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 a rope (see rope breaks below), only to put his hand back on the mat so he can crawl towards the rope some more; this is NOT a submission, and the referee decides what his intent is. Submission was initially a large factor in professional wrestling, but following the decline of the submission-oriented catch-as-catch-can style from mainstream professional wrestling, the submission largely faded. Despite this, some wrestlers, such as Chris Jericho, Ric Flair, Bret Hart, Kurt Angle, Ken Shamrock, Dean Malenko, Chris Benoit, and Tazz, became famous for winning matches via submission. A wrestler with a signature submission technique is