Estlund (2008) has raised a challenge against fairness-based versions of democratic proceduralism. He points out that other decision-making procedures—flipping a coin, for example—also satisfy a fairness requirement. An argument from fairness is thus insufficient to establish the superior legitimacy of democratic decision-making. Pure proceduralists can respond to this challenge by pointing to the distinctive fairness of democratic decision-making procedures. Christiano and Kolodny, for example,