But, as offending someone is less serious than harming someone, the penalties imposed should be higher for causing harm. In contrast, Mill does not support legal penalties unless they are based on the harm principle. Because the degree to which people may take offence varies, or may be the result of unjustified prejudice, Feinberg suggests that a number of factors need to be taken into account when applying the offence principle, including: the extent, duration and social value of the speech, the ease with which it can be avoided, the motives of the speaker, the number of people offended, the intensity of the offence, and the general interest of the community at large. Jasper Doomen argued that harm should be defined from the point of view of the individual citizen, not limiting harm to physical harm since nonphysical harm may also be involved; Feinberg's distinction between harm and offence is criticized as largely trivial. In 1999, Bernard Harcourt wrote of the collapse of the harm principle: "Today the debate is characterized by a cacophony of competing harm arguments without any way to resolve them. There is no longer an argument within the structure of the debate to resolve the competing claims of harm. The original harm principle was never equipped to determine the relative importance of harms." Interpretations of both the harm and offense limitations to freedom of speech are culturally and politically relative. For instance, in Russia, the harm and offense principles have been used to justify the Russian LGBT propaganda law restricting speech (and action) in relation to LGBT issues. A number of European countries that take pride in freedom of speech nevertheless outlaw speech that might be interpreted as Holocaust denial. These include Austria, Belgium, Canada, the Czech Republic, France, Germany, Hungary, Israel, Liechtenstein, Lithuania, Luxembourg, Netherlands, Poland, Portugal, Russia, Slovakia, Switzerland and Romania. Armenian Genocide denial is also illegal in some countries. In the U.S., the standing landmark opinion on political speech is "Brandenburg v. Ohio" (1969), expressly overruling "Whitney v. California". In "Brandenburg", the US Supreme Court referred to the right even to speak openly of violent action and revolution in broad terms: The opinion in "Brandenburg" discarded the previous test of "clear and present danger" and made the right to freedom of (political) speech's protections in the United States almost absolute. Hate speech is also protected by the First Amendment in the United States, as decided in "R.A.V. v. City of St. Paul", (1992) in which the Supreme Court ruled that hate speech is permissible, except in the case of imminent violence.