COURTSHIP 267 
proves most attractive? Even if the song is primarily a 
means of recognition or an invitation from the male, still the 
psychological effect must be that the female follows the songster 
that excites her most, and so exerts a kind of unconscious 
selection.” 
The phrase “ unconscious choice” is, however, somewhat 
unsatisfactory, especially when we remember that it is used to 
indicate the result of a direct appeal to the conscious situation. 
If, however, we say that it is perceptual choice arising from 
impulse as distinguished from ideational choice due to motive 
and volition, we see that the distinction is in line with that 
which we have drawn again and again, and which Dr, Stout so 
well emphasizes in his “‘ Manual of Psychology.” But we have 
also drawn the distinction between instinctive behaviour prior 
to individual experience, and intelligent behaviour the result of 
such experience. Under which of these classes does the be- 
haviour of the female during courtship fall? Professor Groos, 
in the further development of his hypothesis, seems to place it 
in the instinctive category. ‘Instead of a conscious or un- 
conscious choice, of which we know nothing certain,” he says,* 
“we have the need of overcoming instinctive coyness in the 
female, a fact familiar enough, but hitherto not sufficiently 
accounted for. Then the question no longer is, which among 
many males will be chosen by the female, but which one has 
the qualities that can overcome the reluctance of the female 
whom he woes. Sexual selection would then become a special 
case of natural selection.” 
I ain unable to follow Professor Groos in this view, which 
I find it rather difficult to reconcile with such statements 
as that already quoted, in which he says that the female’s 
“tantalizing change from allurement to resistance seems to 
include an element of a mischievous playfulness.” It is more 
probable that instinctive coyness and reluctance afford the 
conditions under which experience of the pleasures of courtship 
may be gained. It is said that a flirt, when taken to task for 
her conduct at ball and picnic, justified it by asking demurely 
* Op. cit., p. 244. 
