Lewis (1999) argued that effects of age of acquisition (AoA) are entirely attributable to cumulative frequency. He reported an instance-based model in which the number of instances of the stimulus stored in memory predicts reaction time. We note four aspects of the literature on AoA that cannot be explained by this instance-based approach. Firstly, an effect of AoA has been observed in the absence of an effect of frequency. Secondly, an effect of AoA has been observed when cumulative frequency has been controlled. Thirdly, the effect of AoA is dependent on task. Fourthly, the effect of word frequency is dependent on stimulus modality. Lewis reported an experiment in which participants make a decision based on identity-specific semantic information to celebrity faces to demonstrate an effect of the number of instances in memory, which he interpreted as an effect of AoA. We note that effects of AoA have been found in lexical and perceptual tasks, but to date all attempts to demonstrate an advantage for early-acquired items in semantic classification tasks have failed. We conclude that the effects of AoA cannot be attributed solely to the effects of cumulative frequency.