in reply to Why so strict?
I'm guessing that's a mocked up example derived from some "real" code because as it stands it doesn't make sense on a bunch of levels.
1/ say doesn't return much that's useful (true on success, but printing to the console wil pretty much always succeed). Both invocations of say will return the same result so $c gets the same value regardless.
2/ Maybe what you really wanted was to say $c, not the contents of $c. In that case you should either have written "\$c ..." or '$c ...'.
3/ We don't usually use & in function calls now, just write func().
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