Agree(X, Subj) accounts for all agreement in West Germanic: complementizer agreement (CA) results from an Agree relation between uninterpretable φ-features of Fin0 (Rizzi 1997) and φ-features of the subject; subject-verb agreement (SA) spells out uninterpretable φ-features of T0 on V0 raised to T0, even in OV clauses (Haegeman 2000). Although DPs need Case to participate in Agree relations (Chomsky 2000), deletion-marked Case remains syntactically accessible until the next strong phase (Pesetsky and Torrego 2001), allowing CA and SA to cooccur. In Frisian, ‘that’ cannot agree in embedded VO clauses because it is in Force; the verb is in Fin0, bearing CA (contra Zwart 1997).

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