 Another possible line is the one mentioned in  §2—to  strengthen the justification condition to rule out Gettier cases as justified. In order for this strategy to prevent Zagzebski’s recipe from working, one would need to posit a justification condition that precludes the possibility of step one above—the only obvious way to do this is for justification to entail truth. If it does, then it will of course be impossible to start with a case that has justified false belief. This kind of approach is not at all mainstream, but it does have its defenders—see e.g., Sturgeon 1993 and Merricks 1995. Sutton 2007 and Littlejohn 2012 defend factive approaches to justification on other grounds.