despite the ubiquity of habituation and its modern acceptance as a genuine form of learning it has not enjoyed the same focus within research as other forms of learning. on this topic, the animal psychologist james mcconnell said “...nobody cares…much about habituation”). it has been suggested that the apathy held towards habituation is due to 1) resistance from traditional learning theorists maintain memory requires reproduction of propositional/linguistic; 2) resistance from behaviorists who maintain that "true" learning requires the development of a novel response (whereas habituation is a decrease in a pre-existing response); 3) the behavioral measure of habituation (i.e., a response-decline) is very susceptible to confound by non-learning factors (e.g., fatigue) which, therefore, make it more difficult to study (reviewed in).