 Mind-dependence theories differ from one another in various ways. Yet the ICE strategy can perhaps be modified in ways that would allow it to strike against a wider variety of mind-dependence theories, and perhaps against all such theories. For example, ICE strategy is on its face not aimed at views like cultural relativism, which would nevertheless still count as a mind-dependence view on our definition. But we can easily conceive of ICE-analogues at the cultural level: assume the relevant relativistic view is that moral facts for A are grounded what A’s culture believes. We can imagine A’s culture believing, without internal inconsistency, that genocide is morally commendable – but it clearly is not. Again, the ideally coherent Caligula wants to torture for fun and has no conflicting desires. This will entail that he has a decisive reason to torture for fun on the view that decisive reasons are grounded in desires (at least when those desires don’t conflict with any others). Or take the view that believing one has a reason to X engenders a reason for one to X. We can then imagine that Caligula believes he has a reason to torture for fun. Combining this particular mind-dependence view with the modified Caligula example entails that Caligula has a reason to torture for fun. Nothing seems to suggest that any particular mind-dependence view is going to escape criticism. And, mind-independence proponents will argue, the only way we can account for the facts that Caligula is wrong to torture for fun and lacks a decisive reason to torture for fun is by allowing that some normative facts are fully mind-independent.