Previous Uses:

1) Don King's hair;

2) Non-cancellation of Anna Nicole Smith Show;

3) Result of last Presidential Election;

4) James Traficant Jr.'s lawyering skills -- and his hair -- his membership in Congress -- everything about him, really;

5) Halle Berry's entrance in Die Another Day;

6) Ability of Helen Thomas to refrain from strangling Ari Fleischer at any given press conference;

7) Childbirth;

8) Inability of Gorilla to damage Samsonite luggage;

9) 1996 first-round victory of Princeton Tigers basketball team over defending champion UCLA on backdoor layup with 3 minutes left in game;

10) The Atkins Diet.

Feel free to add your own in the comments.