 Whether φ must be an action. Among philosophers, there is general agreement that benefactor R must act in some way that concerns beneficiary Y in order to deserve Y’s gratitude. Two exceptions in the literature are worth noting. In the first place, Saul Smilansky (1997) argues that Y sometimes should be grateful to R for abstaining from harming Y, at least when certain conditions are met—e.g., in cases when abstaining from harming someone goes beyond the call of duty, or requires effort and sacrifice (see the remainder of this section for a more detailed analysis of those conditions). In these cases, R’s φ-ing, for which Y would be grateful, would be an omission or a refraining rather than an act. A second exception is Kant (1775–1780 [1981]), who writes that something like gratitude is owed or called for in response to mere “heartfelt benevolence”, even in the absence of any acts or attempts on the part of the benefactor. Kant refers to this response as “gratefulness” rather than gratitude.