Stewart Brand in Whole Earth Discipline described some of Shiva's statements as pseudo-scientific, calling her warnings about "heritable sterility" ("Stolen Harvest", 2000) a "biological impossibility" but also plagiarism from Geri Guidetti, owner of the seed supplier company Ark Institute, and a "distraction" created by inflating the potential of terminator genes based on a single 1998 patent granted to a US company. Brand also criticized the position of anti-GMO activists, including Shiva, who forced Zambia's government to reject internationally donated corn in 2001-02 because it was "poisoned", as well as during the cyclone disaster in India. On the latter Shiva argued, "emergency cannot be used as market opportunity", to which Brand responded, "anyone who encourages other people to starve on principle should do some of the starving themselves". In 1998 Shiva was also protesting against Bt cotton program in India, calling it "seeds of suicide, seeds of slavery, seeds of despair", claiming she was protecting the farmers. Restrictive laws established in India under anti-GMO lobbying, however, led to widespread grassroots "seed piracy" where Indian farmers illegally planted seeds of Bt cotton and Bt brinjal, obtained either from experimental plantations or from Bangladesh (where they are planted legally) due to increased yield and reduced pesticide usage. As of 2005 over 2.5 million hectares were planted with "unofficial" Bt cotton in India, of which Noel Kingsbury said: