Eisenhardt (1989) is one of the most frequently cited studies on the methodological fundamentals of the case study for theory construction. This paper will first summarize the methodology espoused by Eisenhardt (1989). Eisenhardt suggests nine steps for conducting a case study as an effective research method for theory construction. However, most of the research that cites Eisenhardt only emphasizes generalizability. To be sure, Eisenhardt (1989) takes a stance of positivism and has an awareness of quantitative empirical research. However, he does not necessarily advocate only generalizability. Regardless, some studies that have drawn on Eisenhardt (1989) have emphasized only generalizability. This has the potential of restricting theory construction using case studies.