Some skeptics would claim that Darwin’s theory of evolution would be an example of a potential defeater. However, some theists find this to be perfectly harmonious with the Genesis account. See Collins, Francis S. The Language of God: a Scientist Presents Evidence for Belief. New York: Free, 2006 and Miller, Kenneth R. Finding Darwin’s God: a Scientist’s Search for Common Ground between God and Evolution. New York: Cliff Street, 1999.