 She goes on to argue that the manipulator need not be aware that she has that intention (Baron 2014, 101). Manne agrees; to support this claim, she offers the example of Joan, who gives extravagant gifts to relatives who pay her less attention than (she thinks) they should (Manne 2014, 225). Manne tells Joan’s story in such a way that it seems plausible to say both that Joan’s gift-giving is a manipulative attempt to make her relatives feel guilty, and that Joan does not consciously intend to make her relatives feel guilty. If Manne’s description of her example is correct, then it seems that Joan can manipulate her relatives into feeling guilty without having any conscious intention of making them feel guilty. (Later, Manne [2014, 235] goes even farther, suggesting that “people can even behave manipulatively despite consciously intending not to.”) Of course, those who hold that manipulation requires more conscious intention than Manne allows might simply deny that Joan’s behavior is manipulative. Nevertheless, the arguments offered by Baron and Manne raise important questions about the level of conscious intentionality required for an action to be manipulative.