This and other communist death tolls have been criticized by various historians and scholars. Any attempt to estimate a total number of killings under communist regimes depends greatly on definitions, ranging from a low of 10–20 millions to as high as 110 millions. Criticism of some of the estimates is mostly focused on three aspects, namely that the estimates were based on sparse and incomplete data when significant errors are inevitable, that the figures were skewed to higher possible values, and that those dying at war and victims of civil wars, Holodomor, and other famines under Communist regimes should not be counted. Historian Andrzej Paczkowski wrote that "[s]ome critics complained that Courtois was 'hunting' for the highest possible number of victims, which led him, as J. Arch Getty wrote in the Atlantic Monthly, to include 'every possible death just to run up the score.' To an extent, the charge is valid. Courtois and other contributors to the volume equate the people shot, hanged, or killed in prisons or the camps with those who were victims of calculated political famines (in the Chinese and Soviet cases), or who otherwise starved for lack of food or died for lack of drugs." Based on the results of their studies, Courtois estimated the total number of the victims at between 65 and 93 million, an unjustified and unclear sum according to Margolin and Werth. In particular, Margolin, who authored the book's chapter on Vietnam, stated that "he has never mentioned a million deaths in Vietnam"; Margolin likened Courtois's effort to "militant political activity, indeed, that of a prosecutor amassing charges in the service of a cause, that of a global condemnation of the Communist phenomenon as an essentially criminal phenomenon." Historians Jean-Jacques Becker and J. Arch Getty criticized Courtois for failing to draw a distinction between victims of neglect and famine and victims of "intentional murder." Regarding these questions, historian Alexander Dallin wrote that moral, legal, or political judgments hardly depend on the number of victims. Getty criticized Malia as a "specialist on the 19th century who has never done original research on the Soviet era." In The Devil in History, political scientist Vladimir Tismăneanu wrote: "Speaking of the number of victims under communist regimes (between 85 and 100 million) and comparing this horrible figure to number of people who perished under or because of Nazism (25 million), Courtois decided to downplay a few