In the literature about harm, the counterfactual comparative account has emerged as a main contender. According to it, an event constitutes a harm for someone iff the person is worse off than they would otherwise have been as a result. But the counterfactual comparative account faces significant challenges, one of the most serious of which stems from examples involving non-harmful omitted actions or non-occurring events, which it tends to misclassify as harms: for example, Robin is worse off when Batman does (...) not give him a new set of golf clubs, but Batman has not harmed him. In this article, I will clearly state the counterfactual comparative account; state and explain this objection to the account; canvass several unsatisfactory responses; and attempt to show how the account can overcome the objection. This solution involves distinguishing between principles concerning the existence of harm and principles concerning attributions of responsibility for harm. (shrink)