 In “What is Justified Belief?”, Goldman acknowledged this sort of problem, and suggested adding a “No Defeaters” condition to the theory of epistemic justification. There, he elucidated an account of defeat in counterfactual terms. Roughly, your belief B is defeated provided there is some reliable (or conditionally reliable) process X available to you such that, if you were you use X, you would no longer hold B. On this view, Alice’s belief is defeated because if she were to use the process believing her friend’s testimony, she would not have believed B. However, this account of defeat has been subject to various challenges. For example, Beddor (2015) argues that it commits a version of the “counterfactual fallacy”, rendering it susceptible to counterexamples. And both Lyons (2009: 124) and Beddor (2021) point out that it has trouble accommodating cases where one defeater is defeated by another.