Paterson Joseph, Shakespeare Mastermind

Personally I don't know who this gentleman is, I had to go look him up on IMDB. Seems he's done mostly work on UK rather than US features. Fair enough.  He popped up in my newsfeed this morning for a Shakespeare mention, and here's what he had to say:

Mastermind specialist subject
Shakespeare. When I watch Pointless and there are any Shakespeare questions I nearly always get them all, and I feel like I’d probably know more about Shakespeare than I do about anything else, as a sort of general knowledge thing. So yeah, it would be Shakespeare, but I’d have to read all 36 plays again.

Anybody else notice something odd right at the end, there?  36? I hear 37 most often, and sometimes 38, but I can't remember the last time I heard 36. When somebody says that, which play are they not counting? Henry VIII?