to Revelatory law. But if we elevate Revelatory law to a position of religious value, in which case we focus on the ritualistic action over and above the rational moral sentiment, then we affirm ourselves as exclusionary in the realm of religious expression. God commanded only the Jews to keep the law and bars non-Jews from sharing in its value. Thus, as the contrast with Mendelssohn’s theories sensitizes us — we place religious value on Revelation and non-rational law, and then emphasize prescribed actions alongside inner sentiment — we are truly distinguished from the rest of mankind. As God informs us in Deuteronomy, we are an am kadosh, a unique nation.[16]
Hermann Cohen (1842 – 1918), a post-Kantian Jewish German philosopher and the subject of R. Joseph B. Soloveitchik’s doctoral thesis, leaves the folds of traditional Jewish thought. Indeed, he treats God more as an idea rather than as an actual metaphysical entity. Similar to Mendelssohn, however, his philosophy of Judaism revolves around the spread of universal ethics as opposed to exclusionist legal doctrine. He contends that Judaism, especially as manifested in the Prophets, embodies the highest of ethical monotheistic principles.
What is the goal of these ethics? The ethical act is directed toward the accomplishment of an ideal: the completely ethical community. Thus, a performer of ethical acts focuses on the future moral progress of society. Though Cohen believes that Jewish texts embody the highest levels of moral value, his views disaffirm the historical significance of the Jews as a nation. As Julius Guttmann writes, according to Cohen, “We are duty bound to uphold our ancestral faith, not out of a sense of reverence for the past, but from a sense of responsibility toward the moral future.”[17] Thus, we can ask, why focus on a unique religious national past when the goal of our actions is not uniqueness? Indeed, the aim of Judaism becomes the loss of its identity. In the words of Eliezer Berkovits, “Israel is unique [in Cohen’s eyes] – for the time being – because the others [of the world] have not yet become what they are supposed to be, [ethical] mankind.”[18] The more the purpose of religion is identified with universal rational ethics, the less its distinct history matters other than as an ethical example to future generations. Though we may be unique today, our hope is to no longer be unique tomorrow.
In that same vein, Cohen’s conception of universal ethical monotheism severs the religious connection between Jews and the Land of Israel. Indeed, if Judaism aims to spread a message of morality, why should it restrict itself to a single land? As Berkovits points out, “If the state is an unnatural framework for [ethical] monotheism, statelessness is not exile; on the contrary…it is the ideal situation for the Jew.”[19] The universalistic Jews of Cohen, far from dreaming of aliyyah, instead strive to spread out amongst the nations! Cohen’s philosophy thus highlights Judaism’s inner conflict between universalism and exclusivism. If Orthodox Jews today embrace the Land and State of Israel as inherently religiously significant, as opposed to only historically or nationally important, they must also acknowledge Judaism as religiously select.
Although Western universalism and the tolerance of the modern age have led to times of unprecedented safety and opportunity for the Jewish people, especially in America, we Modern Orthodox Jews must acknowledge the inherent dangers. As our analysis of Mendelssohn and Cohen emphasizes, no matter how seductive the universal “religion of reason,” we conceive our identity as bound up in an immutable reality: We are spiritually different. As we contribute to and benefit from America, now liberated from persecutions of the past, we cannot blur lines between the end of our societal separation and the loss of our religious identity. What, however, is our precise relationship to the law, morality, and general culture of environing nations? These questions have for thousands of years been the subject of profound deliberation by major Jewish thinkers for thousands of years. Even as our varied responses to them determine our interactions with and attitudes toward the nations around us, it remains true that our actions, our beliefs, and our desires will always reflect those of an “other.”
Shmuel Lamm is a sophomore at YC majoring in Philosophy and Political Science.
[1] US Declaration of Independence
[2] John Locke, An Essay Concerning Human Understanding (London: E. Holt, 1961), Book IV, 19.
[3] Though nowadays many reject rational proofs for God, the reason-based universalism that originated with the Enlightenment remains.
[4] Michael A. Meyer, The Origins of the Modern Jew (Detroit: Wayne State University Press, 1972), 15.
[5] Sa’adyah Gaon. The Book of Beliefs and Opinions, transl. by Samuel Rosenblatt. (New
Haven, Connecticut: Yale University Press, 1948), 139 – 141.
[7] Julius Guttmann, Modern Philosophies of Judaism, transl. by David Silverman. (New York and Chicago: Holt, Rinehart, and Winston, 1964), 297.
[8] Shneyer Z. Leiman, “Rabbinic Openness to General Culture in the Early Modern Period,” in Judaism’s Encounter with Other Cultures, ed. by Jacob J. Schacter (Northvale, NJ: Jason Aronson Inc., 1997), 158.
