the strategy of employing the same morphosyntactic structure for both the noun complement clause construction and the relative clause construction. Example: Japanese uses the noun-modifying clause strategy – the same externally headed strategy is used for both the relative clause construction ([gakusei ga katta] hon 'the book that the student bought') and the noun complement clause construction ([gakusei ga hon o katta] zizitu 'the fact that the student bought the book'). (Section 19.2.4)