 Unfortunately, this approach faces a serious problem. If we define manipulation in terms of bypassing rational deliberation, and then use the appeal to unconscious motives and exaggerated portrayals of hypnosis and subliminal advertising to illustrate what it means to bypass rational deliberation, we will set a very high bar for something to count as manipulation. This bar would be too high to count any of Irving’s tactics as manipulation, since none of them completely bypasses Tonya’s capacity for rational deliberation in the way that subliminal advertising, hypnosis, conditioning, or the appeal to unconscious motives would appear to do.