According to Kant’s lectures on logic, the formation of empirical concepts consists in the logical acts of comparison, reflection, and abstraction. This paper defends the tenability of Kant’s account by solving two prominent difficulties identified by commentators. Firstly, I justify Kant’s chronological presentation of the three acts by clarifying two meanings of ‘comparison’ in his writings: while comparison-1 refers to apprehension in relation to apperception and precedes reflection, comparison-2 refers to a twofold operation comprising both comparison-1 and reflection, such that (...) its completion presupposes reflection. Secondly, to unravel an alleged ‘circularity’ in Kant’s account, I propose multiple interactions between comparison-1, which can be entirely arbitrary, and reflection, which examines the compared representations according to the imagination’s free agreement with the understanding, namely, a lawfulness without law. By means of such interactions, we experiment back and forth and lawfully generate an empirical concept without relying on conceptual guidance. (shrink)