Pulvermüller assumes that words are represented as associations of two cell assemblies formed according to Hebb's coincidence rule. This seems to correspond to the linguistic notion that words consist of lexemes connected to lemmas. Standard examples from theoretical linguistics, however, show that lemmas and lexemes have properties that go beyond coincidence-based assemblies. In particular, they are inherently disposed toward combinatorial operations; push-down storage, modelled by decreasing reverberation in cell assemblies, cannot capture this. Hence, even if the language capacity has an associationist characterization at some level, it cannot just be co-occurrence-based assembly formation.