The article seemed to omit a central issue, however—economics. To have sex with a past or present patient is an intentional act, hence, an intentional tort, which precludes coverage by malpractice insurance. Plaintiffs’ attorneys have had two choices in making such cases triable: 1) stressing the other negligences commonly found in such cases (2) or 2) "creating" a negligent (insurable) tort by claiming mismanagement of the transference, a form of (insurable) negligence. Legal precedent has then enshrined the centrality of a transference analysis, even when it does not fit, as Drs. Malmquist and Notman so effectively pointed out.