The second way to characterize a constraint against harm is as a constraint against intending harm. This presupposes a distinction between harm that is intended as a means or an end, and harm that is merely foreseen as an unintended side effect. We can again provide some intuitive support for this distinction – in terms of either the idea of using someone or the idea of aiming at evil – but here too the distinction ends up sorting cases in ways that are intuitively unattractive. And once again, attempts to defend the relevance of the distinction are ultimately unsuccessful, as are attempts to show that the distinction would support a constraint.