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Current theories of human memory frequently assume that the probability of recall depends on the similarity of the test context to the study context. A model for contextual fluctuation is developed that is based on Stimulus Sampling Theory. The model assumes that “context” can be represented by a set of so called contextual elements. Part of this set represents the current context. There is a continuous fluctuation between the active contextual elements (the current context) and the inactive contextual elements. During study, part of the current context is conditioned to (stored in) the memory trace. The model may be used to derive predictions for the overlap between the study and test contexts. The model is developed in the context of interference paradigms. It is shown that the model leads to a number of interesting predictions. The incorporation of this model in the SAM theory (Raaijmakers & Shiffrin 1981 …