In 1981, Frank Tipler put forth an argument that extraterrestrial intelligences do not exist, based on the absence of von Neumann probes. Given even a moderate rate of replication and the history of the galaxy, such probes should already be common throughout space and thus, we should have already encountered them. Because we have not, this shows that extraterrestrial intelligences do not exist. This is thus a resolution to the Fermi paradox – that is, the question of why we have not already encountered extraterrestrial intelligence if it is common throughout the universe.

A response came from Carl Sagan and William Newman. Now known as Sagan's Response, it pointed out that in fact Tipler had underestimated the rate of replication, and that von Neumann probes should have already started to consume most of the mass in the galaxy. Any intelligent race would therefore, Sagan and Newman reasoned, not design von Neumann probes in the first place,