sentences:  In addition to the aforementioned report by Cooke and Michie that a three-factor structure may provide a better model than the two-factor structure, Hare's concept and checklist have faced other criticisms.In 2010, there was controversy after it emerged that Hare had threatened legal action that stopped publication of a peer-reviewed article on the PCL-R. Hare alleged the article quoted or paraphrased him incorrectly.The article eventually appeared three years later.