Modern debate on the term was sparked by conservative critiques of assumed liberal bias in academia and education, and conservatives have since used it as a major line of attack. University of Pennsylvania professor Alan Charles Kors and lawyer Harvey A. Silverglate connect speech codes in US universities to Frankfurt School philosopher Herbert Marcuse. They claim that speech codes create a "climate of repression", arguing that they are based on "Marcusean logic". The speech codes, "mandate a redefined notion of "freedom", based on the belief that the imposition of a moral agenda on a community is justified", a view which, "requires less emphasis on individual rights and more on assuring "historically oppressed" persons the means of achieving equal rights". Kors and Silverglate later established the Foundation for Individual Rights in Education (FIRE), which campaigns against infringement of rights of due process, in particular "speech codes".