Sampling error estimation in forensic DNA testimony was discussed. Is an estimate necessary and how should it be made? The authors find that all modern methods have areas of strength and weakness. The assessment of which is the 'best' is subjective and depends on the performance of the method, the type of problem (criminal work or paternity), the database size and availability of computing software and support. The authors preferred the highest posterior density approach for performance, however the other methods all have areas where their performance is adequate. For single-contributor stains normal approximation methods are suitable, also the bootstrap and the highest posterior density method. For multiple-contributor stains or other complex situations the match probability expressions become quite complex and it may not be possible to derive the necessary variance expressions. The highest posterior density or the bootstrap provide a better general method, with non-zero theta. The size-bias correction and the factor of 10 approaches may be considered acceptable by many forensic scientists as long as their limitations are understood.