This paper is an investigation of freezing effects, that is, cases where an element (e.g. an object or a subject, or an element within it) is unable to move from a certain structural position. An account of the most prominent properties of freezing in Norwegian is followed by a comparative study of primarily English and Norwegian indirect objects, with important consequences for the general approach to indirect objects. Although recent analyses capture central properties of indirect objects, they fall short of accounting for freezing properties, seen here in terms of agreement properties, most notably Case agreement. It is shown that both subjects and indirect objects disallow sub-extraction in both English and Norwegian ; however, unlike English, Norwegian allows the indirect object to A-bar move. This relates to the question of whether Case is structural or inherent. As such, this paper offers a new argument in favor of Case as a central ingredient in deriving freezing effects. , and two anonymous JL referees. Thanks are also due to Cedric Boeckx for his support and constructive suggestions, and especially to Caroline Heycock, Norbert Hornstein, Howard Lasnik and Juan Uriagereka for all their valuable comments and for ensuring that my writing is much clearer than it would otherwise have been.[2] This is a construction similar to the was für construction in many Germanic languages.