 The goal was to explain to the court the results and the data sets with as many counter-arguments concerning how the estimate was biased upwards and then they were closed off. Beyond portraying minimums as best estimates, basically, if you say, well, what's the minimum it could be, and then say that's the best estimate, no, that's the minimum estimate, Kessler misleads his readers with a half-truth that the 2014 paper estimated