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Other, more theoretical arguments in opposition to encroachment have also been superior; see for instance Ichikawa, Jarvis, and Rubin , who argue that pragmatic encroachment is at odds with necessary tenets of belief-desire psychology. Another attainable line is the one talked about in §2—to strengthen the justification situation to rule out Gettier circumstances as justified. In order for this technique to forestall Zagzebski’s recipe from working, one would need to posit a justification situation that precludes the potential for step one above—the only apparent means to do that is for justification to ivolve fact. If it does, then it's going to of course be inconceivable to start out with a case that has justified false belief. This type of approach is by no means mainstream, but it does have its defenders—see e.g., Sturgeon 1993 and Merricks 1995. Sutton 2007 and Littlejohn 2012 defend factive approaches to justification on different grounds. To say the least, not everyone i