 We have been considering actual consent accounts of agents using others, but not treating them merely as means. We can also develop accounts that invoke other concepts familiar from discussion of sufficient conditions for treating others merely as means, including the concepts of possible end-sharing and possible consent. For example, we might suggest that an agent who uses another does not use that other merely as a means if the other can consent to the agent’s use of him, that is, if the other can avert the use simply by dissenting from it. This suggestion, as well as others that invoke additional concepts we have considered, such as that of end sharing, might generate questionable verdicts regarding exploitation cases. For example, the mother of modest means discussed above can consent to the rich person’s use of her. Her dissent from it alone would stop it from occurring. But some would insist that the rich person is nevertheless treating her merely as a means in making her his personal slave in exchange for educating his children.