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Fair enough, but they shouldn't. Factory farming should be used to describe the industrialization of farming.
Doesnt that already go by a different name?
I mean technically, the plants are all grown outside in a big garden. Then they get plucked, and shipped off to the supermarket right? Or they go to a food processor to be turned into juice or something. But by then it is no longer a farm really.
And plants dont have feelings. Cows, pigs, goats and chickens, etc can suffer. So no real need to give plants an after thought and call what they go through with any meaning. Animals though, we take more consideration with.