 Whether R’s φ-ing must be supererogatory. There is also debate over whether Y can owe R gratitude for φ-ing if R was obligated to φ, or if Y had a right to R’s φ-ing. Heyd (1982), Weiss (1985), Walker (1980–1981), Card (1988), and Macnamara (2019) all argue that Y does not owe gratitude to R for doing something R was already obligated to do anyway or that Y had a right to, and that gratitude is owed only in response to supererogatory acts. Other philosophers disagree, citing various counterexamples. Simmons (1979), for instance, claims that I owe gratitude to a good Samaritan who stops to offer me assistance, even though such acts are obligatory. Lyons (1969) argues that while I may not owe gratitude to a lifeguard for saving my life, I may owe him gratitude for having freely taken up the obligation to do so. Seneca (On Benefits) claims that gratitude may be owed for an obligatory act if the benefactor had gratitude-worthy motives beyond the motive to fulfill her obligation, and these gratitude-worthy motives were decisive in motivating her. Bennett Helm (2019) argues that I can owe gratitude to someone who dutifully upholds (but does not necessarily exceed) an obligatory social norm, when his upholding that norm is “notable” and demonstrates recognition respect for me. Finally, it might be argued that a benefactor who benefits me in fulfilling her duty deserves gratitude insofar as living up to her duty required extraordinary sacrifice on her part (McConnell 1993: 16; Seneca On Benefits: III.19.12–13), or insofar as her living up to her duty makes her a “moral standout” among so many other similarly situated people who fail to fulfill such duties (McConnell 2017). The captured soldier who resists torture long enough for her companions to reach safety seems to deserve gratitude, despite doing no more than her duty (refraining from giving the enemy valuable information). These examples suggest that perhaps φ’s praiseworthiness, rather than φ’s supererogatoriness, is a necessary condition for Y’s owing gratitude to R. This possibility is challenged by the fact that sometimes, it seems a beneficiary Y may owe gratitude to a benefactor who was obligated to give away some particular benefit to someone, and happened to choose Y as the recipient. McConnell (1993) gives the example of a student who is required by her instructor to volunteer at a charitable organization of her choice. When she chooses Y’s organization, her action is neither supererogatory nor praiseworthy; but it seems she still deserves gratitude from Y.