Fodor has argued that observation is theory neutral, since the perceptual systems are modular, that is, they are domain‐specific, encapsulated, mandatory, fast, hard‐wired in the organism, and have a fixed neural architecture. Churchland attacks the theoretical neutrality of observation on the grounds that (a) the abundant top‐down pathways in the brain suggest the cognitive penetration of perception and (b) perceptual learning can change in the wiring of the perceptual systems. In this paper I introduce a distinction between sensation, perception, and (...) observation and I argue that although Churchland is right that observation involves top‐down processes, there is also a substantial amount of information in perception which is theory‐neutral. I argue that perceptual learning does not threaten the cognitive impenetrability of perception, and that the neuropsychological research does not provide evidence in favor of the top‐down character of perception. Finally, I discuss the possibility of an off‐line cognitive penetrability of perception. (shrink)