[9] Nathan Rotenstreich, Jewish Philosophy in Modern Times (New York and Chicago: Holt, Rinehart, and Winston, 1968), 12.
[10] Moses Mendelssohn, Jerusalem, transl. by Allan Arkush (Hanover, NH: University Press of New England, 1983), 128.
[14] We can ask, furthermore, if religious value is identical to morality, then what aspect of the worshipful act expresses that value? Mendelssohn, in accordance with the thinkers of his age, holds that the core of morality and, therefore, religion, consists of inner sentiment. A person requires proper intentions of the heart in order to elevate physical action to spiritual significance. This deemphasizes, however, the role of objective action in religious worship.
[15] Aharon Lichtenstein, “Torah and General Culture: Confluence and Conflict,” Judaism’s Encounter with Other Cultures, ed. by Jacob J. Schacter (Northvale, NJ: Jason Aronson Inc., 1997), 283.
[18] Eliezer Berkovits, Major Themes in Modern Philosophies of Judaism (New York: Ktav, 1974), 25.
The Jew as the “Other”?
In our politically correct Western culture, Modern Orthodox Jews face an unrelenting intellectual struggle. We embrace the concept that “all men are created equal”[1] and staunchly affirm the inherent moral value of mankind. Yet, even as we interact with our non-Jewish neighbors, we preach a religion that glories in exclusionism. We celebrate the concept of chosenness with the weekly Sabbath, teach it to our children, and, for those of us in YU, encounter it in our daily Jewish Studies program. Our cherished religion and prevailing intellectual culture clash wildly. How can the true faith of the benevolent and perfect God exclude 99% of humanity? Must we be different?
Moses Mendelssohn and Hermann Cohen were two of the early modern Jewish philosophers to tackle the disturbing paradox of religious and cultural beliefs. Unlike the modern day Orthodox community, however, they attempted to recast traditional Judaism as a universalistic faith that offers equal spiritual opportunity to all of mankind. Nevertheless, despite their differences from the mainstream views, we may find their quests instructive. Thrust into a conflict between religious and cultural principles, it becomes easy to lose sight of our distinctiveness in the face of our universalist atmosphere. This essay, through a study of Mendelssohn and Cohen, seeks to accentuate exclusionist aspects of Judaism. Indeed, the traditional doctrine of Jewish election that the two philosophers sacrificed in order to accomplish their goal of reconciliation serves to highlight just how Orthodox Judaism spiritually elevates the Jewish nation above the rest of the world. Though this essay makes no attempt to define the precise nature of the differences between the Jewish and non-Jewish nations nor offers alternative paths to reconcile religion with culture, it underscores an element of Orthodox Judaism all too easily deemphasized: we are the consummate spiritual “other.”
In order to understand Moses Mendelssohn (1729 – 1786), we must first outline his cultural context. Mendelssohn embodied the values of the Enlightenment — a sweeping intellectual movement infatuated with the power of rational thought. The foundation for much of our modern day epistemology, the movement established reason as the sole standard of truth. Religion, a sphere whose basic tenets were previously beyond rational critique, came under increasing fire. As the Enlightenment pioneer John Locke wrote, “If they [the devout] know it [religion] to be a truth, they must know it to be so, either by its own self-evidence to natural reason, or by rational proofs.”[2] Indeed, Christian philosophers of this age employed rational metaphysics in attempts to prove the existence of an omniscient and omnibenevolent God and to establish rational bases for morality. Since all humankind possesses the rational faculty required for this endeavor, the movement sparked a universalistic trend that lasts until today.[3] With God omnibenevolent and with rationality (the means of attaining morality and salvation) available to everyone, an environment of tolerance developed. Indeed, as Hebrew Union College professor Michael Meyer writes, “a universal human nature, universal natural law, and universal rationality” made the persecution of religious minorities, such as the Jews, “a gross anomaly.”[4]
Thus, even as anti-Semitism continued, a process known as Emancipation began, in which for the first time in over 1500 years of exile Jews gradually attained full citizenship and legal protection under European law. This newfound ability to engage in society and the widespread acceptance of the universalistic religion of reason, however, presented a grave challenge to Jewish doctrine. According to classical Jewish thought, such as that propounded by R. Sa’adyah Ga’on, religious values bifurcate into mitsvot sikhliyot — laws arrived at through reason — and mitsvot shim’iyot — law that originated in Revelation.[5] Though R. Sa’adyah presented Revelatory law as fully consistent with and accessible by reason, he affirmed it as the heritage solely of the Jewish nation. As Michael Meyer explains, Enlightenment Christians besieged this conception of Judaism and its intellectual elite with attacks on its rational foundations. If God is omnibenevolent, how does one explain the exclusionism of Revelation? If God cares for all those He created in His image, why limit it only to a “small Asiatic people”?