The Problem of the Speckled Hen is a potential stumbling-block for any philosophical treatment of perceptual certainty. Roderick Chisholm argues in the third edition of his Theory of Knowledge (Prentice Hall, 1989) that the Speckled Hen is not a problem for the account of the perceptually certain contained in that book. In this note, I argue that Chisholm’s defense of his account does not work.