In a 2006 article published in the Journal of Clinical Investigation, a group of writers that included historian of science Ronald L. Numbers (author of The Creationists), philosopher of biology Elliott Sober, Wisconsin State Assembly representative Terese Berceau, and four members of the Department of Biochemistry at the University of Wisconsin–Madison characterized such claims as being a hoax. On their website refuting the claims in the film Expelled (which featured Meyer), the National Center for Science Education states that "Intelligent design advocates ... have no research and no evidence, and have repeatedly shown themselves unwilling to formulate testable hypotheses; yet they complain about an imagined exclusion, even after having flunked the basics." In analysing an Academic Freedom bill that was based upon a Discovery Institute model statute, the Florida Senate found that "According to the Department of Education, there has never been a case in Florida where a public school teacher or public school student has claimed that they have been discriminated against based on their science teaching or science course work." Signature in the Cell On June 23, 2009, HarperOne released Meyer's Signature in the Cell: DNA and the Evidence for Intelligent Design. The philosopher Thomas Nagel, who generally argues in opposition to the philosophical position of physicalist reductionism specifically and materialism more generally, submitted the book as his contribution to the "2009 Books of the Year" supplement for The Times, writing "Signature in the Cell...is a detailed account of the problem of how life came into existence from lifeless matter – something that had to happen before the process of biological evolution could begin ... Meyer is a Christian, but atheists, and theists who believe God never intervenes in the natural world, will be instructed by his careful presentation of this fiendishly difficult problem." Stephen Fletcher, chemist at Loughborough University, responded in The Times Literary Supplement that Nagel was "promot[ing] the book to the rest of us using statements that are factually incorrect." Fletcher explained "Natural selection is in fact a chemical process as well as a biological process, and it was operating for about half a billion years before the earliest cellular life forms appear in the fossil record." In another publication, Fletcher wrote: "I am afraid that reality has overtaken Meyer's book and its flawed reasoning", pointing out scientific problems with Meyer's work by citing how RNA "survived and evolved into our own human protein-making factory,