 In an essay that develops Warren Quinn’s view that Double Effect is best understood as resting on a distinction between direct and indirect agency, Dana Nelkin and Samuel Rickless (2014) formulate the principle in this way: “In cases in which harm must come to some in order to achieve a good (and is the least costly of possible harms necessary), the agent foresees the harm, and all other things are equal, a stronger case is needed to justify harmful direct agency than to justify equally harmful indirect agency” (2014). In harmful indirect agency, harm comes to some victims in order to achieve a good, but “nothing in that way is intended for the victims, or what is so intended does not contribute to their harm.” In harmful direct agency “harm comes to some victims, at least in part, from the agent’s deliberately involving them in something in order to further his purpose precisely by way of their being so involved” (Nelkin and Rickless (2014), quoting Quinn (1989)).