Patient H.M. can form new memories and maintain them for a few seconds before they fade away. From a neurobiological perspective, this amnesia is usually attributed to the absence of memory consolidation, that is, memory storage. An alternative view holds that this impairment reflects that the memory is present but cannot be retrieved. This debate has been unresolved for decades. Here, we will consider some of the arguments that make it so difficult to resolve this issue. In addition, some recent work will be discussed that has gone beyond the shortcomings of previous experimental approaches to strongly suggest that amnesia can be due to a retrieval impairment that can be overcome with a reminder--an example of memories fading in. Finally, this review will suggest some strategies for resolving this debate.