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We give a simple argument to show that no purely metric-based, relativistic formulation of Milgrom’s Modified Newtonian Dynamics (MOND) whose energy functional is stable (in the sense of being quadratic in perturbations) can be consistent with the observed amount of gravitational lensing from galaxies. An important part of the argument is the fact that reproducing the MOND force law requires any completely stable, metric-based theory of gravity to become conformally invariant in the weak field limit. We discuss the prospects for a formulation with a very weak instability.

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