Abstract
In his 2018 AJP paper, Shlomo Cohen hints that deception could be a distinct subset of manipulation. We pursue this thought further, but by arguing that Cohen’s accounts of deception and manipulation are incorrect. Deception under uncertainty need not involve adding false premises to the victim’s reasoning but it must involve manipulating her response, and cases of manipulation that do not interfere with the victim’s reasoning, but rather utilize it, also exist. Therefore, deception under uncertainty must be constituted by covert manipulation.