 Another approach argues that a novel consequence of a theory is one that was not known to the theorist at the time she formulated the theory—this seems like a version of the temporal conception, but this point appeals implicitly to the heuristic conception: if a theorist knew of a result prior to constructing a theory which explains it, it may be difficult to determine whether that theorist somehow tailored the theory to fit the fact (e.g., she may have done so unconsciously). A knowledge-based conception is thus the best that we can do to handle this difficulty (Gardner  1982).[5] 