 Indeed, it is difficult to think of any serious version of moral success theory for which the moral facts depend in no way on mental activity. Yet to conclude that the distinction between minimal and robust realism cannot be upheld would be premature. Many metaethicists who reject noncognitivism and the error theory, and thus count as minimal realists, continue to define their position (often under the label “constructivism”) in contrast to a realist view. (See Bagnoli 2002; Ronzoni 2010; Street 2010, 2012. See also the entry on  constructivism in metaethics.)  The challenge is to pick among the various mind-(in)dependence relations in the hope of drawing a distinction that is philosophically interesting and meshes satisfactorily with our preexisting philosophical taxonomy, such that some success theorists count as realists and some do not.