 The reliance on Newark's article was also criticised, since "Neither he nor Goff attempted to justify their opinion with reference to anything external to [the "Rylands"] judgment".Clearwater points out that the original judgment in "Rylands" required modification "the price paid for which was legal uncertainty" to make it socially acceptable, which he sees as evidence that "Rylands" was, despite what Newark says, a significant change to the law.Peter Kutner, a professor of law at the University of Oklahoma, argues that there is a significant ambiguity in Goff's judgment.