 Ross’s foes are not alone in recommending fewer duties than he allows. Some of Ross’s fans advocate for reducing his initial list of duties, too. Phillips, for example, agrees Ross holds, at least initially, there are five foundational duties (Phillips 2019, 58–59). However, Phillips thinks the best account of Ross’s view involves jettisoning the duty of non-maleficence (the responsibility not to harm or injure others) (Phillips 2019, 86–90).