If you create an infinite loop or somesuch thing by overriding create, you should reconsider your strategy

I agree. So, who needs create. It's a silly name. The same could be said about new....so in the same type of situation, I can't override new in the subclass? That's wrong IMHO. There should never be a situation where I can't provide my own new(). And I don't really think and SUPER class methods calling new on itself or it's subclass is quite kosher either; but it happens.