Growth and value investing are two distinct investment styles that have piqued the interest of both investors and academics. Scholars have come to agree that value investing strategies, on average, outperform growth investing strategies (Chan et al., 2004, p.71). However, the underlying cause of this discrepancy in performance is still highly debated. In the research of Chan and Lakonishoks (2004) they dismantle the thesis that the performance differential is the result of a risk difference and look at behavioral theories that can explain the superior value investing strategy. The researchers hypothesize that individual investors have a tendency to use simple heuristics when choosing a stock, resulting in a selection of stocks with recent high earnings but a lack of consistent earnings (p.76-77). This behavioral analysis parallels Statman's (2004) use of behavioral analysis of individual investors' tendency to use simple heuristics in their decisions not to diversify their portfolios (p. 44). Chan and Lakonishoks' (2004) use of behavioral theory to call attention to an excellent explanation for the improved performance of value stocks indirectly reinforces Statman's conjectural use of behavioral theory to justify the lack of diversification among individuals.