Philosopher Kate Manne of Cornell University defines misogyny as the attempt to control and punish women who challenge male dominance. Manne finds the traditional "hatred of women" definition of misogyny too simplistic, noting it does not account for how perpetrators of misogynistic violence may love certain women; for example, their mothers. Instead, misogyny rewards women who uphold the status quo and punishes those who reject women's subordinate status. Manne distinguishes sexism, which she says seeks to rationalise and justify patriarchy, from misogyny, which she calls the "law enforcement" branch of patriarchy: