  Through the formulation of his law of thermal emission, Kirchhoff conferred
upon blackbody radiation the quality of universality [G.Kirchhoff, Annalen der
Physik 109, 275 (1860)]. Consequently, modern physics holds that such radiation
is independent of the nature and shape of the emitted object. Recently,
Kirchhoff's experimental work and theoretical conclusions have been
reconsidered [P.M.L. Robitaille, IEEE Transactions on Plasma Science 31(6),
1263 (2003). In this work, Einstein's derivation of the Planckian relation is
reexamined. It is demonstrated that claims of universality in blackbody
radiation are invalid.
