Women’s Zimmun: An Addendum
This article is intended not as a response, but rather as an addendum to Gabrielle Hiller’s well-written article, “Women’s Zimmun: It’s Just Not that Radical.”[i] In no way do I wish to be overly critical or to challenge her general thesis, which shows a basis in Halakhah for women’s zimmun. It is not a question of whether women’s zimmun is permitted, but rather a question of whether women are required to perform zimmun.[ii]I simply wish to offer additional relevant and necessary sources which were not presented in Ms. Hiller’s analysis.[iii]
This article will clarify and address six additional factors: 1) Rambam’s view in light of Ms. Hiller’s discussion of whether zimmun is obligatory or optional for women (any halakhic discussion should mention the position of Rambam); 2) implications stemming from Berakhot 45b, with emphasis on the positions of R. Simhah of Speyer[iv] and R. Yehudah ha-Kohen;[v] 3) permissibility of adding the word Elokeinu, a name of God, to the liturgy of the zimmun when there is a group of ten women present at a meal; 4) a clarification on the view of R. Yosef Karo in Shulhan Arukh, and the basis for his opinion; 5) the separation of three women to form their own zimmun when eating together with three men; and 6) other commentators who obligate women in zimmun besides for the authorities mentioned by Ms. Hiller (Rosh and Gra).
1) Rambam writes in the fifth chapter of Hilkhot Berakhot that “women, slaves and children[vi] are not included in a zimmun; rather, they should perform zimmun separately…”[vii] The language of Rambam here is decidedly ambiguous, for he does not mention the words hiyyuv (obligation) or reshut (optional act) at all. However, Rambam’s position can be ascertained in light of the entire fifth chapter. As one literary whole, this chapter indicates that Rambam holds that women are obligated in zimmun. As he writes in the first halakhah of the chapter, “women… are obligated in birkat ha-mazon.”[viii] Rambam continues and states in the sixth halakhah that “all are obligated in the blessing of zimmun in the same way that they are obligated to say the birkat ha-mazon.”[ix] Thus, for Rambam, a person obligated in birkat ha-mazon is also obligated in zimmun. This indicates that women, too, have an obligation in zimmun.[x] It is worth noting here that the dispute in Berakhot 20b over whether women’s obligation in birkat ha-mazon is rabbinic or biblical[xi] should have no bearing on the matter for Rambam or for the other rishonim, such as Rosh and Rokeah,[xii] who maintain that zimmun is obligatory for women. Even if the Halakhah would dictate that women are obligated in birkat ha-mazon only rabbinically, women would still be obligated to say zimmun because they are obligated to say birkat ha-mazon. Birkat ha-mazon and zimmun have a correlative relationship.[xiii] Additionally, Rambam’s omission of a particular Talmudic phrase from this chapter supports the position that he holds women are obligated in zimmun. Berakhot 45b states that if “they [women and slaves] want to join together, we do not allow them…” Tosafot comments that the language of “if they want to” further implies that women’s zimmun is voluntary.[xiv] However, Rambam does not include this expression, implying further that he believes that women are obligated in zimmun.[xv] Further, Me’iri cites Rambam as holding that women are obligated in zimmun.[xvi]
2) Establishing the obligation for zimmun, the Mishnah in Berakhot 45a states: “If three persons have eaten together, it is their duty to invite [one another to say birkat ha-mazon].”[xvii] The same Mishnah later continues, “women, children, and slaves may not be counted in the three.”[xviii] Despite the fact that this subsequent clause can be interpreted to refer back to the “three persons” who “have eaten together”– indicating that the Mishnah prohibits women from joining a men’s zimmun— the Beraita in Berakhot 45b and its subsequent Talmudic discussion seems to imply otherwise. The Beraita states: “Women by themselves invite one another, and slaves by themselves invite one another, but women, slaves, and children together, even if they desire to invite one another, may not do so.”[xix] This Tannaitic statement does not indicate that women cannot join men, but rather it indicates that women cannot join a zimmun of slaves or children! The Gemara asks on the Beraita: “Why not [join women with slaves or children]?”[xx] The Gemara responds, mi-shum peritsuta, “because it might lead to promiscuity.”[xxi] Commentators point out that this concern is on account of the slaves.[xxii] Berakhot 45b, therefore, is specifically concerned with groupings of slaves and women in order to guard against immoral behavior. The simple reading of the Gemara says nothing about women and free men; it only refers to women and slaves.
