 Here MacKinnon speaks to a broader debate in feminist legal theory, in which some feminists have argued for the adoption of a “reasonable woman standard” in matters ranging from sexual harassment to stalking, battering, and rape. Proponents of this approach believe that a gender-neutral standard of reasonableness is impossible given the differences between men’s and women’s social positioning. They point out, for instance, that men have greater social and (in most cases) physical power than women and, relatedly, that women’s beliefs and reactions are shaped by the constant threat of male violence with which women live (Kerns 2001). Because of these differences, women and men often have divergent perceptions of interpersonal behavior (Scheppele 1991, 45): for instance, behavior that men see as merely flirtatious may be experienced by women as offensive or even threatening, and women may see advances as physically intimidating that men see as aggressively amorous. Proponents thus contend, in the words of Hubin and Haely (who reject this approach), that “when we seek to determine whether the actions and words of the victim constitute or indicate consent to sexual intercourse – it is the standard of the reasonable woman we must employ” (1999, 119). Thus, for example, in assessing the reasonableness of an alleged victim‘s judgment that it would be dangerous to resist a particular sexual advance, a jury would ask whether a reasonable woman in that situation would so judge. Opponents of the reasonable woman standard contend that it is both possible and desirable to account for common differences between men’s and women’s physiologies, social experiences, and perceptions without importing gender into the definition of reasonableness itself. For instance, while granting that a reasonable person standard should often yield different conclusions for men than for women, Hubin and Haely contend that “this is not because the reasonable person standard fails to present a single (gender neutral) standard, but because the standard we are employing is sensitive to features of the agent and the situation that are correlated with gender” (1999, 133).