A recent study conducted by Prather on Zipf-Halstead's theory of software metrication points out the need for a theory which can (1) provide a unified approach for bridging the theories of Zipf and Halstead; (2) derive the two program length estimates of Zipf and Halstead; and (3) generate the distribution satisfying Prather's inequalities. Based on Herbert Simon's creative process for scientific discovery, we show that the Simon-Yule model of text provides a promising theory.