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Simple scaling laws for laser-generated fast electron heating of solids that employ a Spitzer-like resistivity are unlikely to be universally adequate as this model does not produce an adequate description of a material's behaviour at low temperatures. This is demonstrated in this paper by using both numerical simulations and by comparing existing analytical scaling laws for low temperature resistivity. Generally, we find that, in the low temperature regime, the scaling for the heating of the background material has a much stronger dependence on the key empirical parameters (laser intensity, pulse duration, etc.).