Fletcher and Vaughn (this issue) describe recent changes to federal laws governing special education eligibility for specific learning disabilities focusing on what is commonly known as response to intervention (RTI). We are concerned about what appears to us as a selective review of empirical support for RTI and a consequently overly optimistic view of many practical issues surrounding the implementation of RTI models that neglects the potential negative long-term impact on the range of students with and without a learning disability. These include (1) the lack of a firm evidence base reflected in vagaries and ambiguity of the critical details of the model in practice; (2) the worrisome shortcomings of the RTI process as a means of diagnosis or determination of a disability; (3) the contextual, situation-dependent nature of who is identified; (4) the seeming lack of consideration of bright struggling readers in the RTI process; and (5) the apparent lack of student-based data to guide the most effective choice of approaches to, and specific components of, intervention.