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
Muscle Outlaw'z own personal referee. He allowed the MO'z members to break the rules and he used fast counts when they pinned their opponents, and he also refused to count pinfalls done to MO'z members and would sometimes even attack opponents. The group became the refuge for any heel wrestler visiting Dragon Gate, their membership list including Pentagon Black, Kevin Steen, Muscle Gang, and Arik Cannon. This has caused their membership to become the highest in Dragon Gate history. Kishiwada would become more of a part-time member, spending increasing amounts of time away from Dragon Gate, and Naoki Tanisaki would eventually leave