Graham's statement about the possible bias of First Round is unfounded. This was not any sort of a real study like Graham thinks and First Round clearly notes that. When the returns are as skewed as they are in venture capital (http://www.sethlevine.com/archives/2014/08/venture-outcomes-...), a small sample size and a simple analysis won't do. First Round even excluded their investment in Uber because it would skew the results too much.