 Butler’s normativity argument makes two claims. The first is akin to Spelman’s particularity argument: unitary gender notions fail to take differences amongst women into account thus failing to recognise “the multiplicity of cultural, social, and political intersections in which the concrete array of ‘women’ are constructed” (Butler 1999, 19–20). In their attempt to undercut biologically deterministic ways of defining what it means to be a woman, feminists inadvertently created new socially constructed accounts of supposedly shared femininity. Butler’s second claim is that such false gender realist accounts are normative. That is, in their attempt to fix feminism’s subject matter, feminists unwittingly defined the term ‘woman’ in a way that implies there is some correct way to be gendered a woman (Butler 1999, 5). That the definition of the term ‘woman’ is fixed supposedly “operates as a policing force which generates and legitimizes certain practices, experiences, etc., and curtails and delegitimizes others” (Nicholson 1998, 293). Following this line of thought, one could say that, for instance, Chodorow’s view of gender suggests that ‘real’ women have feminine personalities and that these are the women feminism should be concerned about. If one does not exhibit a distinctly feminine personality, the implication is that one is not ‘really’ a member of women’s category nor does one properly qualify for feminist political representation.