Like Poincaré, Einstein concluded in 1906 that the inertia of electromagnetic energy is a necessary condition for the center-of-mass theorem to hold. On this occasion, Einstein referred to Poincaré's 1900 paper and wrote: "Although the merely formal considerations, which we will need for the proof, are already mostly contained in a work by H. Poincaré2, for the sake of clarity I will not rely on that work." In Einstein's more physical, as opposed to formal or mathematical, point of view, there was no need for fictitious masses. He could avoid the "perpetual motion" problem because, on the basis of the mass–energy equivalence, he could show that the transport of inertia that accompanies the emission and absorption of radiation solves the problem. Poincaré's rejection of the principle of action–reaction can be avoided through Einstein's , because mass conservation appears as a special case of the energy conservation law.