Kirschmann's Fourth Law states that the magnitude of simultaneous color contrast increases with the saturation of the inducing surround, but that the rate of increase reduces as saturation increases. Others since Kirschmann have agreed and disagreed. Here we show that the form of the relationship between simultaneous color contrast and inducer saturation depends on the method of measurement. Functions were measured by four methods: (i) asymmetric matching with a black surround, (ii) asymmetric matching with a surround metameric to equal energy white, (iii) dichoptic matching, and (iv) nulling an induced sinusoidal modulation. Results from the asymmetric matching conditions agreed with Kirschmann, whereas results from nulling and from dichoptic matching showed a more linear increase in simultaneous contrast with the saturation of the inducer. We conclude that the method certainly affects the conclusions reached, and that there may not be any "fair" way of measuring simultaneous contrast.