Quotation marks in Command Line commands

WORKING my way through the Command Line tutorial. I have a question regarding the use of quotation marks (or not!) in commands. In the below lesson link on Redirection-grep |, the lesson specifically states “Note that we don’t use quotes in our command” …
https://www.codecademy.com/courses/learn-the-command-line/lessons/redirection/exercises/redirect-grep-i

THE COMMAND example given without quotation marks around America is …
$ grep -i America continents.txt

BUT IN the accompanying quiz, there is a question that states …
Search the file greatest.txt for “Earl” then send the results to the file odd future.txt.

THE CORRECT answer to the above quiz question is …
$ grep “Earl” greatest.txt >> odd future.txt

DO YOU SEE the quotation marks around “Earl”? The lesson beforehand specifically said “Note that we don’t use quotes in our command”

I’M CONFUSED?

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