Gains v. losses, or context dependence generated by confusion?

Tversky and Kahneman introduced the term framing for the finding that people give different answers to the same question depending on the way it is posed. One form of framing involves presenting the same outcome as either a gain or a loss. An experiment on starlings by Marsh and Kacelnik suggests that this form of framing occurs in non-humans. We argue that the experimental result demonstrates framing in the general sense of context dependence but does not provide compelling evidence of framing in terms of gains and losses. A version of scalar utility theory which is extended to include the possibility of memory errors accounts for the data and suggests future lines of research.