Recently Merkine, Mo and Kalnay (1985) have re-examined the possible existence of Fofonoff's (1954) steady free inertial solution and the role of Fofonoff's mode in numerical circulation models after Veronis (1966). Merkineet al. conclude that the Fofonoff mode does not occur, that such a mode would be barotropically unstable and that resemblances between numerical circulations and Fofonoff's mode are more dependent upon the natures of forcing and dissipation. On the contrary, I suggest that Fofonoff's mode very naturally does emerge and that forcing and dissipation only impede the full realization of Fofonoff's mode. Moreover, statistical mechanical arguments from Salmon, Holloway and Hendershott (1976) show that the Fofonoff mode is expected to co-exist with a transient eddy field whose statistics are in equilibrium with the mode; thus bartotropic instability does not argue for non-realization of Fofonoff's mode.