In 1900, while studying black-body radiation, the German physicist Max Planck suggested in his "On the Law of Distribution of Energy in the Normal Spectrum" paper that the energy carried by electromagnetic waves could only be released in packets of energy. In 1905, Albert Einstein published a paper advancing the hypothesis that light energy is carried in discrete quantized packets to explain experimental data from the photoelectric effect. Einstein theorized that the energy in each quantum of light was equal to the frequency of light multiplied by a constant, later called the Planck constant. A photon above a threshold frequency has the required energy to eject a single electron, creating the observed effect. This was a step in the development of quantum mechanics. In 1914, Robert A. Millikan 's highly accurate measurements of the Planck constant from the photoelectric effect supported Einstein's model, even though a corpuscular theory of light was for Millikan, at the time, "quite unthinkable". Einstein was awarded the 1921 Nobel Prize in Physics for "his discovery of the law of the photoelectric effect", and Millikan was awarded the Nobel Prize in 1923 for "his work on the elementary charge of electricity and on the photoelectric effect". In quantum perturbation theory of atoms and solids acted upon by electromagnetic radiation, the photoelectric effect is still commonly analyzed in terms of waves; the two approaches are equivalent because photon or wave absorption can only happen between quantized energy levels whose energy difference is that of the energy of photon.