better, it is unclear whether it is due the pcl-r's inclusion of past offending history, rather than the personality trait scores that make it unique. criticism in addition to the aforementioned report by cooke and michie that a three-factor structure may provide a better model than the two-factor structure, hare's concept and checklist have faced other criticisms. in 2010, there was controversy after it emerged that hare had threatened legal action that stopped publication of a peer-reviewed article on the pcl-r. hare alleged the article quoted or paraphrased him incorrectly. the article eventually appeared, three years later. it alleged that the checklist is wrongly viewed by many as the basic definition of psychopathy, yet it leaves out key factors, while also making criminality too central to the concept. the authors claimed this leads to problems in over-diagnosis and in the use of the checklist to secure convictions. hare has since stated that he receives less than $35,000 a year from royalties associated with the checklist and its derivatives. hare's concept has also been criticised as being only weakly applicable to real-world settings and tending towards tautology. it is also said to be vulnerable to "labeling effects", to be over-simplistic, reductionist, to embody fundamental attribution error, and not pay enough attention to context and the dynamic nature of human behavior. it has been pointed out that half the criteria can also be signs of mania, hypomania, or frontal lobe dysfunction (e.g., glibness/superficial charm, grandiosity, poor behavioral controls, promiscuous sexual behavior, and irresponsibility). some research suggests that ratings made using the pcl system depend on the personality of the person doing the rating, including how empathic they themselves are. one forensic researcher has suggested that future studies need to examine the class background, race and philosophical beliefs of raters because they may not be aware of enacting biased judgments of people whose section of society or individual lives for whom they have no understanding of or empathy. further, a review which pooled various risk assessment instruments including the pcl, found that peer-reviewed studies for which the developer or translator of the instrument was an author (which in no case was disclosed in the journal article) were twice as likely to report positive predictive findings. notable evaluations lawrence bittaker was evaluated as 39/40. canadian serial killer duo paul bernardo and karla homolka were assessed using the checklist. bernardo was evaluated as 35/40, and homolka 5/40 (a malignant narcissist). ted bundy was evaluated as 39/40. jeffrey dahmer was evaluated as 23/40. brian dugan was evaluated as 38/40. john wayne gacy was evaluated as 27/40. charles guiteau was evaluated as 37.5/40. peter lundin was evaluated as 39/40. brian david mitchell was evaluated as 34/40. clifford olson was evaluated as 38/40. gary ridgway, known as the green river killer, was evaluated at 19/40. aileen wuornos was evaluated as 32/40. dwight york was evaluated as 39/40.