Despite normative halakhic practice,[xxiii] the conclusion of Berakhot 45b seems to indicate that a grouping of free-men and women would constitute a legitimate zimmun[xxiv] because the fear of “promiscuity” refers only to a grouping of women and slaves. This seems to be the view of R. Simhah of Speyer, as quoted by Mordekhai.[xxv] Mordekhai writes that “R. Simhah used to include a woman with men [to meet the requisite number of people necessary] for zimmun.”[xxvi] To clarify, he[xxvii] continues, “and even if you say that women are only obligated [in birkat ha-mazon] rabbinically, as is proposed in the chapter Mi she-Meito,[xxviii] [the Gemara’s discussion] was only in regard to fulfilling others’ obligations; but, for simply joining in zimmun, it is certainly appropriate to include a woman, so the group can recite the name of God in the zimmun.”[xxix] According to this explanation, in addition to joining a woman with two men, it is even permitted to include a woman with nine men, creating an obligation to recite Elokeinu in the zimmun.[xxx]
R. Yehudah ha-Kohen also included women in the requisite number necessary for zimmun (presumably both three and ten). R. Ya’akov ben Asher[xxxi] cites R. Yehudah ha-Kohen as follows: “R. Yehudah ha-Kohen instructed halakhah le-ma’aseh (practical Halakhah) to include a woman [in the requisite number necessary] for zimmun.[xxxii] R. Yehudah ha-Kohen explains that if a woman’s status for inclusion in zimmun were under question, then the Gemara in Berakhot 20b, which discusses whether women have a rabbinic or biblical obligation to recite birkat ha-mazon, should have also asked, “can women join for zimmun,” and not only, “can women fulfill the obligation of men in birkat ha-mazon?” Since the Gemara is only concerned with the question of fulfillment, it must hold that women can join with men for zimmun.[xxxiii]
R. Me’ir of Rothenburg rejects the view of R. Yehudah ha-Kohen and states that women cannot be counted with men for zimmun.[xxxiv] Normative halakhic practice has adopted the position of R. Me’ir of Rothenburg, prohibiting women from making up the requisite number required (either three or ten) for zimmun.[xxxv] Despite this, it is important to acknowledge that the simple understanding of Berakhot 45b implies that a grouping of men and women does, in some way, constitute a grouping for zimmun.[xxxvi]
3) The next topic to address is whether or not a group of ten women who recite zimmun should add the word Elokeinu, as ten men must. Me’iri cites an opinion which states that a group of ten women should include Elokeinu in their zimmun.[xxxvii] Shiltei ha-Gibborim also espouses such a position.[xxxviii] However, the normative practice is for women not to say Elokeinu, as codified in Shulhan Arukh.[xxxix] The earliest mention of this seems to come from Rambam;[xl] however, he does not explain why women cannot say Elokeinu. The Beit Yosef explains that the inclusion of Elokeinu is a davar she-be-kedushah (a declaration of sanctification, like the recitation of Barekhu or Kaddish), and Halakhah stipulates that only free adult men can be included in a quorum of ten for davar she-be-kedushah.[xli]
4) Taking an intermediate approach, the Shulhan Arukh rules like Tosafot that zimmun is optional for women; however, he writes that “when women eat with [three] men, they become obligated in zimmun and their obligation is fulfilled through the zimmun of the men.”[xlii] The source for his ruling appears to come from the Sefer Mitsvot Gadol (Semag) of R. Moshe ben Ya’akov of Coucy.[xliii] The Semag offers a resolution between two conflicting Talmudic sources, and thereby provides a logical space in which Tosafot constructs its position: Tosafot is of the opinion that zimmun is optional for women based on Berakhot 45b. However, the Gemara in Arakhin 3a explicitly states that women are obligated in zimmun. [xliv] Therefore, the Semag limits the application of Arakhin to situations in which women are eating with men, and, in such a case, women fulfill their obligation with the men’s zimmun. The Shulhan Arukh quotes the end of this statement of the Semag almost verbatim.[xlv]
