The receiving team is penalized 15 yards if the receiver initiates contact with any member of the kicking team after delivering a fair catch signal but before the ball is touched by any player. A fair catch has been made by several types of football developed from particular English school football games of the nineteenth century. They include drop-back yardage offense (used by most college teams), sweep-off tackle offense (used by some high school teams), and wild-cat offense (used primarily by college teams). The rule was created to protect defensive players from being injured by careless or unwarranted tackles after a fair catch. Before the rule, receivers could often be stopped by a big hit from behind at the point of delivery. Since fair catches are usually followed by quick handoffs, it is important that the quarterback release the ball quickly so that his protection can get into position. There are two ways for a receiver to initiate contact with an opposing player after he has delivered a fair catch: a forward jump with both feet or a lateral jump. A forward jump brings the receiver inbounds, while a lateral jump does not. Contact between a receiver who has made a fair catch and an opponent results in a foul. The referee will call "fair catch," and then place him on the side opposite the foul. If a defender makes contact with the receiver after he has made a fair catch, the penalty is 15 yards.