Some commentators have criticized individual American New Atheists such as Sam Harris and Christopher Hitchens for making Islamophobic statements.[63][64][65] Commenting on Greenwald's response to Harris, Jerome Taylor, writing in The Independent, has stated that, "Like Chomsky, who has also been a vocal critic of New Atheism, he [Greenwald] blames writers like Harris for using their particularly anti-Islamic brand of rational non-belief to justify American foreign policies over the last decade.[66][67] Two educators at universities in Utah have claimed that these American atheist activists invoke Samuel Huntington's 'clash of civilizations' theory to explain the current political contestation and that this forms part of a trend toward "Islamophobia [...] in the study of Muslim societies".[68]