5) If three men and three women dine at the same table, is it permissible for the women to perform their own zimmun independent of the men’s zimmun? Despite Shulhan Arukh’s contention that women fulfill their obligation with the men’s zimmun, the Shulhan Arukh ha-Rav maintains that it is permissible for women in such a circumstance to separate and form their own zimmun.[xlvi] However, the Shulhan Arukh ha-Rav proceeds to explain that this is only true when there are fewer than ten men. If ten men are present, the women are not permitted to separate and form an independent zimmun; rather, they must remain and answer to the men’s zimmun. This is because the Shulhan Arukh ha-Rav agrees with Rambam that women can never constitute a quorum of ten to say Elokeinu, and therefore they cannot separate to form a zimmun without Elokeinu when the present men’s zimmun will recite Elokeinu.[xlvii]
6) Ms. Hiller points out that the position of Rosh and Gra is that women are obligated in zimmun. This view is, in fact, even more prevalent in the rishonim than her discussion indicates. It is also the view of the Rokeah,[xlviii] R. Yonah,[xlix] Or Zaru’a,[l] Ritva,[li] Me’iri,[lii] Rif,[liii] Kol Bo,[liv] and, as established above, Rambam; all of these rishonim maintain that women have an obligation in zimmun. Nonetheless, the established halakhic practice today is that zimmun is optional for women.[lv]
What remains clear from all of these sources is that, at the very least, women can form a zimmun; according to many, they are in fact obligated in zimmun. Despite the simple understanding of Berakhot 45b, Halakhah does not permit women to be counted with men to make up the requisite number for a zimmun of three or ten. A woman who eats with three men must remain and share in the zimmun obligation by answering with the men’s zimmun. Women may, however, separate from presence of a men’s zimmun and perform their own, provided that there are fewer than ten men present. Although there are many rishonim who maintain that women have an obligation in zimmun, normative Halakhah has not adopted this view. Nonetheless, zimmun provides an easy opportunity to perform a mitsvah and find greater meaning in Jewish practice.
Yoni Zisook is a senior at YC majoring in Sociology.
[i] Gabrielle Hiller, “Women’s Zimmun: It’s Just Not that Radical,” Kol Hamevaser 5:1 (2011): 8-9.
[ii] See Ms. Hiller’s article, especially her discussion of Rosh and Tosafot. Rosh holds that when three women dine together, they have an obligation to perform zimmun (Berakhot 7:4), while Tosafot is of the opinion that zimmun is only a reshut, an optional act (Berakhot 45b, s.v. shani hatam de-ika de’ot). Tosafot maintains this position despite the fact that the Gemara in Arakhin 3a indicates an obligation for women to perform zimmun.
[iii] In addition to the Talmudic and halakhic sources presented, the manifestation of women’s zimmun today is likely related to the sociology of Jewish life. However, addressing this point any further would go beyond the scope of this article.
[iv] R. Simhah was a German Tosafist who lived during the second half of the twelfth and first half of the thirteenth century. He studied with El’azar b. Yehudah (Rokeah) and under Eli’ezer b. Shmu’el of Metz (Yere’im). See Shlomoh Zalman Havlin, “Simhah ben Samuel of Speyer,” in Encylopaedia Judaica, ed. by Michael Berenbaum and Fred Skolnik, Second Edition, Vol. 18 (Detroit: Macmillan Reference USA, 2007), 603-604.
[v] The R. Yehudah ha-Kohen cited in this article is likely one of two medieval German scholars; it is, however, unclear which R. Yehudah ha-Kohen is referred to here. He may be Yehudah b. Me’ir ha-Kohen Leontin, who lived at the end of the Geonic period, during the tenth and eleventh centuries, and was one of R. Gershom Me’or ha-Golah’s teachers. The second possibility is that this is the Tosafist R. Yehudah b. Moshe ha-Kohen, who lived during the thirteenth century and was a contemporary of R. Me’ir of Rothenburg. From the juxtaposition of R. Yehudah ha-Kohen and R. Me’ir of Rothenburg in Tur OH 199, and from the citation of the former’s position in She’elot u-Teshuvot Maharam me-Rotenberg (Prague ed.), part 4, 227, the second possibility is also a reasonable conclusion. See Shlomo Eidelberg and David Derovan, “Gershom ben Judah Me’or Ha-Gola,” in Encylopaedia Judaica, ed. by Michael Berenbaum and Fred Skolnik, Second Edition, Vol. 7 (Detroit: Macmillan Reference USA, 2007), 551-552. See also Irving A. Agus, “Meir ben Baruch of Rothenberg,” in Encylopaedia Judaica, ed. by Michael Berenbaum and Fred Skolnik, Second Edition, Vol. 13 (Detroit: Macmillan Reference USA, 2007), 780-783.
