Source: (2004) Penn State Law Review. 108(4): 1017-1076.Robert Creoâs professional experience and expertise stem from his many years of work as a commercial mediator. On the basis of that work he argues that mediation is an art and not a science. There is, as he puts it, a growing 'legalism and institutionalism' in the field of mediation. A number of movements and events are tending toward the development and enforcement of uniform standards of rules and conduct for mediators. While not advocating a lack of competency and professionalism for mediators, Creo expresses concern about the prospect of external regulation of mediation, of âmediation orthodoxy.â? He argues instead that free market principles should be the guiding forces in any movement toward formal professionalism. Tolerance and diversity of practice should be core values of the mediation community.