intent rather on expressing themselves prettily than on conveying their meaning clearly, & still more those whose notions of style are based on a few misleading rules of thumb, that are chiefly open to the allurements of elegant variation," Fowler's term for the over-use of synonyms. Contrary to Fowler's criticism of several words being used to name the same thing in English prose, in many other languages, including French, it might be thought to be a good writing style. An inquiry into the 2005 London bombings found that verbosity can be dangerous if used by emergency services. It can lead to delay that could cost lives. A 2005 study from the psychology department of Princeton University found that using long and obscure words does not make people seem more intelligent. Dr. Daniel M. Oppenheimer did research which showed that students rated short, concise texts as being written by the most intelligent authors. But those who used long words or complex font types were seen as less intelligent. In contrast to advice against verbosity, some editors and style experts suggest that maxims such as "omit needless words" are unhelpful. It may be unclear which words are unnecessary, or where advice against prolixity may harm writing. In some cases a degree of repetition and redundancy, or use of figurative language and long or complex sentences can have positive effects on style or communicative effect. In nonfiction writing, experts suggest that a balance must be struck between, on one hand removing excessive elements that do not aid communication, versus unduly terse style on the other hand, which fails to make its meaning clear. Law professor Neil Andrews suggests that in the writing of legal decisions, for example, "A balance must be struck between judgments which are inadequately reasoned and too terse, cryptic and formulaic, and decisions (especially when multiple judgments are given by an appellate court) which are too long and difficult to unravel." In such cases attention should be paid to the argument underlying a conclusion, so that the language used strikes a balance between simplicity and precision. A number of writers advise against excessive verbosity in fiction. For example, Mark Twain (1835–1910) wrote "generally, the fewer the words that fully communicate or evoke the intended ideas and feelings, the more effective the communication." Similarly Ernest Hemingway (1899–1961), the 1954 Nobel laureate for literature, defended his concise style against a charge by