 Frank Lovett argues that avoiding domination does not require democracy, but instead subjecting the powerful to reliably enforced and widely known rules. Perhaps democracy does, in fact, most effectively reduce domination, but this should follow from substantive argument, not from the mere analysis of concepts (Lovett 2010). Also, there is reason to think that subordinate groups are less dominated whenever their overlords must abide by reliably enforced and widely known rules, even when those rules do not express the will of the subordinated in any way. Lovett uses the following case to make his point: