 The concept of duress is similarly fraught. The law distinguishes “physical duress”, which bypasses the coercee’s rational control over her actions, from duress via “wrongful threats” which operates through the will of the coercee (R2: §§ 174-5; cf. Nozick 1969). A threat is considered wrongful when the threatened consequence leaves the coercee with “no reasonable alternatives” to compliance. The law does not give detailed guidance on the baseline of “reasonable alternatives” against which the wrongfulness of a threat might be measured. The question of the baseline has attracted significant commentary in the philosophical literature on coercion. Nozick (1969: 446) offers a characterization in terms of the “normal or natural or expected course of events”. Others have analyzed the baseline in explicitly normative terms, as a set of options that persons ought to have as a matter of right (Wertheimer 1987; cf. Berman 2002). While the paradigmatic threat (“your money or your life”) makes the coercee worse off relative to her baseline regardless of compliance, threats in commercial exchange are often more subtle. An offeror might threaten to worsen the offeree’s situation if she refuses an offer, even if its acceptance would be baseline-improving. To illustrate, if workers refuse to work under the terms of an existing contract unless the employer consents to a modification, the employer may be under duress even if the proposed modification is mutually beneficial.