The results of numerical experiments are used to guide an analytic discussion of hyperbolic mergers among an uncorrelated galaxy population. The expected merger rate is derived as a function of progenitor mass and relative angular momentum, and is used to predict the distribution of the parameter V(c)/sigma/0/ for merger products, where V(c) is the maximum observed rotation velocity in a galaxy and sigma(0) is its central velocity dispersion. The median value of this parameter for mergers between comparable galaxies is estimated to be 0.65 and is higher than the observed value in any of the 14 galaxies for which data are available. It seems unlikely that most elliptical galaxies are the result of single or multiple mergers between initially unbound stellar systems; further observational and theoretical work is suggested which should lead to a conclusive test of this picture. The present arguments cannot, however, exclude formation from low angular momentum elliptical orbits.