In 1951 Callen and Welton proved the quantum fluctuation-dissipation theorem (FDT) which was originally formulated in classical form by Nyquist (1928) as an explanation for observed Johnson noise in electric circuits. Fluctuation-dissipation theorem showed that when something dissipates energy, in an effectively irreversible way, a connected heat bath must also fluctuate. The fluctuations and the dissipation go hand in hand; it is impossible to have one without the other. The implication of FDT being that the vacuum could be treated as a heat bath coupled to a dissipative force and as such energy could, in part, be extracted from the vacuum for potentially useful work. Such a theory has met with resistance: Macdonald (1962) and Harris (1971) claimed that extracting power from the zero-point energy to be impossible, so FDT could not be true. Grau and Kleen (1982) and Kleen (1986), argued that the Johnson noise of a resistor connected to an antenna must satisfy Planck's thermal radiation formula, thus the noise must be zero at zero temperature and FDT must be invalid. Kiss (1988) pointed out that the existence of the zero-point term may indicate that there is a renormalization problem—i.e., a mathematical artifact—producing an unphysical term that is not actually present in measurements (in analogy with renormalization problems of ground states in quantum electrodynamics). Later, Abbott et al. (1996) arrived at a different but unclear conclusion that "zero-point energy is infinite thus it should be renormalized but not the 'zero-point fluctuations'". Despite such criticism, FDT has been shown to be true experimentally under certain quantum, non-classical conditions. Zero-point fluctuations can, and do, contribute towards systems which dissipate energy. A paper by Armen Allahverdyan and Theo Nieuwenhuizen in 2000 showed the feasibility of extracting zero-point energy for useful work from a single bath, without contradicting the laws of thermodynamics, by exploiting certain quantum mechanical properties.