 Hale (1996) examines Monique Wittig's (1992) contentious claim that lesbians are not women. (Wittig's point was to turn on its head the heterosexist view that lesbians fail to count as women by arguing that lesbians step outside the oppressive category of woman which requires heterosexual relations with men). Hale is one of the first to defend the view (now adopted by many feminist philosophers) that the category woman is what Wittgenstein called a family-resemblance concept. The concept woman, in Hale's view, has thirteen, differently weighted characteristics none of which are necessary or sufficient for category membership (1996, 107–12). This position enables Hale to then argue, pace Wittig, that some lesbians are women, others are not, and for some there is no fact of the matter (1996, 115).