 One limitation of a purely performative account of consent is that it does not take into account the context in which the relevant behavior or utterance occurs. For instance, if a woman says “yes” or even feigns sexual enthusiasm in order to keep a knife-wielding attacker from becoming angry and hurting or killing her, it would be absurd to regard her behavior or utterance as consent (or at least as meaningful consent). The question is what other contextual constraints and pressures may also undermine the validity of a woman’s (apparent) consent. To put the point another way, having granted that “no” always means no, we must recognize that, in some cases, “yes” also means no. There are many kinds of explicit and implicit threats that render a woman’s consent to sex less than meaningful: the man may threaten to sue for custody of their children, to derail her green card application, to evict her, or simply to sulk and make her life miserable for days should she refuse to have sex. Which (if any) such nonviolent coercive pressures should be regarded as rape, either morally or legally, is a matter of some controversy (Schulhofer 1998; Burgess-Jackson 1996, 91-106).