The starting point to the biggest refusion of his principle is unorthodox but it does the work: Debates continue that go over the line between life and nonlife.

If we can use an extremely broad, but very useful definition, like that Life is everything that's subject to Darwinian evolution, Smolin proposed that the universe is alive!

Of course, at subsystem level (system=universe) , life and Darwinian evolution is permitted and, for example, Paul Suter points to the issue of existence of non human life in that some creatures existing in very early universe (VEU) conditions would have lived and died in the blink of an eye, their entire history lasting less than a second — being structures that could have stored information. There would have been plenty of energy to go around, and those structures could have self-replicated, enabling Darwinian evolution.

This does not fall under cosmic Darwinian evolution principle, but in subsystem darwinian evolution which is valid.

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