 Not all theorists accept that the value problems are genuine. For example, in light of the literature on the Gettier problem, some theorists deny that the secondary value problem is genuine. On this approach, whatever is added to justified true belief to rule out Gettier cases does not increase the value of the agent’s intellectual state: it is of no consequence whether we have Gettier-proof justified true belief rather than mere justified true belief (Kaplan 1985). Of course, Gettier cases are peculiar and presumably rare, so in practice having Gettier-proof justified true belief is almost invariably confounded with having mere justified true belief. This could lead some theorists to mistake the value of the latter for that of the former. Other theorists deny that the primary value problem is genuine. For example, on one approach, knowledge just is true belief (Sartwell 1991). If knowledge is true belief, then knowledge cannot be better than true belief, because nothing can be better than itself. However, the definition of knowledge as true belief has not been widely accepted.