Many measures of human verbal behavior deal primarily with semantics (e.g., associative priming, semantic priming). Other measures are tied more closely to orthography (e.g., lexical decision time, visual word-form priming). Semantics and orthography are thus often studied and modeled separately. However, given that concepts must be built upon a foundation of percepts, it seems desirable that models of the human lexicon should mirror this structure. Using a holographic, distributed representation of visual word-forms in BEAGLE [12], a corpus-trained model of semantics and word order, we show that free association data is better explained with the addition of orthographic information. However, we find that orthography plays a minor role in accounting for cue-target strengths in free association data. Thus, it seems that free association is primarily conceptual, relying more on semantic context and word order than word form information.