 Whether R must have φ-ed intentionally. Most philosophers hold that Y owes R gratitude only if R φ-ed intentionally. Some philosophers have argued that gratitude is not warranted in response to all intentional acts, but only those that are voluntary (Simmons 1979). On this view, if R benefits Y only because R has a gun to her head, she does not deserve Y’s gratitude, even if she benefited Y intentionally. Other philosophers specify that in order for gratitude to be warranted, R’s φ-ing must have been intentional under the description “benefiting Y” (Manela 2016a). On this view, if R φs unintentionally, or intentionally under the description “harming X”, and thereby incidentally happens to benefit Y, Y would not owe R gratitude for φ-ing (though Y’s appreciation for R’s φ-ing may be warranted). This view, if correct, might have an intriguing implication for children’s gratitude to their parents. Some philosophers have argued that to intentionally create a child does not amount to benefiting that child, since to benefit someone is to make him better off than he was before, and when one chooses to bring a child into existence, there was no child there before that choice who could be made better off by it. If this is true, then parents who intentionally bring children into existence cannot do so under the description “benefiting those children”, insofar as we cannot intend the impossible; and if intention to benefit is necessary for gratitude to be warranted, children’s gratitude to their parents for bringing them into existence is never warranted. Philosophers who hold this view (e.g., McConnell 1993) can of course still hold that children owe their parents gratitude for benefits their parents conferred on their children after bringing them into existence.