There have been several criticisms of Searle's idea of biological naturalism.
Jerry Fodor suggests that Searle gives us no account at all of exactly why he believes that a biochemistry like, or similar to, that of the human brain is indispensable for intentionality. Fodor thinks that it seems much more plausible to suppose that it is the way in which an organism (or any other system for that matter) is connected to its environment that is indispensable in the explanation of intentionality. It is easier to see how "the fact that one's thought about a desk is causally related with a desk can bear on the fact that person's thought is about a desk than it is to see how the fact that one's thought is made up of hydrocarbons can bear on the fact that one's thought about a desk is about a desk."
John Haugeland takes on the central notion of some set of special "right causal powers" that Searle attributes to the biochemistry of the human brain. He asks us to imagine a concrete situation in which the "right" causal powers are those that our neurons have to reciprocally stimulate one another. In this case, silicon-based alien life forms can be intelligent just in case they have these "right" causal powers; i.e. they possess neurons with synaptics connections that have the power to reciprocally stimulate each other. Then we can take any speaker of the Chinese language and cover his neurons in some sort of wrapper which prevents them from being influenced by neurotransmitters and, hence, from having the right causal powers. At this point, "Searle's demon" (an English speaking nanobot, perhaps) sees what is happening and intervenes: he sees through the covering and determines which neurons would have been stimulated and which not and proceeds to stimulate the appropriate neurons and shut down the others himself. The experimental subject's behavior is unaffected. He continues to speak perfect Chinese as before the operation but now the causal powers of his neurotransmitters have been replaced by someone who does not understand the Chinese language. The point is generalizable: for any causal powers, it will always be possible to hypothetically replace them with some sort of Searlian demon which will carry out the operations mechanically. His conclusion is that Searle's is necessarily a dualistic view of the nature of causal powers, "not intrinsically connected with the actual powers of physical objects."
Searle himself actually does not rule out the possibility for alternate arrangements of matter bringing forth consciousness other than biological brains. He also disputes that Biological naturalism is dualistic in nature in a brief essay entitled "Why I Am Not a Property Dualist".
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