 A strategy that avoids disputes surrounding the concept of harm would be to argue that, even if the act does not harm the child, the fact that it causes the child to suffer may mean that it nonetheless wrongs the child. Bonnie Steinbock thus recognizes how hard it is to establish that the child brought into the unavoidably flawed existence has been genuinely harmed (Steinbock 2009, 157–158). But she argues that we still have room to insist that such a child has been treated unfairly or has been wronged in cases in which the child’s existence fails to meet or exceed a certain “decent minimum,” which is itself achieved “only if life holds a reasonable promise of containing the things that make human lives good,” such as “an ability to experience pleasure, to learn, to have relationships with others” (Steinbock 2009, 163–165). Another approach would be to draw the line at average wellbeing (for discussion, see Rachels 1998; Tooley 1998). Still another approach would be to focus on whether the child will face unusual or severe hardships (Benatar 2000; Kamm 2002).