Similar characters, known as Scarecrow and Straw Man, have appeared in Marvel Comics. Geoffrey Sampson argues that the SSSM is based on a straw man. It had 30 attendees, and featured the burning of a straw man built on site. This is a combination of the straw man fallacy and the ad hominem argument. In the "straw man" approach, there are witnesses to the transfer. They were opposed by Daredevil, Doctor Strange and Straw Man (who betrayed them). Against these ideas, Dembski characterizes both Dawkins' and Gould's argument as a rhetorical straw man. Hedonism was used as a "straw man" argument by opponents of Charvaka. Some argue that current views of culture history are simplified and attack a straw man. Arguing that races are not completely discrete biologically is a straw man argument. The "steel man argument" (or "steelmanning") is the exact opposite of the straw man argument. Lowndes accused Heinlein of using straw man arguments, "countering ingenuous half-truths with brilliant half-truths". One who engages in this fallacy is said to be "attacking a straw man". Nevertheless, it has been used as a straw man to attack the Indo-Aryan Migration theory.