Examples of universalist influence in the 1960s are the studies by Berlin and Kay who continued Lenneberg's color research. They studied color terminology formation and showed clear universal trends in color naming. For example, they found that even though languages have different color terminologies, they generally recognize certain hues as more focal than others. They showed that in languages with few color terms, it is predictable from the number of terms which hues are chosen as focal colors, for example, languages with only three color terms always have the focal colors black, white and red. The fact that what had been believed to be random differences between color naming in different languages could be shown to follow universal patterns was seen as a powerful argument against linguistic relativity. Berlin and Kay's research has since been criticized by relativists such as Lucy, who argued that Berlin and Kay's conclusions were skewed by their insistence that color terms encode only color information. This, Lucy argues, made them blind to the instances in which color terms provided other information that might be considered examples of linguistic relativity.