 Second, the emphasis on collective self-determination as the value that territorial rights realize seems to apply most straightforwardly to groups that engage in democratic self-determination, because then we can then be confident that the state is the vehicle of the group self-determination. If this is so, then, both Moore and Stilz are vulnerable to the criticism that is parallel to one that is levelled against justice theorists, viz., that either the bar to being a territorial right-holder is so high that many states would not meet it (which seems somewhat counter-intuitive); or the bar is so low that it raises questions whether such an entity could be justified on a self-determination argument. Both Moore and Stilz partially avoid the most troubling implication of this as they argue that the appeal to self-determination distinguishes between internal and external threats to state territorial integrity and that they can thereby explain the value that is lost by external intervention. 