The term "puppy mill" has been widely used by animal rights groups in protests against smaller breeders who may appear to have substandard breeding conditions. Such breeders, occasionally labeled hobby breeders, are often cited by animal rights groups as puppy mills. Hobby breeders claim that emotional rhetoric, sensationalism, and pictures of dirty kennels are used to justify additional legislation or additional restrictive licensing that travels well beyond the initial goal of removing dogs from truly deplorable conditions.[12]