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Pragmatically speaking, there is a stronger case for using the language of “futility” than “potentially appropriate” for end-of-life care. The latter obscures the reality of death as a part of human life. Do patients die because death always wins in the end? Or do they die because physicians run out of ways to treat them? In the end, modern medicine has made the conquest of death its de facto goal. That is a fundamental error, one which the language of “potentially appropriate” is unwittingly supportive of.