According to W.H. Thorpe, the term was devised by C. Lloyd Morgan after trying out similar phrases "trial and failure" and "trial and practice". Under Morgan's canon, animal behaviour should be explained in the simplest possible way. Where behaviour seems to imply higher mental processes, it might be explained by trial and error learning. An example is the skilful way in which his terrier Tony opened the garden gate, easily misunderstood as an insightful act by someone seeing the final behaviour. Lloyd Morgan, however, had watched and recorded the series of approximations by which the dog had gradually learned the response, and could demonstrate that no insight was required to explain it.