 Civil recourse writers have also emphasized the plurality of torts, arguing that tort law provides a unified system, because it brings together the full range of relational wrongs, including not only negligence of the sort that has occupied so much legal scholarship over the past century, but also defamation, battery, intentional infliction of emotional distress and many other wrongs. Civil recourse theory emphasizes these wrongs, not because they are the main business of modern legal systems, but because a focus on their relational structure clarifies the ways in which torts are relational wrongs. An excessive focus on negligence makes non-relational accounts, whether focused on deterrence or compensation, appear at least superficially viable. If, however, tort law really is a unified doctrinal area, then focus on other torts clarifies that the basic form of tortious wrongdoing can only be understood relationally. The tort of fraud provides a particularly clear illustration: it requires that the defendant intentionally represented the subject matter of the deceit to the deceived plaintiff. If someone purchases a forged artwork based on a lie that the seller told to someone else, the purchaser has no action in fraud against the seller. So, too, in defamation, only the person who was defamed has a cause of action, even if that person’s family members or business associates will suffer as much or more from the defamation.