Both theories argue that time is in favor of their hypothesis more than the other. The REH claims that time may work against life, which in turn makes life on Earth rare and special (Peter Ward & Donald Brownlee). Supporters of the REH state that complex life takes far too long to form, for example life on Earth took billions of years to happen, and that other planets may perhaps only be in the beginning stages of life forming. That, however, is very unlikely too. Scientists, also, declare that catastrophic events are more likely to wipe out budding life before it can evolve into complex life because of the amount of time it takes for life to develop and grow (Milan Cirkovic). The more time forming life requires, the more chances there are of random events destroying that life on the planet. Milan Cirkovic, in his “Earths: Rare in Time, Not Space?,” debates that extraterrestrial life may exist outside the Milky Way galaxy; but, he ultimately agrees with astrobiologists Ward and Brownlee. He claims that life would have been abundant in the beginning stages of the universe being born; however, for new life to be forming now would be a rarity and that since the universe was so destructive in its beginning stages that the majority of potential new life would have most likely been wiped out then too. Because it is already biological difficult for single celled organisms to evolve into multicellular organisms, scientists whom believe the REH argue that time is just too much of a flexible factor to determine if life exist elsewhere in the universe. Although these scientists have valid argumentative points, the POM effortlessly counters these claims with evidence to disprove the