The relationship between thinking and learning constitutes one of the fundamental problems of cognitive psychology. Though there is an obvious overlap between the domains of thinking and learning, it seems more productive to consider learning as being predominantly acquisition while considering thinking as the application of the existent concepts and strategies to new tasks. This distinction acquires a new meaning in the context of the dynamic assessment (DA) approach, which has often used the notions of learning potential and cognitive modifiability interchangeably. An illustrative assessment study of 88 primary school students shows that not all students who demonstrate high learning potential reveal a propensity toward cognitive modifiability and vice versa. Educational implications for the design, selection and application of DA procedures are discussed. (Contains 2 tables and 1 figure.)