The pūrvapakṣa of the Śūnyavāda chapter of Kumārila’s Ślokavārttika (vv. 10-63) is the longest continuous statement of a Buddhist position in that work. Philosophically, this section is of considerable interest in that the arguments developed for the thesis that the form (ākāra) in cognition belongs to the cognition, not to an external object, are cleverly constructed. Historically, it is of interest in that it represents a stage of thinking about the two-fold nature of cognition and the provenance of the ākāra that is clearly more advanced than Dignāga but not quite as sophisticated as Dharmakīrti. In particular, although one may see an anticipation of Dharmakīrti’s famous sahopalambhaniyama argument in this text, it is not yet fully spelled out.