[vi] Rambam’s second clause does not ordinarily apply to children forming a zimmun in their own right. However, there is at least one opinion that holds a group of three children can constitute a valid zimmun. See Perishah to Tur OH 199. Berakhot 48a indicates that one child can be counted towards a zimmun of adult males if the child “knows whom [we] are blessing.” This is codified in Shulhan Arukh OH 199:10. See, however, the gloss of Rama, ad loc. who writes, “some do not ever count [a child].”
[vii] Rambam, Mishneh Torah, Hilkhot Berakhot 5:7. Rambam continues to state that “…to prevent promiscuity, women, slaves, and children should not form a zimmun together; rather, women, slaves, and children should form independent groups for zimmun, so long as they do not mention the name of God.” Though this part of Rambam’s ruling is important, it is not relevant for ascertaining his position regarding women’s obligation in zimmun. Therefore, for the sake of clarity, it is left out of the above quotation. All translations are my own unless otherwise indicated.
[viii] Ibid. 5:1.
[ix] Ibid. 5:6.
[x] Rabbi Dr. Eliezer Berkovits understood Rambam’s opinion in the same manner. See Eliezer Berkovits, Jewish Women in Time and Torah (Hoboken, New Jersey: Ktav Pub. House,1990), 87-88.
[xi] As for the nature of zimmun itself, irrespective of the particular issue of women’s zimmun, the rishonim dispute whether it is a rabbinic or Biblical obligation. According to R. Shlomo Zevin, the majority of poskim agree that zimmun is rabbinic in nature. See “Zimmun,” in Encyclopedia Talmudit, ed. by Shlomo Zevin (Jerusalem: Talmudic Encyclopedia Publ. Ltd., 1967): 237-238. See also notes 18 and 19, ad loc.
[xii] Ms. Hiller has already demonstrated that Rosh maintains that zimmun is obligatory for women. I will demonstrate later that this is also the opinion of at least eight other rishonim.
[xiii] According to Rambam himself, the question of whether women are obligated in birkat ha-mazon rabbinically or Biblically is not resolved. He writes in Hilkhot Berakhot 5:1 that “women… are obligated in birkat ha-mazon, but it is a doubt whether they are obligated Biblically, for it is not time bound, or Rabbinically. Therefore, [because of this doubt], women should not fulfill others’ [i.e. adult males] obligation in birkat ha-mazon.” See also Ms. Hiller’s review of Tosafot in Arakhin 3a s.v. mezammenot le-atsman. Tosafot implies that women’s obligation in birkat ha-mazon is rabbinic, for Tosafot holds that women cannot join with men in zimmun because they do not say the berit (i.e. the line of “al beritekha she-hatamta bi-vessareinu, a reference to the covenant of male circumcision) while men do. However, Tosafot in Berakhot 20b s.v. nashim concludes, like Rambam, that it is in doubt whether women’s obligation in birkat ha-mazon is rabbinic or Biblical.
[xiv] Tosafot to Berakhot 45b, s.v. shani hatam de-‘ika de’ot.
[xv] Shmuel Dickman, the author of the notes to Makhon ha-Talmud ha-Yisraeli ha-Shalem’s edition of Me’iri to Berakhot, interprets Rambam’s opinion very similarly. He writes that Rambam’s expression, “aval mezammenin le-atsman” (“but they make a zimmun of their own”), implies that women are obligated in zimmun. Dickman does not elaborate as to why. His rationale, however, is likely that if Rambam wanted to declare zimmun optional for women, he would have written, “im ratsu le-zammen, mezammenin le-atsman” (“if they want to make a zimmun…”). Additionally, Rambam should write explicitly that zimmun is optional, were he to think so. One may infer from the fact that Rambam does no such thing that he feels zimmun is obligatory for women. See Me’iri to Berakhot 47a in the Makhon ha-Talmud ha-Yisraeli ha-Shalem edition and note 153, ad loc.
[xvi] Me’iri to Berakhot 47a.
[xvii] Berakhot 45a (Soncino translation).
[xix] Berakhot 45b (Soncino translation).
