Though separate from the historical debate regarding the status of universals, there has been significant debate regarding the conceptual character of experience since the release of "Mind and World" by John McDowell in 1994. McDowell's touchstone is the famous refutation that Wilfrid Sellars provided for what he called the "Myth of the Given"—the notion that all empirical knowledge is based on certain assumed or 'given' items, such as sense data. Thus, in rejecting the Myth of the Given, McDowell argues for perceptual conceptualism, according to which perceptual content is conceptual "from the ground up", that is, all perceptual experience is a form of conceptual experience. McDowell's philosophy of justification is considered a form of foundationalism: it is a form of foundationalism because it allows that certain judgements are warranted by experience and it is a coherent form of this view because it maintains that experience can warrant certain judgements because experience is irreducibly conceptual.