A count may be started at any time that a wrestler's shoulders are down (both shoulders touching the mat), back-first and any part of the opponent's 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 their foot gently on the opponent's body, prompting a three-count from the referee.