 Second, that challenge aside, there are disagreements within the ranks of any given theory. Consider rule versus act utilitarianism, for instance, or disagreement amongst Rawlsians. Third, some cite tensions between some versions of high theory and democracy. Publicity, many hold, ought to be a fundamental norm governing policy making in a democratic society (Rawls 1971). Requiring such publicity would preclude justifications that no one outside an elite class of philosophers can understand. One need not be a theory sceptic, then, in order to demote the place of high theory within bioethics; one need only recognize the tension between doing bioethics in a democracy, and rarefied moral theory (Bertram 1997; London 2001).