Lay in bed all day vs Has Lain in bed all day

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Looking on the internet deeply has found these results:

Lay in bed all day is the most popular phrase on the web. 

Has Lain in bed all day

111 results on the web

Lay in bed all day

111,900 results on the web

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Some examples and use cases from the internet:

Some examples and use cases from the internet:

  • Apr 19, 2008 ... ... remember that lie (past tense lay, past participle has lain) is intransitive: he lies in bed all day, he lay in bed all day, he has lain in bed all day.
  • Feb 21, 2006 ... What about “She has lain in bed all day”? Most people say “She has laid in bed all day” because they never paid attention in English class and ...
  • Oct 30, 2012 ... My father has lain in bed all day. 6. Mother has laid the book down somewhere. 7 . Have you read that there was an earthquake in China? 8.
  • Feb 22, 2013 ... Someone must lay the carpet. For lain (lie): She has lain in bed all day today because she is sick with the flu. merquiades, Feb 23, 2013.
  • Jan 25, 2001 ... Obviously there will be some confusion when it is correct to say, "I lay in bed all day," to describe what you did yesterday or last week, but ...
  • ... on the bed all day (yesterday). Place a capital letter at the beginning of your sentences. We would make the second sentence I lay in bed all day (yesterday).
  • Yesterday, he lay in bed all day. Don't lie on the floor! I lay on the floor last week and you didn't say anything. Lie (past tense lied) means to say something ...
  • Feb 25, 2014 ... However I am concerned because since the retirement he tends to just lay in bed all day (we live in the same apartment and based on my ...

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