  A separate line of criticism centres on the fact that courts do not often articulate their use of analogies in terms of some ‘principle’ inherent in an earlier case. Where principles are used as arguments for a result, earlier cases tend to be cited as illustrations of the application of the principle, rather than as analogies to the facts of the case at hand. If another case is cited as providing an analogy, the emphasis will be on how ‘close’ the analogy is, i.e., on how specific the common characterisation of the facts of the two cases is, and how that characterisation relates to the rationale for the earlier decision. The more specific an analogy, the stronger; the more abstract the characterisation, the weaker the argument as an analogy. The reason for this is that the more specific the analogy, the less room there is for distinguishing the two cases, whereas the more abstract the analogy the more grounds on which the two cases may be regarded as significantly different. So if it is lawful to consent to tatooing, it is also lawful to consent to a decorative branding, which is closely  analogous.[20]   On the other hand, the analogy of boxing to sadomasochistic activities is more remote, although both involve the intentional infliction of a certain level of  harm.[21]