It is widely, but not universally, believed that the lipids of the plasma membrane are not uniformly distributed, but that "rafts'' of sphingolipids and cholesterol float in a "sea'' of unsaturated lipids. The physical origin of such heterogeneities is often attributed to a phase coexistence between the two different domains. We argue that this explanation is untenable for several reasons. Further we note that the results of recent experiments are inconsistent with this picture. However they are quite consistent with an alternate explanation, namely that the plasma membrane is an emulsion of the two kinds of regions. To show this, we briefly review a simplified version of this theory and its phase diagram. We also explicate the dependence of the predicted domain size on four physical parameters. Among them are the spontaneous curvature of the membrane and its bending modulus and surface tension. Taking values of the latter two from experiment, we obtain domain sizes for several different cell types that vary from 58 to 88 nm.