Can complex structures be generically stable in a noisy world?

Toom's "NEC" cellular automaton is a simple model or dynamical "rule" that succeeds in producing two-phase coexistence generically, i.e., over a nonzero fraction of its two-dimensional parameter space. This paper reviews and explains the behavior of the NEC rule and discusses the implications of the rule for the generic stabilization of complex structures. Much of the discussion is based on work performed almost twenty years ago by Charles Bennett and the author.