In 1910-1917, L. Brusotti showed that this is not the case. He found inductive constructions of M-curves based on classical small perturbation which were different from the methods of Harnack and Hilbert.
Before describing Brusotti's constructions, we need some definitions. A simple
arc 
 in the set of real points of a curve 
 of degree 
 is said to be a
base of rank 
 if there exists a curve of degree 
 which
intersects the arc in 
 (distinct) points. A base of rank 
 is
clearly also a base of rank any multiple of 
 (for example, one can obtain
the intersecting curve of the corresponding degree as the union of several
copies of the degree 
 curve, each copy shifted slightly).
An M-curve 
 is called a generating curve if it has disjoint bases
 and 
 whose ranks divide twice the degree of the curve. An M-curve
 of degree 
 is called an auxiliary curve for the generating
curve 
 of degree 
 with bases 
 and 
 if the following conditions
hold:
a) The intersection 
 consist of 
 distinct points
and lies in a single component 
 of 
 and in a single component 
of 
.
b) The cyclic orders determined on the intersection 
by how it is situated in 
 and in 
 are the same.
c)  
.
d) If 
 is a one-sided curve and  
, then the base 
 lies
outside the oval 
.
e) The rank of the base 
 is a divisor of the numbers 
 and 
, and
the rank of 
 is a divisor of 
 and 
.
An auxiliary curve can be the empty curve of degree 0. In this  case the rank
of 
 must be a divisor of the degree of the generating curve.
Let 
 be a generating curve of degree 
, and let 
 be a curve of degree
 which is an auxiliary curve with respect to 
 and the bases 
 and
. Since the rank of 
 divides 
, we may assume that the rank is
equal to 
. Let 
 be a real curve of degree 
 which intersects
 in 
 distinct points. It is not hard to verify that a classical
small perturbation of the curve 
 directed to 
will give an M-curve of degree 
, and that this M-curve will
be an auxiliary curve with respect to 
 and the bases obtained from
 and 
 (the bases must change places).  We can now repeat this
construction, with 
 replaced by the curve that has just been
constructed. Proceeding in this way, we obtain a sequence of M-curves
whose degree forms an arithmetic progression: 
 with
. This is called the construction by Brusotti's method,
and the sequence of M-curves is called a Brusotti series.
Any simple arc of a curve of degree 
 is a base of rank 1 (and hence of
any rank). This is no longer the case for curves of degree 
. For
example, an arc of a curve of degree 3 is a base of rank 1 if and only if it
contains a point of inflection. (We note that a base of rank 2 on a curve of
degree 3 might not contain a point of inflection: it might be on the oval
rather than on the one-sided component where all of the points of inflection
obviously lie. A curve of degree 3 with this type of base of rank 2 can be
constructed by a classical small perturbation of a union of three lines.)
If the generating curve has degree 1 and the auxiliary curve has degree 2, then the Brusotti construction turns out to be Harnack's construction. The same happens if we take an auxiliary curve of degree 1 or 0. If the generating curve has degree 2 and the auxiliary curve has degree 1 or 2 (or 0), then the Brusotti construction is the same as Hilbert's construction.
In general, not all Harnack and Hilbert constructions are included in
Brusotti's scheme; however, the Brusotti construction can easily be extended in
such a way as to be a true generalization of the Harnack and Hilbert
constructions. This extension involves allowing the use of an arbitrary number
of bases of the generating curve. Such an extension is particularly worthwhile
when the generating curve has degree 
, in which case there are
arbitrarily many bases.
It can be shown that Brusotti's construction with generating curve of degree 1
and auxiliary curve of degree 
 gives the same types of M-curves as
Harnack's construction. But as soon as one uses auxiliary curves of degree 5,
one can obtain new isotopy types from Brusotti's construction. It was only in
1971 that Gudkov [Gud-71] found an auxiliary curve of degree 5 that
did this.  His construction was rather complicated, and so I shall only
give some references [Gud-71], [Gud-74], [A'C-79] and present
Figure 12, which illustrates the location of the degree 5 curve
relative to the generating line.
Even with the first stage of Brusotti's construction, i.e., the classical small
perturbation of the union of the curve and the line, one obtains an M-curve
(of degree 6) which has isotopy type
,
an isotopy type not obtained using the constructions of
Harnack and Hilbert. Such an M-curve of degree 6 was first constructed in a
much more complicated way by Gudkov [GU-69], [Gud-73] in the late
1960's.
In Figures 13 and 14 we show the construction of two curves of degree 6 which are auxiliary curves with respect to a line. In this case the Brusotti construction gives new isotopy types beginning with degree 8.
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In the Hilbert construction we keep track of the location relative to a fixed
line 
. The union of two conics is perturbed in direction to a
quadruple of lines. One obtains a curve of degree 4. To this curve one
then adds one of the original conics, and the union is perturbed.
In numerous papers by Brusotti and his students, many series of Brusotti M-curves were found. Generally, new isotopy types appear in them beginning with degree 9 or 10. In these constructions they paid much attention to combinations of nests of different depths--a theme which no longer seems to be very interesting. An idea of the nature of the results in these papers can be obtained from Gudkov's survey [Gud-74]; for more details, see Brusotti's survey [Bru-56] and the papers cited there.
An important variant of the classical constructions of M-curves, of which we
shall need to make use in the next section, is not subsumed under Brusotti's
scheme even in its extended form. This variant, proposed by Wiman
[Wim-23], consists in the following. We take an M-curve 
 of
degree 
 having base 
 of rank dividing 
; near this curve we
construct a curve 
 transversally intersecting 
 in 
 points
of 
, after which we can subject the union 
 to a classical
small perturbation, giving an M-curve of degree 
 (for example, a
perturbation in direction to an empty curve of degree 
. The
resulting M-curve  has the following topological structure: each of
the  components of the curve 
 except for one (i.e., except for the
component containing 
 is doubled, i.e., is replaced by a pair of
ovals which are each close to an oval of the original curve, and the
component containing 
 gives a chain of 
 ovals. This new curve does not
necessarily have a base, so that in general one cannot construct a series of
M-curves in this way.