In biology, the idea of an unbeatable strategy was proposed by W.D. Hamilton in his 1967 paper on sex ratios in Science. In this paper Hamilton discusses sex ratios as strategies in a game, and cites Verner as using this language in his 1965 paper which "claims to show that, given factors causing fluctuations of the population's primary sex ratio, a 1:1 sex-ratio production proves the best overall genotypic strategy".
The concept can be traced through R.A. Fisher (1930) to Darwin (1859); see Edwards (1998). Hamilton did not explicitly define the term "unbeatable strategy" or apply the concept beyond the evolution of sex-ratios, but the idea was very influential. George R. Price generalised the verbal argument, which was then formalised mathematically by John Maynard Smith, into the evolutionarily stable strategy (ESS).