 The case for including animals within the scope of the rules of justice produced by the contract is more difficult to make because, unlike the disabled who may only require and depend on appropriate accommodations in order to reciprocate, animals may be considered incapable of reciprocating benefits to others and are also incapable of rational interaction. If contractarianism is at all able to account for the moral standing of animals, then it has to do so in a more indirect way than in the case of the disabled. It may be possible to ground the moral standing of animals as part of a contract agreed to by other contractors who are capable of rational interaction (Cohen 2007, 2009). Suppose that Bob agrees to form a contract with Jane only on the condition that Jane also attributes direct moral standing to Bob’s pet dog, Rosko. As a result of the contract between Bob and Jane, Rosko gains intrinsic moral standing that imposes correlative moral duties on Jane. If Jane were to harm Rosko in some way, she would not only violate a duty to Rosko’s owner, Bob, but she would also violate a duty that she has to Rosko who possesses intrinsic moral standing of his own. In this way bilateral agreements between contractors could potentially extend the scope of the rules of justice to apply to beings both incapable of rational interaction and arguably incapable of reciprocating benefits to others.