Professional wrestling body is lying over the wrestler. This often results in pins that can easily be kicked out of, if the defensive wrestler is even slightly conscious. For example, an attacking wrestler who is half-conscious may simply drape an arm over an opponent, or a cocky wrestler may place his foot gently on the opponent's body, prompting a three-count from the referee. Illegal pinning methods include using the ropes for leverage and hooking the opponent's clothing, which are therefore popular cheating methods for heels, unless certain stipulations make such an advantage legal. Such pins as these are rarely seen by the
Professional wrestling future match to determine the winner. To score by submission, the wrestler must make his opponent give up, usually, but not necessarily, by putting him in a submission hold (e.g. figure four leg-lock, arm-lock, sleeper-hold). A wrestler may voluntarily submit by verbally informing the referee (usually used in moves such as the Mexican Surfboard, where all four limbs are incapacitated, making tapping impossible). Also, since Ken Shamrock popularized it in 1997, a wrestler can indicate a voluntary submission by "tapping out", that is, tapping a free hand against the mat or against an opponent. Occasionally, a wrestler will reach for