There is historical controversy regarding who should receive credit for articulating the central tenet of modern cell theory, the principle of biogenesis. Although Rudolf Virchow popularized the idea that all cells arise from other cells in his ${}1855$ essay 'Cellular Pathology,' his former colleague Robert Remak had published the same idea ${}3$ years earlier. In ${}1858$, Virchow dismissively claimed that his ${}1855$ publication was an editorial rather than a scientific paper, and thus did not require a citation for Remak's prior work.