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There can be When there are two or more scrollable frames under mouse cursor, only one frame should be scrolled. Gecko decides one scrollable frame for the target by following rules:
→Gecko honors mouse cursor position
Note that on Windows, most mouse drivers honors keyboard focus rather than mouse cursor position. However, Internet Explorer and other web browsers honor the cursor position too. So, it's not a problem, probably.
# Finds a frame under mouse cursor.