 In sum, the animal rights position takes the significance of morally considerable claims to be absolute. Thus, any use of animals that involves a disregard for their moral claims is problematic. The significance of an animal’s morally considerable interests according to a utilitarian is variable. Whether an action is morally justified or permissible will depend on a number of factors. The utilitarian position on animals would condemn a large number of practices that involve the suffering and death of billions of animals, but there are cases in which some use of non-human animals, and perhaps even human animals, may be morally justified (Gruen 2011: ch. 4; Gilbert, Kaebnick, &amp; Murray 2012).