This article is a critical review of Bode's (2020) recent work on linguistic minimalism, according to which UG constitutes the structure-building operation Simplest Merge (Epstein, Kitahara, and Seely (2015, 2017) ). Bode argues that the islandhood of adjuncts is a function of the way a confl ict in "labeling" the set of two non-heads, i. e. XP, YP, resolves (Chomsky (2013 (Chomsky (, 2015) ) ). The key proposal is her equation of labeling with "Transfer" (Chomsky (2004 (Chomsky (, 2008) ) ). I scrutinize the workings of Simplest Merge and labeling/Transfer, taking up several contingent theoretical and empirical issues. I conclude that despite the challenges, Bode's general conception of UG is one to be pursued further.
Tomio Hirose (Sun,) studied this question.