 In its modern guise, ST was established in 1986, with the publication of Robert Gordon’s “Folk Psychology as Simulation” and Jane Heal’s “Replication and Functionalism”. These two articles criticized the Theory-Theory and introduced ST as a better account of mindreading. In his article, Gordon discussed psychological findings concerning the development of the capacity to represent others’ false beliefs. This attracted the interest of developmental psychologists, especially Paul Harris (1989, 1992), who presented empirical support for ST, and Alison Gopnik (Gopnik &amp; Wellman 1992) and Joseph Perner (Perner &amp; Howes 1992), who argued against it—Perner has since come to defend a hybrid version of ST (Perner &amp; Kühberger 2005).