they believe it would allow an attorney to evade responsibility for a frivolous lawsuit filed by their client. Certain critics have argued that legal ghostwriting actually gives the self-represented litigant an unfair advantage over his or her adversary, even when that adversary has an attorney. The reason for this is that judges have had a history of giving pro se litigants more leeway in the courtroom to make up for their lack of experience. For example, a person appearing pro se might be allowed to fix a procedural error but had a lawyer made the same mistake, their error would have led to some adverse consequence. When a self-represented litigant uses an attorney as a ghostwriter, critics argue he or she should not be entitled to any special treatment. However, proponents of legal ghostwriting point out that while judges might grant certain flexibility to pro se clients on procedural matters, no judge would rule in favor of a party simply because they lacked an attorney. To avoid the potential for this unfair advantage, some jurisdictions, like New York, require an attorney to disclose in papers submitted to the court that they were prepared by an attorney, but attorneys are not required to disclose their name or firm. Many jurisdictions look at the intent of the attorney for his legal ghostwriting. Where an attorney used the ghostwriting technique to avoid disclosing that he was not admitted in the state where the case was filed, it may be ruled unethical. However the American Bar Association Model Rules of Professional Conduct have been amended to allow for legal ghostwriting where the attorney merely intends to offer unbundled legal services to a client. Another ethical concern concerning unbundled legal services is that it leads to the commoditization of law. Rather than treating the law as a profession, critics believe unbundling might lead to a factory-like approach, where cases are treated with a "one-size-fits-all" approach. However, Richard Susskind in his 2008 book "The End of Lawyers: Rethinking the Nature of Legal Services," argues that, as technology progresses, lawyers might have no choice but to move toward commoditization. With the emergence of do-it-yourself companies that sell blank legal documents like LegalZoom, lawyers must compete with new low-cost options. Further driving down attorney fees has been outsourcing, where attorneys educated in American law but not necessarily licensed in any state provide services to law firms at reduced