Like Berlin and Kay, Maclaury concluded that the domain is governed mostly by physical-biological universals. Studies by Berlin and Kay continued Lenneberg's color research. They studied color terminology formation and showed clear universal trends in color naming. For example, they found that even though languages have different color terminologies, they generally recognize certain hues as more focal than others. They showed that in languages with few color terms, it is predictable from the number of terms which hues are chosen as focal colors, for example, languages with only three color terms always have the focal colors black, white and red. The fact that what had been believed to be random differences between color naming in different languages could be shown to follow universal patterns was seen as a powerful argument against linguistic relativity. Berlin and Kay's research has since been criticized by relativists such as Lucy, who argued that Berlin and Kay's conclusions were skewed by their insistence that color terms encode only color information. This, Lucy argues, made them blind to the instances in which color terms provided other information that might be considered examples of linguistic relativity. Universalism Universalist scholars ushered in a period of dissent from ideas about linguistic relativity. Lenneberg was one of the first cognitive scientists to begin development of the Universalist theory of language that was formulated by Chomsky as universal grammar, effectively arguing that all languages share the same underlying structure. The Chomskyan school also holds the belief that linguistic structures are largely innate and that what are perceived as differences between specific languages are surface phenomena that do not affect the brain's universal cognitive processes. This theory became the dominant paradigm in American linguistics from the 1960s through the 1980s, while linguistic relativity became the object of ridicule. Other universalist researchers dedicated themselves to dispelling other aspects of linguistic relativity, often attacking Whorf's specific points and examples. For example, Malotki's monumental study of time expressions in Hopi presented many examples that challenged Whorf's "timeless" interpretation of Hopi language and culture, but seemingly failed to address linguistic relativist argument actually posed by Whorf (i.e. that the understanding of time by native Hopi speakers differed from that of speakers of European languages due to the differences in the organization and construction of their respective languages; Whorf never claimed that Hopi speakers lacked any concept of time). Malotki himself acknowledges that the conceptualizations are different,