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Theory/Quine/Duhem: the contestability through experience (E.g. here is a black swan) cannot be distributed among the sentences of the theory.
This is actually an argument for the indeterminacy of meaning.
McDowellVsQuine: but the argument is only tenable if our observation language is distinct form our theoretical language, so that the relevant experience is not already expressed in the theoretical language. ((s) see indeterminacy.)
Geist und Welt Frankfurt 2001