 Yet, like the other accounts we have considered, this account is subject to criticism. One possible shortcoming stems from cases of competition (Kerstein 2009: 170–171). Sometimes people have the end of being the sole winner in a competition. A competitor pursuing such an end might, according to the account, be treating his competitor merely as a means and thus acting wrongly, even though she abides fully with the competition’s rules. To begin, competitors sometimes count as treating one another as means. To invoke one account of doing so (discussed in  §2  above), Player A intentionally does something to her opponent, Player B, for example, tries to defeat him, which requires B’s presence or participation. Moreover, A’s proximate end in trying to defeat B might be to win top player for the year; and B’s proximate end in trying to defeat A might also be to win top player for the year. To focus on A, she is using B to realize an end, namely her (A’s) winning top player for the year, but B cannot share this end. In willing that A be top player of the year, B would, in effect, be willing to be thwarted in his attempt to win top player for the year, assuming that there can be no tie for top player. Finally, awareness on B’s part of the likely effects of A’s successful pursuit of being the top player would presumably not result in B’s being willing to give up his (B’s) end of being top player. In trying to defeat B to be number one, A would be treating B merely as a means and thereby acting wrongly, the account seems to imply, even if A competed fairly, that is, violated none of the competition’s rules. Some might find this implication implausible. Sometimes becoming the best in some endeavor involves defeating (and using) competitors to do so. But defeating (and using) competitors to be the best, especially when they have freely entered a competition, need not amount to acting wrongly, some might insist.