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 if the wrestler does not. If the referee reaches the count of five, and the wrestler still does not break the hold, he is disqualified. If a manager decides that his client wrestler should tap out, but cannot convince the wrestler himself to do so, he may "throw in the towel" (by literally taking a gym towel and hurling it into the ring where the referee can see it). This is the same as a submission, as in kayfabe the manager is considered the wrestlers agent and therefore authorized to make formal decisions (such as forfeiting a match) on the