Carson Strong argues, in “Cloning and Infertility,” that if cloning of humans by somatic cell nuclear transfer were to become a safe procedure, then infertile couples should have access to it as a last resort. He lists six reasons such couples might desire genetically related children. Of these, two are relevant to justifying their access to cloning—namely, that they want to jointly participate in the creation of a person, and that having a genetically related child would constitute an affirmation of their mutual love. According to Strong, these reasons justify at least some infertile couples' freedom to clone themselves. He wants to prevent the widespread use of cloning technology by making it available to only infertile couples and only as a last resort. One way to enforce this restriction, he suggests, is to penalize physicians who carry out disallowed clonings. After all, fertile couples and many infertile couples can satisfy their need to have genetically related children in other ways.