In an extended comment on work by this paper’s authors, Gustafsson in a previous issue of this journal reaches scathing judgements on Russia’s arbitrazh (or commercial) courts and draws strong conclusions about the prospects for the rule of law in Russia. He concludes that litigants use the courts because they can bribe the judges. His paper revives old tales about the 1990s that we showed previously were myths. We examine Gustafsson’s argument both conceptually and empirically.