 Several philosophers have made similar criticisms of advertising. Often, these criticisms are limited to forms of advertising that do not simply convey accurate factual information. As is the case with purely informational nudges, the presentation of accurate information in advertising might not be manipulative in and of itself, though perhaps the selection of which information is presented might be manipulative. Be that as it may, most advertising attempts to influence consumer behavior by means other than or in addition to purely providing accurate information. Such non-informational advertising is the most apt target for worries about manipulation. Tom Beauchamp and Roger Crisp have made influential arguments that such advertising can be manipulative (Beauchamp 1984; Crisp 1987). Similar criticisms claim that non-informational advertising can subvert autonomy or improperly tamper with consumers’ desires (e.g., Santilli 1983). Such critiques are either versions of or close relatives to critiques of advertising as manipulation. On the other side, Robert Arrington argues that, as a matter of fact, advertising very seldom manipulates its audience or undermines its audience’s autonomy (Arrington 1982). Michael Phillips has marshalled a large body of empirical evidence to argue that while some advertising is manipulative, its critics vastly overestimate its power to influence consumers (Phillips 1997).