One popular approach to theorizing about phenomenal consciousness has been to connect it to representations of a certain kind. Representational theories of consciousness can be further sub-divided into first-order and higher-order theories. Higher-order theories are often interpreted as invoking a special relation between the first-order state and the higher-order state. However there is another way to interpret higher-order theories that rejects this relational requirement. On this alternative view phenomenal consciousness consists in having suitable higher-order representations. I call this ‘HOROR’ (‘Higher-Order Representation Of a Representation’) theory to distinguish it from relational versions of higher- order theory. In this paper I make the case that HOROR theory is a plausible account of the real nature of phenomenal consciousness whatever one’s views are about whether it is physical/reducible or not. I first clarify HOROR theory and compare it to the more traditional same-order and higher-order thought theories. Afterwards I move to presenting some considerations in favor of HOROR theory.