 One influential interpretation of “reasonable belief” in sexual consent is that of Lois Pineau (1989), who points out that judgments of reasonableness in this area must be based on some normative conception of healthy, normal sexual interaction. The prevailing conception, which she calls the “aggressive-contractual model,” holds that women’s sexually provocative behavior generates enforceable agreements to have sex, that male sexuality is uncontrollable past a certain point, and that women are not to be trusted in matters of sexuality. Pineau believes that this model is the backdrop against which many people base their judgments about reasonable belief in rape cases. The aggressive-contractual model should be replaced, she argues, with a model of “communicative sexuality,” one that emphasizes “an atmosphere of comfort and communication, a minimum of pressure, and an on-going checkup on one’s partner’s state” (1989, 231). Communicative sexuality is most likely to be rewarding for both parties, allows them to promote each other’s sensual ends non-manipulatively and non-paternalistically, and observes norms appropriate to friendship and trust. Because it is through communication that one gains knowledge of one’s partner’s desires or lack thereof, Pineau contends that “where communicative sexuality does not occur, we lack the main ground for believing that the sex involved was consensual.” She continues: