Take a web application that sets a cookie. Now let's say the application takes the cookie value included in subsequent requests and outputs it into the HTML of the responses. Also assume this occurs with no authentication required and with no output encoding being done. Yes, this application is susceptible to reflected cross-site scripting.
I recently tested such an application. Interestingly, both HP WebInspect and Burp's active scanner reported the XSS vulnerability, but they were at opposite ends of the spectrum in terms of rating its severity. WebInspect rated it "critical" (the most severe rating), while Burp rated it as "information", which implies you don't even need to concern yourself about it.
So why the big disparity in these tools? Is it critically severe, or is it really no big deal? In my view, the answer is somewhere in between. This type of vulnerability is clearly very difficult to exploit. An attacker would somehow have to cause a victim's browser to send a script-injected cookie as part of a request to the vulnerable site. But regardless of the difficulty level, the application should properly encode the cookie value when it is written into the HTML page. Please let me know your opinion on how serious you think this type of vulnerability is.