 A more significant threat to the link between manipulation and autonomy appears in an influential paper by Sarah Buss. She argues that “when we are obligated to refrain from manipulation or deceiving one another, this has relatively little to do with the value of autonomy” (S. Buss 2005: 208). Buss’s argument has two parts. First, she claims that manipulation does not, in fact, deprive its victim of the ability to make choices; indeed, it typically presupposes that the target will make her own choice. But if the manipulation does not take away the target’s choice, Buss maintains, it does not undermine her autonomy. (For a similar argument, see Long 2014). Second, Buss argues that it is false to claim that an autonomous agent would rationally reject being subjected to manipulative influences. To support this claim, Buss argues that manipulation and deception are “pervasive forms of human interaction which are often quite benign and even valuable” (S. Buss 2005: 224). Her most notable example is the cultivation of romantic love, which often involves—and may even require—significant amounts of behavior that is aptly described as manipulation.