 Theorists who believe that cases of failed attempts and/or sadistic voyeurism show that evil actions need not cause or allow significant harm nevertheless tend to believe that evil actions must be connected in an appropriate way to significant harm (See, e.g., Kramer 2011, 203–223; Russell 2007, 676; Formosa 2019, 262–265). However, others dispute this contention. These theorists argue instead that there can be cases of “small-scale evil” where evil actions involve very little or no harm (De Wijze 2018; Garrard 1998 and 2002; Morton 2004, 60). These cases constitute the third sort of argument against the claim that evil actions must cause or allow significant harm. For example Eve Garrard has suggested that schoolyard bullies perform evil actions even though they do not cause very much harm (Garrard 1998, 45), while Stephen de Wijze has argued that torturing and killing what you know to be a lifelike robot would be evil even if the robot has no conscious life (De Wijze 2018, 34).