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valid estimates using lme4?

It is impossible to determine if SAS, Stata, or SPSS are implementing the steps they claim to implement since the source code is not available. It is one thing to be able to write out the algebraic expression for solving mixed models, whether using Henderson's mixed model equations (SAS) or any other approach. 

Part of unit testing software does involve simulation and testing to ensure one recovers back the anticipated parameters. However, "validation" is NOT comparing output from one program to another.

Differences in various rule implementations (such as when to stop) can alter parameter estimates between programs. 

I would proposed validation requires the ability to review

1) The mathematical model proposed to implement the mixed model solution
2) A review of source code to ensure that code aligns with the mathematical model
3) Unit testing with some simulation

Since step (2) is impossible for SAS, Stata, and SPSS, how can they be validated? The source code and mathematical model are available for lme4 functions.

I assume the reviewer assumes they are valid because they are sold. In which case, I'm sure Doug Bates would be happy to collect a donation to bring him up to "validation" standards if that is what is required