Legislatures have reduced infringement by narrowing the scope of what is considered infringing. Section 512(c) applies to online service providers that store copyright infringing material. Freescale was sued by Marvell Semiconductor for infringing seven patents. Each found that Nokia was not infringing on Qualcomm's patents. The bill specifically targets websites dedicated to illegal or infringing activity. SOPA targets only foreign Web sites that are primarily dedicated to illegal and infringing activity. The law is rarely enforced due to concerns of infringing civil liberties. A higher standard is used in reviewing legislation infringing on personal liberties. Google may facilitate the user's access to infringing images. Jobs claimed that the project is infringing Apple's IP. Some WHO officials have privately criticized GAVI for infringing and weakening the WHO's mandate. The browser then interacts with the computer that stores the infringing image. Teams are given penalty points for infringing various rules. Co. (MSD) over infringing use of the Merck name.