We welcome the opportunity to respond to Jonathan Bonnitcha and Robert McCorquodale’s discussion of the 2011 United Nations Guiding Principles on Business and Human Rights... When it comes to the concept of corporate human rights due diligence, however, Bonnitcha and McCorquodale stray from both. They analogize from state-based legal concepts and contexts to private sector non-legal processes and miss critical elements in the logic and provisions of the Guiding Principles. They thereby end up in a place that is quite inconsistent with, and falls short of, the Guiding Principles, while failing to reflect how key stakeholders are currently implementing them. In trying to fit everything into, or render compatible with, traditional legal forms, they inadvertently illustrate why international human rights law has had such limited effects on corporate practices and why the Guiding Principles have succeeded where conventional initiatives have failed.