Which One of the Following Explanations Does Not Describe Why

Which one of the following explanations does not describe why generating transgenic animals is more difficult than plants?

A) The intracellular environment of an animal can be much different than bacteria and even plants.
B) Animal cells do not readily take up plasmid DNA like plant cells.
C) The techniques for cloning animals from a single cell are more challenging than for plants.
D) Genetic material must be inserted into a fertilized egg, then implanted into a living animal; plants can be grown in culture media, and thus, there is no need for implantation.
E) Genetic material is introduced to animal cells in culture media and the animal is allowed to mature in the culture media.