Kirchhoff in 1860 introduced the theoretical concept of a perfect black body with a completely absorbing surface layer of infinitely small thickness, but Planck noted some severe restrictions upon this idea. Planck noted three requirements upon a black body: the body must (i) allow radiation to enter but not reflect; (ii) possess a minimum thickness adequate to absorb the incident radiation and prevent its re-emission; (iii) satisfy severe limitations upon scattering to prevent radiation from entering and bouncing back out. As a consequence, Kirchhoff's perfect black bodies that absorb all the radiation that falls on them cannot be realized in an infinitely thin surface layer, and impose conditions upon scattering of the light within the black body that are difficult to satisfy.