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 match types pinned wrestler makes it to the ring in this time, the match continues. Under these rules, all pinfalls must take place outside of the ring, technically making the match no longer falls count anywhere. Occasionally, this stipulation is listed as having a specific territory in which falls count (e.g. the state, county, or general location the match is in). A new variation of the stipulation, submissions count anywhere, debuted at Breaking Point in a match between D-Generation X and The Legacy. Generally, falls counting "anywhere" still has a "de facto" limitation that the falls occur somewhere inside the arena (due