The German car company Volkswagen was recently embroiled in an unethical car emissions scandal. Volkswagen engineer James Liang has pleaded guilty to creating and embedding a software program inside more than 500,000 Volkswagen diesel cars to manipulate the cars' emissions ratings. This software program would allow cars with high levels of nitrogen oxide emissions to pass auto emissions tests and be sold in the United States. Some cars had up to forty times the standard legal car emissions limit. This is an unethical decision on the part of Volkswagen and James Liang because they did not take their actions with good will. Volkswagen also didn't consider the consequences if anyone were to catch the company producing. The foundation for a utilitarian approach to rules is the consequences involved in a situation. Rule utilitarianism defines that the right action that an individual should take is the action that has the least number of consequences involved and brings the most happiness to an individual. Kant's theory, however, does not focus on the consequences of the outcome, rather than on the reasoning or intentions why a person chose to approach a situation. Furthermore, Kant's moral theory is related to the Golden Rule and people should not be used only as a means to benefit another person. The term “mere means” is when someone takes an action and does not consider the other people involved in the situation. . By having this software inside the vehicle that provided false pollution control readings, Volkswagen made a false advertisement to its customers by claiming that the car is safe to use. In this case, Volkswagen is only using its customers to sell diesel vehicles for the benefit of its company. Additionally, some cars would emit nearly forty times the legal gas emissions standard for diesel cars in the United States. In this situation, Volkswagen's actions used the citizens of the United States as "mere means" and did not consider what effects their decision might have on the country or on the clean air of the United States.