  In whatever way we characterize the fiction/non-fiction distinction, the distinction is widely recognized as important. We care which category a work belongs to. We read Lord Macaulay’s The History of England (1848) to learn about the overthrow of James II and its aftermath, and criticize Macaulay for departures from fact or for bias: these detract from its value as a work of non-fiction. Historical novels such as Tolstoy’s War and Peace (1865–1867) or Hilary Mantel’s Wolf Hall (2009) also display bias and they depart in numerous ways from fact, but the bias and inaccuracies don’t lessen their value as works of fiction. And when a writer passes off a work as a work of non-fiction, deliberately hiding the fact that much of its content was made up, we see that as fraudulent. (There are numerous examples. One famous case is “Jimmy’s World”, written for the Washington Post in 1980 by journalist Janet Cooke; the article won her a Pulitzer Prize that she later returned.)