original grant of summary judgement for the defendant. After Daubert, it was expected that the range of scientific opinion evidence used in court would be expanded. However, courts have strictly applied the standards in Daubert, and it has generally been successful in excluding "junk science" or "pseudoscience", as well as new or experimental techniques and research that the decision might have been expected to deem admissible. Discerning between science and "pseudoscience" was the theme of a book by Karl Popper whose summary was quoted in Daubert: "the criterion of the scientific status of a theory is its falsifiability, or refutability, or testability." The book, Conjectures and Refutations: The Growth of Scientific Knowledge (5th ed. 1989), pp. 34–57, explains how psychology is more like astrology than astronomy because it does not make predictions about an individual which are falsifiable. He wrote that "the impressive thing about" Einstein's predictions "is the risk involved...If observation shows that the predicted effect is definitely absent, then the theory is simply refuted." But "it was impossible to describe a human behaviour" which would be accepted as proving psychology false. The considerations in Daubert do not all have to be met for the evidence to be admitted. It is necessary only that the majority of the tests be substantially complied with. The principle in Daubert was expanded in Kumho Tire Co. v. Carmichael (1999), where the evidence in question was from a technician and not a scientist. The technician was going to testify that the only possible cause of a tire blowout must have been a manufacturing defect, as he could not determine any other possible cause. The Court of Appeal had admitted the evidence on the assumption that Daubert did not apply to technical evidence, only scientific evidence. The Supreme Court reversed, saying that the standard in Daubert could apply to merely technical evidence, but that in this case, the evidence of the proposed expert did not meet the standard. Pronunciation of Daubert While not a matter of law, there has been disagreement over the pronunciation of the plaintiff's surname. Michael H. Gottesman, Jason Daubert's attorney, reports that Daubert and his family do not use the French pronunciation, which would sound similar to "dough-bear" . Rather, they pronounce their family name in the same manner as Dow-Burt. The popular use of the French pronunciation may have arisen from Gottesman refraining from correcting the justices during oral