[6] Julius Guttmann points out, “If Revelation were truly necessary for making them [religious truths] known, it would contradict the [universal] goodness of God.”[7] So, if all people with rational abilities can discover religious truths and attain ethical perfection, what need is there for Revelation in the first place? Moses Mendelssohn, both a God-fearing Jew and a leader of and spokesman for the burgeoning Haskalah (Jewish Enlightenment) movement undertakes in his masterpiece, Jerusalem, a delicate mission to legitimize Judaism as a rational, universalistic religion without sacrificing its identity. [8]
Mendelssohn affirms that religious truths are demonstrable through reason and, as a result, obtainable by any with a rational faculty.[9] Thus, Judaism remains compatible with an omnibenevolent and rational God who extends the hope of salvation to reasonable people. All aspects of religious value remain within reach of mankind. What of Revelation and the ceremonial laws that distinguish Judaism? Mendelssohn strips Revelatory law of its inherent religious value and finds a different significance for its existence. He concludes that ritual laws, rather than embody purely religious values, “relate to eternal truths, or are founded upon them, or remind man of them, and arouse mankind to be mindful of them…[it stimulates] the spirit and the soul…it connects action with contemplation, life with theory.”[10] God, in an act of divine grace, transmitted to the Jews the practices that lead to moral perfection. They safeguard morality and counter the pagan influences that have historically threatened it.[11]
Mendelssohn now confronts the problem of Judaism’s exclusivity in its claim to this Revelatory safeguard. He removes the law from the rational sphere and expresses it as a divinely legislated path to achieve religious perfection, imposed by God solely on the chosen people.[12] Though a person can find meaning in the law, he can grasp neither the otherworldly intelligence nor motivation behind their legislation. Thus, as the law transcends any rational challenge it remains, pursuant to a new Revelation, an obligation only for Jews. Whereas the Gentile finds his way to morality and ethical action through reason, the Jew supplements the rational way with that of the law.
Our outline of Mendelssohn’s basic position now complete, we can finally ask the question: What are the major implications of his philosophy? Let us restate two of his key principles: First, only rationally accessible morality and ethics, as opposed to Revelatory law, possess inherent religious value. Second, Revelatory law serves to focus and guide us on the pursuit of rational morality. The practice of the law itself, however, applies only to Jews and imparts no inherent religious value. Nathan Rotenstreich points out a glaring weakness in these tenets. He asks, if everyone can access morality purely through rational means, and if the laws of Torah are not required for salvation, “why should Jews continue to abide by them?”[13] Indeed, four of Mendelssohn’s six children chose the “rational path” toward salvation rather than the rigors of Jewish law.[14]
Moses Mendelssohn’s seduction by the forces of Enlightenment rationalism and universalism runs counter to the classical doctrine of many Orthodox Jews. Indeed, R. Aharon Lichtenstein discusses the friction sometimes created between religious doctrine and reason that Mendelssohn attempts to circumvent. He argues, “Mendelssohn’s contention that [dogma] does not figure at all [in the rational sphere within Judaism] is patently false.”[15] As opposed to Mendelssohn, who subjugates religion to reason, Modern Orthodox Jews sometimes accept tenets that conflict with reason, though we attempt to avert the collision. Thus, we can assert that all humans are created be-tselem Elokim (in the image of God) even as we grant independent value to Revelatory law. But if we elevate Revelatory law to a position of religious value, in which case we focus on the ritualistic action over and above the rational moral sentiment, then we affirm ourselves as exclusionary in the realm of religious expression. God commanded only the Jews to keep the law and bars non-Jews from sharing in its value. Thus, as the contrast with Mendelssohn’s theories sensitizes us — we place religious value on Revelation and non-rational law, and then emphasize prescribed actions alongside inner sentiment — we are truly distinguished from the rest of mankind. As God informs us in Deuteronomy, we are an am kadosh, a unique nation.[16]
Hermann Cohen (1842 – 1918), a post-Kantian Jewish German philosopher and the subject of R. Joseph B. Soloveitchik’s doctoral thesis, leaves the folds of traditional Jewish thought. Indeed, he treats God more as an idea rather than as an actual metaphysical entity. Similar to Mendelssohn, however, his philosophy of Judaism revolves around the spread of universal ethics as opposed to exclusionist legal doctrine. He contends that Judaism, especially as manifested in the Prophets, embodies the highest of ethical monotheistic principles.
