The following brief overview offers consideration of why quantitative research on terrorist leader targeting may be a dead-end or at least of questionable use from a policy-maker's perspective. It presents the quest for identifying best policies against terrorism as largely futile given the multi-dimensional and reflexive nature of the strategic interaction of terrorists and counter-terrorists. Developing a doctrine for counterterrorism is not impossible, however. The criticism offered here merely posits that such a doctrine can never be used without case-specific considerations, with special regards to the large number of strategically relevant variables over which decision-makers have weak control or perhaps none at all.