It is often said that the progression from simple to complex runs counter to the normal statistics of chance that are formalized in the Second Law of Thermodynamics. Strictly speaking, we could avoid this criticism simply by insisting that the Second Law does not apply to living systems in the environment in which we find them. For the Second Law applies only when there is no overall flow of energy into or out of a system, whereas all living systems are sustained by a net inflow of energy.