 For example, in the work of legal theorist Catharine MacKinnon, domination is closely bound up with her understanding of gender difference. According to MacKinnon, gender difference is simply the reified effect of domination. As she puts it, “difference is the velvet glove on the iron fist of domination. The problem is not that differences are not valued; the problem is that they are defined by power” (MacKinnon 1989, 219). If gender difference is itself a function of domination, then the implication is that men are powerful and women are powerless by definition. As MacKinnon puts it, “women/men is a distinction not just of difference, but of power and powerlessness….Power/powerlessness is the sex difference” (MacKinnon 1987, 123). (In this passage, MacKinnon glosses over the distinction, articulated by many second-wave feminists, between sex – the biologically rooted traits that make one male or female, traits that are often presumed to be natural and immutable – and gender – the socially and culturally rooted, hence contingent and mutable, traits, characteristics, dispositions, and practices that make one a woman or a man. This passage suggests that MacKinnon, like Judith Butler (1990) and other critics of the sex/gender distinction, thinks that sex difference, no less than gender difference, is socially constructed and shaped by relations of power.) If men are powerful and women powerless as such, then male domination is, on this view, pervasive. Indeed, MacKinnon claims that it is a basic “fact of male supremacy” that “no woman escapes the meaning of being a woman within a gendered social system, and sex inequality is not only pervasive but may be universal (in the sense of never having not been in some form” (MacKinnon 1989, 104–05). For MacKinnon, heterosexual intercourse is the paradigm of male domination; as she puts it, “the social relation between the sexes is organized so that men may dominate and women must submit and this relation is sexual – in fact, is sex” (MacKinnon 1987, 3). As a result, she tends to presuppose a dyadic conception of domination, according to which individual women are subject to the will of individual men. If male domination is pervasive and women are powerless by definition, then it follows that female power is “a contradiction in terms, socially speaking” (MacKinnon 1987, 53). The claim that female power is a contradiction in terms has led many feminists to criticize MacKinnon on the grounds that she denies women’s political agency and presents them as helpless victims (for exemplary versions of this criticism, see Brown 1995 and Butler 1997a).