 A third approach to parenthood, popular with legal theorists, appeals to intentions as the ground of parenthood (Hill 1991; Parker 1982; Shultz 1990; Stumpf 1986). Intentionalists motivate their position by appeal to cases like the following. The Khans wish to have a child “of their own.” They screen egg and sperm providers and find providers who satisfy their requirements. They then select a gestational mother, who carries the fetus to term and then hands the infant over to the Khans. Intentionalists argue that because they “carefully and intentionally orchestrated the procreational act, bringing together all the necessary components with the intention of creating a unique individual whom they intend to raise as their own” (Hill 1991, 359), the Khans should be regarded as the child’s sole parents.