 Accounts of treating others merely as means sometimes leave implicit the notions of using another they rely on. Some points regarding what using another does or does not amount to seem uncontroversial. It does not seem sufficient for us to count as using another as a means that we benefit from what the other has done (Nozick 1974: 31–32). If, on her usual route, a runner derives enjoyment from the singing of a stranger who happens to be walking by, she does not appear to be treating the stranger as a means. Moreover, not all cases of an agent’s intentionally doing something in response to another are cases of her using the other as a means. If someone frowns at another approaching, for example, he might not thereby be using the other at all; he might simply be expressing that the other is unwelcome.