The counterplan leads to legislation.

In addition, activists noted that education stemming from litigation can influence government decision makers. This potentially includes state and federal legislators as well. Attorney Lauren Smedley suggested that judicial decisions can "serve as a springboard for further legislation." Likewise, another attorney-activist described litigation activity as having three parts: litigation, education, and legislation. Although she does not play a direct role in the third, this attorney asserted that, in conjunction with litigation, "ideally, there should be a piece of legislation ready to go so that an angry public that has just read all about it ... can say 'now Mr. or Ms. Assemblyperson, vote for this."'

From this we see litigation defined beyond the realm of implementation and regulatory enforcement. Litigation is viewed and used as a catalyst for legislation. In addition, the evidence and information revealed during trials may provide the impetus for other activity. As Kaplan noted, even if a case does not result in a direct judicial victory, the "emergence of evidence ... may help us to crystallize the grievance that we have and help us to formulate another strategy either in the courts or not in the courts." In Kaplan's view, litigation has meaning-making power for animal rights advocates. It may contribute to the formulation of complaints and strategies and may foster new ways of thinking about and approaching an issue. More generally, litigation by one group can catalyze litigative activity by others. As was suggested in Animals' Agenda, a court decision that overturned a hunter harassment law in New Hampshire "provides potent ammunition for those who wish to challenge the constitutionality of similar legislation in other states" (Animals' Agenda, December 1986, 28).