The role of memory in visual search has lately become a controversial issue. Horowitz and Wolfe (1998) observed that performance in a visual search task was little affected by whether the stimuli were static or randomly relocated every 111 ms. Because a memory-based mechanism, such as inhibition of return, would be of no use in the dynamic condition, Horowitz and Wolfe concluded that memory is likewise not involved in the static condition. However, Horowitz and Wolfe could not effectively rule out the possibility that observers adopted a different strategy in the dynamic condition than in the static condition. That is, in the dynamic condition observers may have attended to a subregion of the display and waited for the target to appear there (sit-and-wait strategy). This hypothesis is supported by experimental data showing that performance in their dynamic condition does not differ from performance in another dynamic condition in which observers are forced to adopt a sit-and-wait strategy by being presented with a limited region of the display only.