 Just one year after Ewing in effect defended a fairly radical form of moral particularism, W.D. Ross argued for a more moderate form. Ross occupies a very interesting place in the history of particularism, as he has served as both an inspiration and a foil to modern particularists. Ross put forward a battery of “prima facie duties” specifying types of conduct—for example acts of gratitude—that are always, in some sense, obligatory. The obligation in question need not be an all things considered one, however, since a conflicting prima facie duty might, in the circumstances, be more important.