This theorem states that, as the thermodynamic temperature of a system in thermodynamic equilibrium approaches zero, the changes in both the Helmholtz function and the internal energy in an isothermal process tend to zero.  Eugene Simon reformulated this lemma from the restrictive form just given, which is known as the new heat theorem, into a statement whose clear consequence is that it is impossible to reduce the temper
This theorem states that, as the thermodynamic temperature of a system in thermodynamic equilibrium approaches zero, the changes in both the Helmholtz function and the internal energy in an isothermal process tend to zero.  Eugene Simon reformulated this lemma from the restrictive form just given, which is known as the new heat theorem, into a statement whose clear consequence is that it is impossible to reduce the temperature of a system to absolute zero by a finite number of thermodynamic cycles.  Also called Nernst's heat theorem, name - for 10 points - the law that states the entropy of a system approaches zero as its temperature approaches zero.
This theorem states that, as the thermodynamic temperature of a system in thermodynamic equilibrium approaches zero, the changes in both the Helmholtz function and the internal energy in an isothermal process tend to zero.  
third law of thermodynamics (accept Nernst's new heat theorem before it's mentioned)