or lands outside the field perimeter, the batter is out. However, the caught ball is in play and base runners may attempt to advance. A foul ball is different from a foul tip, in which the ball makes contact with the bat, travels directly to the catcher's hands, and is caught. In this case, the ball remains live and a strike is added to the batter's count. A batter who hits a foul tip with two strikes on the count is out. In kickball, foul ball does not make a strike, but four foul balls make an out. History Until the 1920s, Major League Baseball spectators were often ejected if they attempted to keep foul balls, and teams employed security guards to ensure it. Negative public sentiment combined with a decrease in the cost of baseballs relative to team revenues caused several teams to change their foul ball policies during this period; the New York Giants changed theirs after losing a New York Supreme Court case (Reuben Berman vs. National Exhibition Co.) filed by Reuben Berman. Berman, a businessman, was ejected in 1921 after tossing a foul ball he caught into the stands. Strategies In different situations, a foul ball may be considered a positive or negative outcome of a pitch or swing. When there are zero or one strikes, a foul ball counts as a strike, benefiting the pitcher. However, a foul ball may reveal to the batter that he has timed a pitch well and need only make adjustment to the location of his swing on the next such pitch; this is often called a good cut or simply a good swing. Foul balls with two strikes are generally considered positive for the batter, since he thus avoids strike three on a potentially difficult pitch. Also, foul balls with two strikes increase the pitcher's pitch count, adding to his/her fatigue, thus providing some small advantage to the offense. A strategy of swinging on any ball to try to produce additional fouls and prolong an at-bat is often used against strong pitchers to try to drive them from the game sooner (and also the possibility of the pitcher throwing a pitch a hitter can get a hit on); this does, however, have the disadvantage of generating more strikeouts. In very specific circumstance—such as in the bottom of the ninth inning (or later) of a tie game when a runner