One-way convection of internal energy is a form a transport of energy but is not, as sometimes mistakenly supposed (a relic of the caloric theory of heat), transfer of energy as heat, because one-way convection is transfer of matter; nor is it transfer of energy as work. Nevertheless, if the wall between the system and its surroundings is thick and contains fluid, in the presence of a gravitational field, convective circulation within the wall can be considered as indirectly mediating transfer of energy as heat between the system and its surroundings, though the source and destination of the transferred energy are not in direct contact.