A physiological model for short-term memory (STM) based on dual theta (5–10 Hz) and gamma (20–60 Hz) oscillation was proposed by Lisman and Idiart (1995). In this model a memory is represented by groups of neurons that fire in the same gamma cycle. According to this model, capacity is determined by the number of gamma cycles that occur within the slower theta cycle. We will discuss here the implications of recent reports on theta oscillations recorded in humans performing the Sternberg task. Assuming that the oscillatory memory models are correct, these findings can help determine STM capacity.