The author reviews the role of play within psychotherapy. She does not discuss the formal play therapy especially popular for young children, nor play from the Jungian perspective that encourages the use of the sand tray with adults. Instead, she focuses on the informal use of play during psychotherapy as it is orchestrated intuitively. Because play--whether we use it consciously or not--is a major source for implicit learning within the social domain, the author considers it a nonspecific factor in therapeutic effectiveness that cuts across all modalities. She also suggests that play bears an important relationship to creativity, especially as it exists in the intersubjective space between therapist and patient, i.e., the fertile zone between two subjectivities in which shared making of meaning arises.