ESO - eso1248 - Even Brown Dwarfs May Grow Rocky Planets:
"Astronomers using the Atacama Large Millimeter/submillimeter Array (ALMA) have for the first time found that the outer region of a dusty disc encircling a brown dwarf contains millimetre-sized solid grains like those found in denser discs around newborn stars. The surprising finding challenges theories of how rocky, Earth-scale planets form, and suggests that rocky planets may be even more common in the Universe than expected."
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