 Another group of feminist political theorists who take sexual difference seriously are those who work in the continental traditions, especially poststructuralism, and attend to the ways in which language and meaning-systems structure experience. Notable among them are the so-called French Feminists, namely Cixous, Kristeva, and Irigaray. Of them all, Irigaray may have the most developed political philosophy, including several books on the rights that should be afforded to girls and women. Irigaray’s early work (1985a and 1985b) made the case that in the history of philosophy women have been denied their own essence or identity. Rather, they have been positioned as men’s mirror negation.  So that to be a man is to not be a woman, and hence that woman equals only not-man. Her strategy in response to this is to speak back from the margins to which women have been relegated and to claim some kind of “essence” for women, and along with that a set of rights that are specifically for girls and women (Irigaray 1994 and 1996). Criticisms of her views have been heated, including among feminists themselves, especially those who are wary of any kind of essentialist and biological conflation of women’s identity. To the extent that Irigaray is an essentialist, her view would indeed be relegated to the approach outlined here as symbolic difference feminism, as Dietz 2003 does. But there are compelling arguments that Irigaray is wielding essentialism strategically or metaphorically, that she isn’t claiming that women really do have some kind of irreducible essence that the history of metaphysics has denied them (Fuss 1989). This other reading would put Irigaray more in the performative group described below.  The same kind of argument could be made for the work of Julia Kristeva, that her metaphors of the female chora, for example, are describing the western imaginary, not any kind of womanly reality. So whether French feminist thought should be grouped as difference feminism or performative feminism is still very much open to debate.