A common response has been to argue that memory dysfunction only occurs in those who don’t recover from depression and that it is caused by the depression not the ECT. The term ‘subjective memory loss’ has become common in the literature. In 1995, however, McElhiney et al. (1995) identified five previous studies showing no significant relationship between anterograde or retrograde amnesia and clinical change after ECT. Their own study found that retrograde amnesia was related to the ECT and not to mood state before or after ECT. Another study (Neylan et al., 2001), which acknowledged that “the memory loss for events immediately preceding, during and after the treatment course can be permanent”, found “no significant correlation between the change in depression rating and the change in any of the 12 cognitive measures”. A recent review concluded that “There is no evidence of a correlation between impaired memory/cognition after ECT and impaired mood, much less a causal relationship” (Robertson & Pryor, 2006). The only large scale prospective study found no relationship between severity of depression and 19 of the 22 cognitive measures employed (Sackeim et al., 2007). Even if there was a correlation the causal relationship might have been in the other direction. It can be depressing to lose one’s memory.