is possible to circumvent surrender to the exemplar by eliminating any necessity for it to be considered that JTB apply in just those areas that Gettier has rendered obscure, without thereby lessening the force of JTB to apply in those cases where it actually is crucial. Then, though Gettier's cases stipulate that Smith has a certain belief and that his belief is true, it seems that in order to propose (1), one must argue that Gettier, (or, that is, the writer responsible for the particular form of words on this present occasion known as case (1), and who makes assertion's about Smith's "putative" beliefs), goes wrong because he has the wrong notion of justification. Such an argument often depends on an externalist account on which "justification" is understood in such a way that whether or not a belief is "justified" depends not just on the internal state of the believer, but also on how that internal state is related to the outside world. Externalist accounts typically are constructed such that Smith's putative beliefs in Case I and Case II are not really justified (even though it seems to Smith that they are), because his beliefs are not lined up with the world in the right way, or that it is possible to show that it is invalid to assert that "Smith" has any significant "particular" belief at all, in terms of JTB or otherwise. Such accounts, of course, face the same burden as causalist responses to Gettier: they have to explain what sort of relationship between the world and the believer counts as a justificatory relationship. Those who accept (2) are by far in the minority in analytic philosophy; generally, those who are willing to accept it are those who have independent reasons to say that more things count as knowledge than the intuitions that led to the JTB account would acknowledge. Chief among these is epistemic minimalists, Crispin Sartwell, who hold that all true belief, including both Gettier's cases and lucky guesses, counts as knowledge. Experimental research Some early work in the field of experimental philosophy suggested that traditional intuitions about Gettier cases might vary cross-culturally. However, subsequent studies have consistently failed to replicate these results, instead finding that participants from different cultures do share the traditional intuition. More recent studies have been providing evidence for the opposite hypothesis, that people from a variety of different cultures have similar