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In biology, the idea of an unbeatable strategy was proposed by W. D.
Hamilton in his 1967 paper on sex ratios in Science.
In this paper Hamilton discusses sex ratios as strategies in a game, and cites Verner as using this language in his 1965 paper which " claims to show that, given factors causing fluctuations of the population's primary sex ratio, a 1: 1 sex-ratio production proves the best overall genotypic strategy ".

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