 While we have set aside the question of abortion, we will briefly address two other cases in which avoiding procreation and parenthood has been taken as protected by procreative autonomy. First is the case of legal paternity assignment for the purposes of child support, particularly in the case of “involuntary fathers.” Second is the case of the disposition of frozen embryos created from the gametes of two people who now disagree on their use. We can usefully distinguish rights not to become a gestational parent, not to become a legal parent, and not to become a genetic parent (Cohen 2007, 1140). The cases we are concerned with in this section relate to the two latter (alleged) rights: not to become a legal or a genetic parent.