The "parameter-free", "local effects" theory of Scholz and Kraft is an extension to mammalian cells of the theory of RBE for dry enzymes and viruses of Butts and Katz. Its claim for parameter freedom has been challenged elsewhere. Here we examine its conceptual base and find errors in its use of the physical concept of cross section and its neglect of the radiobiological relationship between target size and radiosensitivity in evaluating the radiation damage to "point targets".