What is the goal of these ethics? The ethical act is directed toward the accomplishment of an ideal: the completely ethical community. Thus, a performer of ethical acts focuses on the future moral progress of society. Though Cohen believes that Jewish texts embody the highest levels of moral value, his views disaffirm the historical significance of the Jews as a nation. As Julius Guttmann writes, according to Cohen, “We are duty bound to uphold our ancestral faith, not out of a sense of reverence for the past, but from a sense of responsibility toward the moral future.”[17] Thus, we can ask, why focus on a unique religious national past when the goal of our actions is not uniqueness? Indeed, the aim of Judaism becomes the loss of its identity. In the words of Eliezer Berkovits, “Israel is unique [in Cohen’s eyes] – for the time being – because the others [of the world] have not yet become what they are supposed to be, [ethical] mankind.”[18] The more the purpose of religion is identified with universal rational ethics, the less its distinct history matters other than as an ethical example to future generations. Though we may be unique today, our hope is to no longer be unique tomorrow.
In that same vein, Cohen’s conception of universal ethical monotheism severs the religious connection between Jews and the Land of Israel. Indeed, if Judaism aims to spread a message of morality, why should it restrict itself to a single land? As Berkovits points out, “If the state is an unnatural framework for [ethical] monotheism, statelessness is not exile; on the contrary…it is the ideal situation for the Jew.”[19] The universalistic Jews of Cohen, far from dreaming of aliyyah, instead strive to spread out amongst the nations! Cohen’s philosophy thus highlights Judaism’s inner conflict between universalism and exclusivism. If Orthodox Jews today embrace the Land and State of Israel as inherently religiously significant, as opposed to only historically or nationally important, they must also acknowledge Judaism as religiously select.
Although Western universalism and the tolerance of the modern age have led to times of unprecedented safety and opportunity for the Jewish people, especially in America, we Modern Orthodox Jews must acknowledge the inherent dangers. As our analysis of Mendelssohn and Cohen emphasizes, no matter how seductive the universal “religion of reason,” we conceive our identity as bound up in an immutable reality: We are spiritually different. As we contribute to and benefit from America, now liberated from persecutions of the past, we cannot blur lines between the end of our societal separation and the loss of our religious identity. What, however, is our precise relationship to the law, morality, and general culture of environing nations? These questions have for thousands of years been the subject of profound deliberation by major Jewish thinkers for thousands of years. Even as our varied responses to them determine our interactions with and attitudes toward the nations around us, it remains true that our actions, our beliefs, and our desires will always reflect those of an “other.”
Shmuel Lamm is a sophomore at YC majoring in Philosophy and Political Science.
[1] US Declaration of Independence
[2] John Locke, An Essay Concerning Human Understanding (London: E. Holt, 1961), Book IV, 19.
[3] Though nowadays many reject rational proofs for God, the reason-based universalism that originated with the Enlightenment remains.
[4] Michael A. Meyer, The Origins of the Modern Jew (Detroit: Wayne State University Press, 1972), 15.
[5] Sa’adyah Gaon. The Book of Beliefs and Opinions, transl. by Samuel Rosenblatt. (New
Haven, Connecticut: Yale University Press, 1948), 139 – 141.
[6] Meyer, 37.
[7] Julius Guttmann, Modern Philosophies of Judaism, transl. by David Silverman. (New York and Chicago: Holt, Rinehart, and Winston, 1964), 297.
[8] Shneyer Z. Leiman, “Rabbinic Openness to General Culture in the Early Modern Period,” in Judaism’s Encounter with Other Cultures, ed. by Jacob J. Schacter (Northvale, NJ: Jason Aronson Inc., 1997), 158.
[9] Nathan Rotenstreich, Jewish Philosophy in Modern Times (New York and Chicago: Holt, Rinehart, and Winston, 1968), 12.
[10] Moses Mendelssohn, Jerusalem, transl. by Allan Arkush (Hanover, NH: University Press of New England, 1983), 128.
[11] Guttmann, 301.
[12] Rotenstreich, 14.
[13] Rotenstreich, 29.
[14] We can ask, furthermore, if religious value is identical to morality, then what aspect of the worshipful act expresses that value? Mendelssohn, in accordance with the thinkers of his age, holds that the core of morality and, therefore, religion, consists of inner sentiment. A person requires proper intentions of the heart in order to elevate physical action to spiritual significance. This deemphasizes, however, the role of objective action in religious worship.
[15] Aharon Lichtenstein, “Torah and General Culture: Confluence and Conflict,” Judaism’s Encounter with Other Cultures, ed. by Jacob J. Schacter (Northvale, NJ: Jason Aronson Inc., 1997), 283.
[16] Deut. 26:19, 28:9
[17] Guttmann, 359.
[18] Eliezer Berkovits, Major Themes in Modern Philosophies of Judaism (New York: Ktav, 1974), 25.
[19] Berkovits, 24.