 Like MacKinnon, Anderson sees a fundamental problem in the notion of sexual consent as “a woman’s passive acquiescence to male sexual initiative” (1406). Negotiation, in contrast, “suggests not the granting of permission for the actions of another … but an active consultation with someone else to come to a mutual agreement” (1421). The negotiation model thus requires “consultation, reciprocal communication, and the exchange of views before a person initiates sexual penetration” (1421). (This requirement of consultation before penetration distinguishes Anderson’s approach from Pineau’s, despite their shared emphasis on communication; in addition, Pineau’s model retains an overall consent standard whereas Anderson abandons that standard.) Unless and until a relational context has been established that enables partners to interpret reliably each other’s nonverbal behavior, the negotiation must be verbal. The negotiation model is gender-neutral, requiring that any person who initiates sexual penetration consult verbally with his or her partner (of either gender) to come to a mutual understanding of whether both parties want penetration to occur. Such communication, Anderson observes, “expresses an interest in the other person’s perspective … [and] a willingness to consider the other person’s inclinations and humanity. It expresses that the other person matters” (1423). The negotiation model thus differs at least in spirit from even a version of the Yes Model that requires verbal consent, in that it emphasizes mutuality rather than a one-sided permission-seeking.