American football requires that the catcher signal in advance, as did Canadian football before that game abolished the fair catch. Rugby union requires a player to signal a fair catch by catching the ball and shouting "Mark!". In some forms of football a player fielding an opponent's kick must be given a certain circular unobstructed space around him in which to do so by either some or all opponents. In rugby union, rugby league, and Canadian football this applies only against members of the kicking team who are offside, and applies whether the ball is in the air, bouncing, or rolling. In Arena Football, there is no fair catch; however all members of the kicking team must refrain from penetrating the five-yard line in coverage, but only while the ball is in the air. The various games differ as to the conditions under which a fair catch will be awarded — for example, whether the ball must be caught "cleanly", i.e. without juggling. Rugby union requires a clean catch. American football allows the ball to be juggled, but not to be intentionally batted forward to improve the position of the catch (as for a free kick at goal). Australian rules is most generous, allowing unlimited hand play with the ball before it is caught, and allowing the kick to be from any other player, regardless of team (however, the ball must have travelled 15 metres) and the ball can even be dropped so long as the player is deemed to have sufficient control of its fall. In the 19th century in rugby, and into the 20th in American and Canadian football, a fair catch was allowed from certain kicks of a teammate—a punt-out or punt-on.