 Schulhofer (1998) argues, in a similar vein, that the law should recognize two different offenses: sexual assault, which involves the use of “physical force to compel another person to submit to an act of sexual penetration” (283); and sexual abuse, a lesser (though still felonious) crime, which involves sexual penetration without the other person’s affirmative and freely given consent. Some commentators have observed that developing such a lesser offense may aid in winning convictions, as juries are reluctant to convict nonviolent offenders of rape. Anderson (2005a) criticizes this approach, however, pointing out that survivors of what she calls “all-American rape” (nonconsensual sex without extrinsic force or violence, usually committed by an acquaintance) suffer trauma at least as severe as do survivors of forceful rape. She contends that “all-American rape” should retain the powerful label (and potentially severe penalty) of rape, while rapists who employ violence extrinsic to the rape itself should be charged with rape and other offenses (such as kidnapping or aggravated assault) as appropriate.