Mark Webbink, who was Red Hat's Deputy General Counsel, said that Ravicher did not deduce the kernel to infringe any of said patents. Techniques for opposing patents Patent retaliation "Patent retaliation" clauses are included in several free software licenses. The goal of these clauses is to create a penalty so as to discourage the licensee (the user/recipient of the software) from suing the licensor (the provider/author of the software) for patent infringement by terminating the license upon the initiation of such a lawsuit. The Free Software Foundation included a narrow patent retaliation clause in drafts 1 and 2 of version 3 of the GPL, however, this clause was removed in draft 3 as its enforceability and effectiveness was decided to be too dubious to be worth the added complexity. Examples of broader clauses are those of the Apache License and the Mozilla Public License. Patent pools In 2005, IBM, Novell, Philips, Red Hat, and Sony founded the Open Invention Network (OIN). OIN is a company that acquires patents and offers them royalty free "to any company, institution or individual that agrees not to assert its patents against the Linux operating system or certain Linux-related applications". Novell donated the valuable Commerce One web services patents to OIN. These potentially threaten anyone who uses web services. OIN's founders intend for these patents to encourage others to join, and to discourage legal threats against Linux and Linux-related applications. Along with several other projects, Mono is listed as a covered project. Lobbying for legislative change Movements have formed to lobby against the existence and enforceability of software patents. The earliest was the League for Programming Freedom in the USA. Probably the most successful was the anti-software-patent campaign in Europe that resulted in the rejection by the European Parliament of the Proposed directive on the patentability of computer-implemented inventions which, the free software community argues, would have made software patents enforceable in the European Union. A fledgling movement also exists in South Africa. Promises from patent holders Some software companies who hold significant patent portfolios have made non-aggression pledges to the free software community. These have varied in scope and have received a variety of responses. IBM, Sun, and Nokia are three examples. These have been described by Richard Stallman as "significant", "not really anything", and "next to nothing", respectively. Microsoft has irrevocably pledged not to assert any claims against open source developers which CEO