 A second approach to manipulation treats it as a form of trickery, and ties it conceptually to deception. The connection between manipulation and deception is a common theme in both non-philosophical and philosophical discussions of manipulation. In his 1980 book Manipulatory Politics, Robert Goodin argues that manipulation is inherently deceptive, and offers this test for whether an influence is manipulative: “1. Is the interference deceptive? 2. Is the interference contrary to the putative will of those subject to it?” (Goodin, 1980: 35). In the literature on advertising, the charge that (at least some) advertising is manipulative often rests on the claim that it creates false beliefs or misleading associations (e.g., linking the vitality of the Marlboro man to a product which causes lung cancer). Similarly, in his discussion of promises, T. M. Scanlon condemns manipulation as a means of inducing false beliefs and expectations (Scanlon 1998: 298–322). Shlomo Cohen offers a somewhat different account of the relationship between manipulation and deception, according to which the distinction lies in the methods by which the target is induced to adopt a false belief (Cohen 2018). But even on this more nuanced view, there is still a strong connection between manipulation and deception.