Professional wrestling referee and are subsequently often used by heels and on occasion by cheating faces to win matches. Even if it is noticed, it is rare for such an attempt to result in a disqualification (see below) and instead it simply results in nullification of the pin attempt, so the heel wrestler rarely has anything to lose for trying it anyway. Occasionally, there are instances where a pinfall is made where both wrestlers' shoulders were on the mat for the three-count. This situation will most likely lead to a draw, and in some cases a continuation of the match or a
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