 The constitution view is extremely popular, having been defended by Wiggins (1968), Doepke (1982), Lowe (1983, 1995, 2003), Simons (1985), Yablo (1987), Oderberg (1996), Baker (1997, 2000, 2002), Thomson (1998), Shoemaker (1999), Fine (2003), Koslicki (2008), and many others. Indeed, the view is so common, it is sometimes called “the standard account” (Burke 1992). Why not join the crowd?