 The account arguably not only fails to capture some cases of an agent’s treating another merely as a means, but also designates as such some cases of deception that, intuitively speaking, are not. For example, in order to make your spouse’s birthday party a surprise for her, you need to lie to your sister-in-law about your whereabouts during a certain afternoon. You use her to quell your spouse’s suspicions regarding your plans. As you realize, if you told your sister-in-law about the party, she would be unable to keep the secret from your spouse. According to the account, you treat your sister-in-law merely as a means, since your deception leaves her with no opportunity to avert your use of her. This conclusion seems questionable to some, albeit not to others. Here is another case of what some think of as morally permissible deception (Parfit 2011: 178). Suppose that, in order to save the life of an innocent witness to a crime, you use her to pass on a lie you have told her to the perpetrator, Brown. If Brown did not believe the lie, he would kill the witness. You realize that if you let the witness in on what was necessary to save her life and told her to lie to Brown herself, she would not be able to do so effectively. Your treatment of the person renders impossible her consent to your use of her. But it is implausible to conclude that you are treating her merely as a means, some insist.