Foundationalism about justification has historically enjoyed widespread acceptance among philosophers despite equally widespread disagreement about how foundational justification is possible. It is widely agreed that all knowledge must by justified by a foundation that does not stand in need of justification, but philosophers disagree on what could provide that foundation. Internalists, who look for justification in factors internal to rational agents, tend to agree that foundational justification is provided by seemings, or the way things seem to one to be. This view has most commonly gone by the name 'Phenomenal Dogmatism' although variations of it have been defended. Phenomenal dogmatism has been criticized for being too permissive with regard to the states it counts as able to confer foundational justification. In this paper I will consider one attempt, offered by Berit Brogaard, to revise phenomenal dogmatism in response to these criticisms. I will argue that Brogaard's revised view has significant problems of its own. Specifically, it does not account for problems arising from the possibility of cognitively penetrated perceptions. / Master of Arts