The causal theory of reference (CTR) provides a well-articulated and widely-accepted account of the reference relation. On CTR the reference of a term is fixed by whatever property causally regulates the competent use of that term. CTR poses a metaethical challenge to realists by demanding an account of the properties that regulate the competent use of normative predicates. CTR might pose a challenge to ethical theorists as well. Long (2012) argues that CTR entails the falsity of any normative ethical theory. First-order theory attempts to specify what purely descriptive property is a fundamental right-making property (FRM). Long contends that the notion that the FRM causally regulates competent use of the predicate ‘right’ leads to a