Expands on a view of "Valueless Features"--which suggests that the second-language (L2) initial state is distinct from natural language grammars because transfer obliterates the values associated with features located under functional heads--by examining data on the L2 acquisition of English by speakers of German. Despite important differences between French-English and the German-English data, Valueless Features extend in a fairly natural way. (35 references) (Author/CK)