because they are above layer IV.

Brodmann has this to say about layer II:

"The most inconstant or variable layers are Meynert's two so-called granular layers, layers II and IV of the basic pattern (the outer and inner granular layers). They alter their original cytoarchitectonic features so extensively during ontogeny that it is often only possible to correlate their mature structure with their primitive tectogenetic form by following the whole developmental sequence. Extreme variation, such as the disappearance or doubling of

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