[xxii] See Rashi to Berakhot 45b, s.v. im ratzu ein mezamnim, and Shulhan Arukh OH 199:6.
[xxiii] Normative halakhic practice does not join women with men to make up the requisite number for zimmun of three or ten. It appears that, historically, traditional communities have not embraced full inclusion of women into zimmun for two major reasons: 1) Rashi and, later, many aharonim indicate that “ein havrutan na’eh,” “a grouping of men and women is unseemly.” Some authorities indicate that ein havrutan na’eh is synonymous with the concern for peritsuta, promiscuity. However, if that is the case, then any grouping of men and women which would not lead to promiscuity should constitute a legitimate grouping for zimmun. (See the above discussion of Mordekhai et al.) For example, a father, son, and mother should thus be a legitimate grouping for zimmun, for, in such a case, no one is worried about promiscuous behavior. Nonetheless, R. Hayyim Margoliot in his Sha’arei Teshuva, citing the Levush, writes that even such a case is unseemly (OH 199:3). Additionally, Beit Yosef to Tur OH 199:8-9 cites the same conclusion in the name of R. Yonah in the name of Rashi: a woman cannot join in men’s zimmun, even with her husband, for such a grouping is “unseemly.” This is a very difficult view for some to accept. Further, the ein havrutan na’eh explanation becomes very strange in light of the halakhah, as codified in Shulhan Arukh OH 199:7, that if women dine with at least three men, then they must remain and answer the men’s zimmun; clearly, women ate together with men. If this is so, then the basic conception of ein havrutan na’eh should not really be applicable. 2) A second possibility is the application of the concept of lo pelug. That is, once the Rabbis prohibited women from joining with male slaves, they categorically prohibited women from joining with any man, including free men. For other tangible resolutions as to why free men and women cannot be counted together, see Me’iri to Berakhot 47b and Tosafot to Arakhin 3a s.v. mezammenot le-atsman. See also notes 11 and 13 in Hiller.
[xxiv] Up to this point, my formulation is the same as that of Derishah to Tur OH 199, commenting on the view of R. Yehudah ha-Kohen.
[xxv] Mordekhai to Berakhot 45b.
[xxvii] I am not sure whether this statement is of Mordekhai himself or is a continuation of R. Simhah.
[xxviii] The Gemara in Berakhot 20b discusses whether women are obligated in birkat ha-mazon Biblically or only rabbinically. The Gemara does not present a conclusion. However, Yerushalmi Berakhot 3:3 is of the opinion that birkat ha-mazon is Biblically incumbent upon women. As I indicated in note xiii, Rambam and Tosafot in Berakhot hold that the halakhah is in doubt and not decided upon, like in the Bavli. However, other rishonim maintain that women are obligated in birkat ha-mazon Biblically, as in the Yerushalmi. Ra’avad, as cited by Tur in OH 186, and Rashba, as cited in Beit Yosef to Tur ad loc., hold women are obligated Biblically. Rif maintains this opinion as well (Berakhot 11b). However, the Halakhah, as codified in Shulhan Arukh OH 186:1, is in agreement with the Bavli and Rambam, that women’s obligation in birkat ha-mazon is undecided.
[xxix] Mordekhai, ibid. Accordingly, the discussion in the previous note regarding the nature of women’s obligation in birkat ha-mazon, rabbinic or Biblical, is inconsequential for R. Simhah’s position on this matter. However, if we were to hold that women are obligated in birkat ha-mazon under Biblical command, then one could seriously entertain the possibility of counting two women and one man in forming a zimmun, for women’s obligation in birkat ha-mazon would be entirely synonymous with that of men. Additionally, as indicated in my analysis of Rambam’s position, for the rishonim who maintain women have an obligation in zimmun, it should make no difference whether women are obligated in birkat ha-mazon rabbinically or Biblically.
[xxx] R. Simhah, as cited by Mordekhai, is generally interpreted to include both the cases of one woman with two men and one woman with nine men. However, some want to limit his application to only the case of one woman with nine men. See Bah to Tur OH 199.
[xxxi] R. Ya’akov ben Asher, often referred to as the Tur, is the son of R. Asher ben Yehiyel, often referred to as Rosh.
[xxxii] Tur OH 199.
