 In the passage on false promising, Kant references possible consent. He suggests that the victim of the false promise cannot agree to the use the false promisor is making of him. We might conclude that the victim cannot agree on the grounds that he cannot share the promisor’s end; for it would, in the sense invoked above  (§3.1.3),  be practically irrational for him to pursue this end. There is, however, another way of interpreting the victim’s inability to consent in the context of considering candidates for a plausible sufficient condition for an agent’s treating another merely as a means. Another account, prompted by the Groundwork passage, is this: An agent uses another merely as a means if the other cannot consent to her use of him (O’Neill 1989:  113).[7]  An agent cannot consent to being treated as a means if he does not have the ability to avert his being treated as such by dissenting, that is, by withholding his agreement to  it.[8]  If an agent deceives or coerces another, then the other’s dissent is “in principle ruled out” (1989: 111) and thus so is his consent. Suppose, for example, that an appliance serviceperson tricks a customer into authorizing an expensive repair. The customer does not really have the opportunity to dissent to the person’s action by refusing to give his consent to it. For he does not know what her action is, namely one of lying to him about what is wrong with his refrigerator. (If he did know what her action was, then he would not be deceived.) Or suppose that a mugger approaches you on a dark street, points a gun at you, and tells you that unless you give him all of your money, he will hurt you. He leaves you no opportunity to avert his use of you by withholding your consent. Regardless of what you say, he is presumably going to use you, whether it is through your handing over your wallet or his violently taking it from you. Since you cannot consent to his action, the mugger is treating you merely as a  means.[9]