 Other writers have proposed different justice-based accounts of the common law of torts. George Fletcher proposed to understand tort liability as a violation of reciprocity; those who impose non-reciprocal risks on others must compensate for the harm that they do (1972). Other writers, drawing on John Rawls’s theory of justice have proposed to understand tort law in broadly contractarian terms. For example, Gregory Keating has argued that corrective justice is a subordinate principle in tort law, the purpose of which is to uphold entitlements—not only to property but also to personal security—that are themselves the product of a contractualist procedure (1996; 1997). Keating argues that corrective justice’s emphasis on the form of a tort action attends to remedies without adequately accounting for the way in which those remedies are secondary to the rights that they enforce. In order to identify the relevant rights, Keating suggests a contractualist procedure similar to those developed by Rawls and T.M. Scanlon. The proposed contractualist account would weigh the substantive interests of people in liberty and security, and would attach priority to bodily security in particular. It would therefore require two things. First, it would require that business enterprises that characteristically create risks to life and limb spend more on precautions than would be justified through an economic analysis of their expected costs and benefits. Second, it would require that those who suffer injuries, even if those injuries are unavoidable—as is likely in a world in which, as Holmes puts it, enterprises engaged in ongoing “activities” rather than isolated “acts” on a large scale will inevitably produce injuries no matter how careful they are—receive compensation even though nothing short of prohibiting those worthwhile and beneficial activities could have been done to prevent those injuries. Keating puts this point in terms of an idea of enterprise liability under which an enterprise that imposes costs on others should properly be made to bear those costs. Enterprise liability, in which manufacturers were required to insure against all injuries caused by their products, even those that could not be prevented through further care figured prominently in a number of decisions, particularly in California, in the second half of the twentieth century. A leading case involved a cola bottle that exploded, injuring the plaintiff, although there was no evidence of negligent manufacture. In recent decades, the prominence of enterprise liability has largely faded.