[xxxiii] Ibid. See notes xiii and xxix. Also, the language of R. Yehudah ha-Kohen in Tur is somewhat ambiguous. He would seemingly allow multiple women to join, and not just one. However, Bah to Tur OH 199 interprets R. Yehudah ha-Kohen like R. Simhah in reference to including only one woman and not multiple women. Additionally, Bah quotes an opinion that R. Yehudah ha-Kohen only instructed that one woman can join with nine men. However, Shiltei ha-Gibborim to Rif Berakhot 7:1 writes that R. Yehudah ha-Kohen’s view refers to even one woman with two men, whereas R. Simhah’s view refers to one woman with nine men. Shiltei ha-Gibborim further equates the view of R. Tam and Rosh to that R. Simhah, that one woman can join with nine men.
[xxxiv] R. Meir of Rothenburg as quoted by Tur OH 199. R. Meir does not offer a reason for rejecting R. Yehudah ha-Kohen’s position.
[xxxv] See note xxiii.
[xxxvi] In a more moderate way, this is codified in Shulhan Arukh OH 199:7, for once there are three men present in which zimmun becomes obligatory, women become full members of the zimmun and must remain and answer with the men. According to Ba’al Halakhot Gedolot as cited in Bah to Tur OH 689, s.v. u-ba’al, a woman is even permitted to lead the zimmun in such circumstances. That being said, normative Halakhah does not accord with this position of Ba’al Halakhot Gedolot.
[xxxvii] Me’iri to Berakhot 47b.
[xxxviii] Shiltei ha-Gibborim to Rif Berakhot 7:1. Additionally, R. Simhah and R. Yehudah ha-Kohen would likely hold that a group of ten women should say Elokeinu if a woman can already be counted with nine men to say Elokeinu.
[xxxix] Shulhan Arukh OH 199:6.
[xl] Rambam, Mishneh Torah, Hilkhot Berakhot 5:7.
[xli] Beit Yosef to Tur OH 199. R. Yosef Karo rules like Rambam in this matter in Shulhan Arukh, and explains why women cannot say Elokeinu in Beit Yosef. See also note 12 in Hiller. She quotes the Mishnah Berurah OH 199:15, who offers the same davar she-be-kedushah answer. Shulhan Arukh ha-Rav OH 199:6 also cites this answer.
[xlii] Shulhan Arukh OH 199:7.
[xliii] Sefer Mitsvot Gadol, Positive Commandments, 27.
[xliv] See Ms. Hiller’s discussion of the Gemara in Arakhin and her review of the Shulhan Arukh’s position.
[xlv] Semag therefore understands Arakhin 3a as describing a hiyyuv, albeit severely limited, while at the same time interpreting Berakhot 45a as describing a reshut. In this way, Semag alleviates the seeming contradiction between the Talmudic sources. In his opinion, they describe two different scenarios.
[xlvi] Shuhlan Arukh ha-Rav OH 199:6.
[xlvii] Ibid. As for the question of whether it is appropriate for women to perform zimmun in the presence of men, R. Shlomo Zalman Auerbach, as cited by his nephew R. David Auerbach in Halikhot Beitah, 94, holds that one or two men not only may be present, but may also answer to the women’s zimmun. This is also the view of R. Aharon Lichtenstein, who is quoted as saying that R. Joseph B. Soloveitchik also held that it is permissible for men to remain and answer to the women’s zimmun. See Ari Zivotofsky, “Tzarich Iyun: Women’s Zimmun,” Jewish Action, Fall 1999. See also note 14 in Hiller.
[xlviii] Rokeah, Hilkhot Se’udah, 333.
[xlix] R. Yonah to Rif Berakhot 45a (7:1 or 33a on Rif). In s.v. nashim he says that women’s zimmun is optional. However, in s.v. ve-nir’eh he refutes this and promotes the position that women are obligated in zimmun. R. Yonah is also quoted by Kol Bo as obligating women in zimmun. See Kol Bo, 25.
[l] Or Zaru’a, Part 1, Hilkhot Se’udah, 184 and Part 2, Hilkhot Megillah, 368.
[li] Ritva, Hilkhot Berakhot 7:2.
[lii] Me’iri to Berakhot 47a.
[liii] Rif as cited in Or Zaru’a, Part 1, Hilkhot Se’udah, 184.
[liv] Kol Bo, 25.
[lv] See both Arukh ha-Shulhan OH 199:2 and Mishnah Berurah OH 199:13, who hold that women’s zimmun is optional.