 It is tempting to construe this idea of non-objectivity as “mind-dependence,” though this, as we will see below, is a tricky notion, since something may be mind-independent in one sense and mind-dependent in another. Cars, for example, are designed and constructed by creatures with minds, and yet in another sense cars are clearly concrete entities whose ongoing existence does not depend on our mental activity. Those who feel pessimistic that the notion of mind-dependence can be straightened out might prefer to characterize moral realism in a way that makes no reference to objectivity. There is also the concern that the objectivity clause threatens to render moral anti-realism trivially true, since there is little room for doubting that the moral status of actions usually (if not always) depends in some manner on mental phenomena, such as the intentions with which the action was performed or the episodes of pleasure and pain that ensue from it. (See Sayre-McCord 1986; also his the entry on  moral realism.)  Whether such pessimism is warranted is not something to be decided hastily. Perhaps the judicious course is to make a terminological distinction between minimal moral realism—which is the denial of noncognitivism and error theory—and robust moral realism—which in addition asserts the objectivity of moral facts. (See Rosen 1994 for this distinction.) In what follows, however, “moral realism” will continue to be used to denote the traditional robust version.