A distinction between physical constitution and perceptual response is plausible and scientifically useful. A division into wholly objective primary qualities and wholly unreal secondary qualities is much harder to defend. These are different interpretations of the primary and secondary qualities distinction.
John Locke attributes extension, solidity, shape, number and motion to bodies as primary qualities. Secondary qualities are powers to produce sensations through the constitution of bodies: a body's power to produce a colour experience is distinct from the experience itself. This distinction need not make the power unreal. Nor should the further resemblance thesis, that ideas of primary qualities resemble their causes, be confused with the more modest claim that bodily constitution explains experience.[ref]
A modern model of colour perception shows what can be retained. For a nonfluorescent surface in fixed viewing geometry, a simplified cone cell response is
Here is the incident spectral irradiance, the spectral reflectance, and an effective sensitivity for one of three cone cell classes. Neural processing and adaptation also matter, so these responses are not a complete identification of perceived colour. Nevertheless, the model separates the surface, illumination and observer rather than assigning every experienced variation to a changing surface.
It follows that one surface can produce different responses under different illumination. Conversely, distinct spectral reflectance functions can produce the same three responses for a specified illuminant and observer, a case of metamerism. Three weighted integrals do not in general uniquely determine a whole function. Thus identifying experienced colour with one intrinsic surface property loses both the dependence on the observer and the many-to-one character of the response.
The scientific benefits are concrete. A comparison of paints should specify illumination and observer conditions. A measurement intended to characterize a material can instead estimate its spectral reflectance, preserving information that a single colour match discards. In both cases the distinction tells an investigator what to hold fixed and what to vary. It organizes experiments and explains disagreement without requiring that one observer be hallucinating.
However, perceptual variability alone does not distinguish primary qualities from secondary qualities. George Berkeley points out that apparent extension and shape also change with viewpoint and perceiver.[ref] A circular disc yields different projected shapes at different viewing angles. The stable object is inferred through a model of that variation; it is not simply copied into experience. Primary qualities therefore have no automatic exemption from the interpretative work involved in perception.
Nor is relationality equivalent to subjectivity. In special relativity, measured length depends on an inertial frame, but relations between such measurements are tightly constrained. Conversely, a disposition to affect a specified perceiver under specified conditions can be an objective physical fact. Classifying a property as relational does not settle whether it is real, measurable or explanatory.
The best distinction is consequently functional and revisable: distinguish the experience to be explained from physical properties and relations used to explain it. That retains the scientific benefits of separating constitution, environment and response. It does not establish an immutable list of primary qualities, a simple resemblance relation between experience and object, or a proof of scientific realism.

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